-------
NCP REFERENCE INDEX (CONT'D)












300.70(b)(l)Uii)
slurry walls
300.70(S)(l)(iii)
grout curtains
J00.70(b)(l)(iii)
(C)
ground water
pumping
300.70•

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Anonymous B
Anonynou* C
Biocraft
Ch«tical Metals Industries
Chenical Recovery System
College Point
Fairchild Republic
General Electric
Gallup
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-------
NCP REFERENCE INDEX (CONT'D)










300.70(b)(2)(ii)
neutralization
300.70(b)(2)(ii)
equalization
300.70(b)(2)(ii)
air stripping
300.70(b)(2)(ii)
carbon absorption
300.70(b)(2Hiii)(C)
solidification
300.70(b)(2)(iii)(E)
in situ soil treatment
300.70(b)(2)(iii)
solution mining








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Houston Chemical
Howe, Inc.
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Occidental Chemical
PP&L - Stroudsburg
Quanta Resources
Richmond Sanitary
Tramnell Crow


University of Idaho
Vertac Chemical

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-------
NCP REFERENCE INDEX (CONT'D)
























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300.70(b)(2)(iii)
neutralization
300.70(b)(2)(iii)
microbiological
degradation
300.70(c)
off-site transport
300.70(c)(l)
off-site transport
for destruction
300.70(c)(l)(ii)
off-site transport;
capacity to manage
hazardous wastes



300.70(c)(2)(l)
removal of
contaminated soil
and sediments








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-------
NCP REFERENCE INDEX (CONT'D)










300.70(b)(2)(iii)
leutralization
300.70(b)(2)(iii)
nicrobiological
degradation
J00.70(c)
off-site transport
300.70(c)(l)
aff-site transport
for destruction
J00.70(c)(l)(ii)
aff-site transport;
:apacity to manage
lazardous wastes
J00.70(c)(2)(i)
removal of
:ontaminated soil
and sediments

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Anonymous B
Anonymous C
Biocraft
Chemical Metals Industries
Chemical Recovery Systems
College Point
Fairchild Republic
General Electric
Gallup
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J00.71
worker health and
safety








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300.70(d)(2)
provision of alter-
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Houston Cheaic*!
Howe, Inc.
Marty'i CMC
H.W. Hauthe
Occidental Chemical
??&L - Stroudsburg
Quanta Resource*
Richaond Sanitary
Traanell Crow
University of Idaho
Vertac Chemical
NCP REFERENCE INDEX (CONT'D)
-------
-------
                               CASE STUDY REPORTS

                                ANONYMOUS SITE  A

                            NORTH-CENTRAL CALIFORNIA
 INTRODUCTION
     Approximately  100 acres  (40 ha)  of  surface  impound-
ments  containing  pesticide   and fertilizer  wastewater  is
 located  on the  property of  a  large agricultural  chemical
products  manufacturer, which will be referred  to  as  "Anon
A" in  the following  case  study.  The site is underlain  by
relatively  impervious   (10~7   cm/sec)   Bay   Mud,   which
prevents   downward  migration of wastes,  but  seepage and
overflow   through  the dikes  occurred several  times  since
the  facility opened  in  the  early 1950's.  During a  heavy
100-year   rainstorm  in  February 1980,  about  3.5 million
gallons    (1.3   x   10~71)    of   fertilizer  waste   water
containing 2,400 mg/1 ammonia was discharged  into  a  slough
leading  to the  nearby Bay  to  prevent  overtopping of the
dikes  and  feared dike failure.

Background

     The  existing  100  acre  (40  ha)  pond  system  was  built
primarily  in the late 1950's and  early  1960's.   There are
about  56  acres  (23 ha)  of pesticide waste-water  ponds and
32  acres   (13  ha)   of  fertilizer  wastewater.   Seepage
through  the  dikes  and  overflow  of  the ponds   occurred
several times  during  subsequent years because of cracks  in
the  dikes  and heavy  winter  rainstorms.   During  the  early
1970's in  response to these  problems, Anon A repaired and
upgraded  the  dikes by widening and adding clay  covers  to
various sections of  the  dikes to increase their structural
strength and prevent  slumping and seepage.  These modi-
fications  were not intended  to  increase  overall  capacity.
Until  1980, most of  the  releases of waste water were  small
volumes, under 100 galllons  (379  1) and  were  reported  to
the  California Regional Water Quality Board (WQCB).

     In February  1980  a heavy,  100-year  rainstorm filled
the  ponds  close  to   their capacity.  A  representative  of
Anon A called  the  WQCB on February 20,  1980,  reported that
the  waste  ponds were  on  the  verge of overtopping  the
dikes,  and requested  permission to discharge  some  waste
water to relieve the pressure on the dikes.  The

                            1-1
NCP  Reference
300.65(a)(3)
notification by
permit holder
-------
alternatives were  to;  (1) allow overtopping  of all ponds
which might  have resulted in  a 40 million gallon (1.5 x
10    1)  discharge  from  complete  dike  failure,  (2)  dis-
charge  to  the  sewer  system  or (3)  discharge  the least
hazardous wastewater  to  provide additional  pond capacity
into which  one of  the more  toxic  wastes  could be trans-
ferred.   WQCB believed  the  latter alternative  to be the
most  desirable  and  it  allowed the company to lower the
pond level of the Fertilizer Pond by releasing  3.5 million
gallons (1.3 x 107  1) to the adjacent slough which  emptied
into the Bay.  Following the discharge, a Cease and Desist
Order was issued to Anon A to prevent future releases.

Synopsis of Site Response

     Anon A  undertook  two  major  site  response  actions
following the  February 1980  release and subsequent Cease
and Desist Order to increase the capacity and integrity of
its pond system:

     •  About  75 million  gallons  (2.8 x 10   1) of waste-
        water were  pumped out of the  fertilizer and pesti-
        cide   ponds and trucked  to   approved   Class I and
        Class  II-l  landfills; and

     •  The  dikes  were  reinforced  by   increasing their
        thickness  and height, and  an ASPEMIX cut-off wall
        was   installed  along   the  northern,   western  and
        southern   dikes   of West Pond   in  1980, and around
        the  Fertilizer Pond and Pond  2  in  1982.

This  report  will focus on the ASPEMIX cut-off wall because
of  its  innovative  design  and  unique cost components.

     The  ASPEMIX   cut-off  wall  is  an underground  wall
composed  of asphalt  emulsion,  sand, concrete  and water.
The  ASPEMIX material is  installed much like a  grout cur-
tain,  with  side by side  injections,  however,  a  vibrating
beam  on a 80-ton crane is used, similar to a  pile driving
operation.   After  vibrating  a specially designed  I-beam,
approximately  17   feet  (5m)   long,   into  the  ground  and
through the Bay Mud below, ASPEMIX  is  injected while  the
beam   is  withdrawn.    Two-thirds  of  the  dike  perimeter
cut-off wall  have been  finished.   The  final  third  is
anticipated  to be  completed  in 1983.
300.68(e)(2)(iv)
environmental
effects
300.68(c)
responsible
party clean-up
300.70(c)(l)(2)
offsite
transport

300.70(b)
UiiXA)
impermeable
barrier
 SITE DESCRIPTION

      The Anon A site is  located  in northern  California.
 The  chemical  manufacturing  facility  occupies about  140
 acres (56 ha)  and can be  divided into two  general areas
                                      1-2
-------
 that are separated by  Street  X (see Figure  1).   The area
 southeast of Street consists of chemical manufacturing and
 storage  facilities;  and  office  facilities  and  occupies
 approximately 40  acres  (16  ha).   The   remainder  of  the
 facility property is to  the northwest  of Street X  and is
 occupied by  a solar  evaporation and wastewater  treatment
 pond system and  a fertilizer plant.

 Surface Characteristics

      The county  in which Anon A is  located can be  divided
 into four geomorphic units  based on differences  in land-
 form.   These units are:   (1)  hilly to very  steep  uplands
 within  the  Coastal  Range,  (2)  terraces, fans, and  flood
 plains  in the valleys,  (3)  river channels and  delta over-
 flow land and (4)  tidal flats  of the bays.  The site prop-
 erty lies within  the  latter of  these  units,  in what  was
 once a tidal marsh, where the ground surface  is  approxi-
 mately  the  same  elevation  as  mean high  water.    Surface
 drainage  in the  vicinity of  the site is  west  towards a bay
 which merges with the larger Bay.   The  smaller  bay will be
 referred  to as "the bay"  in  this report.

      Historically,  the  evaporation  pond  area  was dissected
 by numerous  natural sloughs and man-made ditches  through
 which surface runoff passed  from the east to  the bay.  The
 main slough  with  which  the other  drainageways connected
 was   located  just  north  of  the  present-day   fertilizer
 plant.   Many of  these  former sloughs and drainage  ditches
 influenced  the layout and configuration  of the  16  existing
 dikes.   With the development  of the fertilizer plant  and
 the  evaporation  pond  system,  offsite   surface  drainage
 across  the  site has been  diverted into constructed  ditches
 that direct  flow  to  Creek  X  which then  drains  into  the
 bay.

     The  bay area   is used   by both city  residents  and  the
 the  wildlife  inhabiting the  area.    It is used  for  recrea-
 tion, navigation, and   as  an  industrial  water  supply.   In
 In  addition,  it  is  the habitat  and  resting  area  for
 waterfowl and migratory birds, a habitat  for  shellfish  and
 part of numerous fish species' migration  routes.

     The  local climate of the   county is  strongly  influ-
 enced by  both topography  and   its proximity to San  Fran-
 cisco Bay.   The area  adjacent  to  the  bay,  in which  the
 site is located,  is characterized by cool summers and mild
winters.  The  influence of marine air is reflected in  the
moderate  average  July  temperature  of 62°F  (16.7°C).   The
month of September brings  slightly  higher   temperatures,
with  an  average  of  65°F (18.3°C).    During  the  winter
300.68(e)(2)(i)
extent of dangejr
to public
300.68(e)(2)
(i)(E) climate
                                     1-3
-------
                                                                A
         WEST
          POHO
         STORM
         WATftR
              Figure 1.  Anon A Facility Pond Locations
(Source: Anon A Facility, CA)
                               1-4
-------
 months, temperatures will average 50°F (10°C).  The annual
 average temperature is approximately 58°F (14.4°C).

      Late  in  the  spring  and through  the  summer  season,
 coastal fog is common in  the  early  morning  hours in areas
 adjacent to  the  bay, usually clearing by midday.   Winds
 are  steady and  generally  prevail  from  a  south-south-
 westerly direction, at velocities between 15  and 25 knots
 (24-40 km/hr) during  daylight hours and  decreasing  to 10
 knots (16  km/hr)  or less in  the evenings.    The humidity
 during winter months  averages about  90 percent  at  night
 and 70 percent in  the afternoons.   During the period from
 July  to  September  the  humidity is  much less,  averaging
 about 55 percent.

      Precipitation in the area is highly variable, ranging
 from  .05  inches  (0.13 cm)  during  August to  more  than  5
 inches (12.7 cm)  in December. The  average annual precipi-
 tation in the area  is approximately  22  inches (56 cm)  per
 year.  It has been  calculated that  1 year out  of  25,  the
 average rainfall  will be  34  inches  (86  cm)  and 1 year out
 of 100, the rainfall will average  40 inches  (1  m).   This
 information is important  in  later  discussions concerning
 wastewater  pond  capacity.   Precipitation in  the  form of
 snowfall,  rarely  occurs  in the lowland areas which include
 the tidal  flats where  the site area is located.

      The  soils   in the  site area are members  of the Reyes    300.68(e)(2)
 series  and  are  characterized as silty clays.   The Reyes    (i)(D)
 series typically   consists of very  poorly drained soils in    hydrogeological
 saltwater   marshes  or  tidal  areas  where  there is regular    factors
 inundation  by  high  tides.  The depth from the  surface of  a
 typical  profile,  is  approximately  5  feet (1.5  m) .    The
 Reyes series  soils are more commonly  known  as Bay  Mud.
 Except for  the pond locations on site,  the Bay Mud  in  the
 area  is  overlaid  by a  placed fill material which ranges in
 thickness between 3 and 10  feet  (.9 and  .3 m).  West of
 Street X the uppermost soil  unit  beneath the treatment  and
 evaporation  ponds is a dark gray silty clay  that  is  rich
 with  organic matter and is highly pervious.  The thickness
 of  the Bay Mud, which  underlies the  organic  silty clay, in
 the  area west of  Street  X,  ranges  from 2.5  (.76 m)  feet
 below the east side of the Fertilization Pond,  to 34  feet
 (10 m) below  the south  end  of the  site.  The Bay Mud is
 not present  east  of Street  X.   In this  area, the  fill,
 instead,  is  directly  underlain  by  alluvium and  the
 soil-type is described as  urban land.

     Below the Bay  Mud,  there lies  what is known as Older
 Bay Mud  which is  darker  in  color and  stiffer in texture
 than  the Younger  Bay Mud.   The thickness of the  Older Bay
Mud ranges  between  2  and 6  feet (.61  and  1.8 m) .   The

                                     1-5
-------
elevation in  the  vicinity of  the  site is  at  or near sea
level and the slope  is  less  than 1 percent.   The soil is
extremely moist  and has  a  permeability between 1.4 10
cm/sec and 4.5 10   cm/sec.

     The  site  is situated on the  outskirts  of  a city1 s
northwest boundary,  with  numerous  other industrial facil-
ities.   The bay  shore  areas  to  the  southwest  and those
that  surround  the the city have been  used  for  industrial
purposes for at least 80 years.  Directly to the northwest
of  the   site,  Creek X  is fed by  another  creek  and  the
marshy  areas  to  the  north  before  entering the  bay (see
Figure 1).

Hydrogeology

     The site is  located along the eastern  shore of a bay.    300.68(e)(2)
The entire  bay area is  a drowned  river valley within  a    (i)(D)
northwest trending   structural trough  formed in  Franciscan    hydrogeological
bedrock.  The bay was formed when a block   of bedrock, was    factors
tilted  towards  the  east;  the  uplifted  western edge of the
block  forming  hills  and  the  downdropped eastern  edge
creating the depressioa which  is now Bay X.  Subsequent to
the  downdropping  of the  block,  material eroded from the
eastern  hills  and was deposited in  alluvial  fans to form
the  gently  sloping plain that borders the  eastern shore-
line of  the bay where the site is located.

     There  are  four  major  geologic units  that  occur
beneath  the site  area  and they are listed  below according
to relative age,  the youngest  appearing first:

     •   Younger Bay  Mud - clayey sandy silt and  silty clay
         with organic matter and  shells

     •   Old Bay Mud  -  stiff  silty clay with sand  and  fine
         gravel

     •   Estuary  deposits  and  alluvium  -  interfingering
         estuary and  alluvial  fan deposits of varying ages;
         silty  and  sandy  clays  with   interbedded  clayey
         gravels and  gravel lenses

      •   Franciscan bedrock -  sandstones and siltstones  of
         the Franciscan  formation.

      Because  the  site is located  near an  inundated  zone,
 in  an area  that  is  nearly level, the underlying  subsurface
 conditions  reflect even  minor fluctuations that  occurred
 in  the  bay water level  in  the way of  extensive interfin-
 gering  of alluvial material  (sediments from the surround-
 ing  hills) and  estuarine or marine  sediments.  The  Bay

                                      1-6
-------
 Muds  are  the  most   recent  deposits  in  this  alluvial-
 estuarine sequence.   The  Bay Mud units were  described  in
 the ^ previous  section on  soils  and  will  not  be  discussed
 again  in  this  section.    The  following  discussion
 concentrates  on  the  alluvium  and  estuary  deposits  and
 Franciscan bedrock that lie below the  Bay Mud.

      The texture of the alluvium is  variable, ranging from
 brown and grayish-brown  silty clays  to  silty sands  with
 fine gravel  lenses.   This  variability reflects  two  pro-
 cesses that have  taken  place during the  formation  of  the
 alluvial  fans  in the  site  area.    The  first  process
 reflects the  gradual  erosion  of  the   hills  and  slow
 deposition of  the  eroded  sediments  in a series  of  poorly
 sorted sheet  wash deposits.   Deposition  of the  coarser
 gravel and sands generally occurs in the  upper part  of the
 fan while  the  silts  and  clays  are  deposited  along  the
 fans'  outer most  flat-lying portions.  The  second process
 involves run-off  flowing  through channels across the  fan
 surface   transporting  and  sorting  sediments,  and  storms
 carrying coarse sediment onto the fan's distal section.

      The  estuary deposits  consist of brownish-gray to gray
 silty clays  and clayey silts  deposited in the quiet, shal-
 low marine environment of  the early bay.   These  clays  are
 often  calcareous and  contain  shell fragments.   The estuary
 sediments at the site may also contain an alluvial  compo-
 nent due to the  site's  proximity to present and  past bay
 shorelines.   Generally, a shallow,  near-shore  environment
 receives  a large influx of alluvial  sands  and  silts, which
 are reworked by tidal  currents and benthic organisms.

     The   bedrock  material   underlying  the  alluvial-
 estuarine sequence consists  of  sandstones and siltstones
 of  the Franciscan formation.   It occurs  at a  depth of
 approximately  273 feet (83 m) at the  northeast corner of
 the Fert i1izer  Pond,  increas ing  in   depth   towards  the
 northwest  and  the bay.

     The  alluvial  deposits, consisting primarily of  sands
 and  silts with  occasional gravel, constitute the principal
 shallow  water-bearing  strata.    The  estuarine  deposits
 consist mainly of clays and organic clays  and silts that
 have low  to very low permeabilities.   Therefore, potential
 ground water  development  for drinking  water  sources  or
 industrial uses within the site  area  is  limited.   Pres-
 ently, within  the  site area,  there is  only  one  deep well
 that was  completed in the  sand  and  gravel  zones between
depths of 100 and 170  feet  (30.5  and  52 m) and is used for
 industrial purposes.  Within a 2-mile (3 km)  radius of the
 site, there are only  two privately owned  wells registered
 for domestic use.  Both wells are located  northeast of the

                                     1-7
-------
site  and  were  completed  in  sands  and gravels  at depths
between 175 and 240 feet (53 and 73 m).

     The site location can be hydrologically characterized
as  a  regional  discharge  area.    The  principal  source of
recharge in the area are the hills to  the southeast of the
site.   The predominant direction of  ground  water flow at
the site is from the southeast to the  northwest.

     The water  table  is  generally  shallow  over the  site
area,  ranging between  2 and 8 feet  (.61  and 2.4 m) below
the ground surface.  The  height  of the ground water table
within  the site  area   is  greatly affected  by  the estab-
lished  network  of drainage ditches  mentioned earlier, in
addition to  the existing  surface impoundments.   The water
table  tends  to be  higher in  the  vicinity of  both the
drainage ditches and surface  impoundments.

     Within  the sediments  underlying the site,  six  main
water-bearing  zones have been  identified,  based  on the
interpretation  of  available  geophysical  logs  and drill
hole  data.   Four  of  these  zones   are  within  200  feet
(161 m) of the  ground  surface.   All  six zones  appear  to be
continuous over  the  site and have  higher  permeabilities
than  the  intervening  silty-clay  strata.    The  uppermost
zone,   'A' ,  consists  of  placed  fill and  the  underlying
Younger Bay Mud deposits.   Potential usage of ground  water
within this  zone is  considered very  limited  due to the low
permeability  of the  Younger Bay  Mud  deposits.

      The   five  remaining  zones  exist  at depths  below  this
uppermost  unit   and  consist  primarily of  sand-silt-gravel
mixtures   that  are  confined by  clay strata.   These  units
are discussed in order of increasing depth.

      Zone   'C1   consists  of  several  large  discontinuous
sandy  lenses  within  a silty-clay  sequence.    This  zone
extends from elevations  -20 to -90  feet  (-6 and -27  m)
below sea level  (BSL).   The ground  water  in  zone  'C1  is
moderately brackish and based on drinking  water standards
 and chemical analyses, it is  not considered potable.

      The  third zone,   'B1 ,   is  relatively  continuous and
 pnderlies  the  site between  elevations of  -100  and  -130
 feet (-30.5 and -40 m) BSL.  The water within this zone is
 fresh and considered  potable.   The  estuarine  clay acqui-
 clude layer bounding these zones is relatively  impermeable
 and expected to act as a barrier to downward migration of
 contaminants.
                                      1-8
-------
     The  fourth  zone,  'D1 ,  is  also relatively continuous
and occurs between  elevations of -140  and  -200  feet (-43
and -61 m) BSL.   Like  zone 'B1  the water contained within
this unit  is  considered  potable and  the  zone is expected
to be protected from downward migration of contaminants by
the confining clay acquiclude.

     The  remaining  two water bearing zones,  'D1  and 'E',
were  not  investigated during  the  hydrogeologic  studies
conducted on site, due to the depths at which they exist.
WASTE DISPOSAL HISTORY

     As previously described,  the  entire evaporation pond
area, which  includes  the wastewater treatment pond  system
and  the  fertilizer  plant,  lies  within  a  former  tidal
marsh.  Prior  to the  evaporation pond system development,
the  area  was  traversed by  numerous natural  sloughs   and
man-made ditches.   Examination of  an 1898 topographic  map
of  the  area  indicates  that   the   northern  and  eastern
portions of  the  area were  once pasture and farm land.   In
addition, a  trash dump was located  in the northwest  corner
of the  site  and extended  into  the  area  that is presently
occupied by  Pond 3A (see Figure 1).  There appears to have
been no other  man-made  modifications on site prior  to  the
present-day  facility's construction.

     The fertilizer plant  and evaporation pond system were
constructed  during the late 1950's  and early  1960's.  Pre-
construction  preparation  of  the  plant  area  involved   the
removal of several  feet of soft marsh deposits, followed
by placement of compacted  fill onto  the underlying Younger
Bay Mud.  The plant foundation was  then constructed  in  the
placed  fill.   There are several parts of  the facility  in
the  western  portion of the  site   that  are  supported   by
piles due to the thicker marsh deposits in this area.   The
ground  surface  throughout  the plant area  is  presently  at
an elevation of +10 to  +11  feet (3 to  3.4  m)  above mean
sea level.

     The  facility's  pond  boundaries are formed by dikes
that were initially constructed  with soils excavated from
adjacent  marsh areas.    The  initial  elevation  of these
structures  was  between  +8 and +10  feet (2 and 3  m)  and
they  were   probably less  than 10  feet (3m) wide   at  the
base.  Subsequent  to  their  original  construction,   the
dikes  have  been gradually  enlarged,   using  borrow fill
materials of varying composition.   In  September 1980,   all
perimeter dike embankments had been widened to at least  20
feet  (6 m)  at  the base  at  an  elevation  equal to   the
planned maximum  pond level which is +11  feet (3.4  m)   for

                                     1-9
300.68(e)(3)
(iii) extent
of adequacy
of current
containment
barriers
-------
the majority of ponds.  In addition, the  pond  side  of all
exterior dikes have  2.5  feet  (.8 m) additional height  to
provide a minimum  of two feet of freeboard  against  over-
flow by wind  generated waves.   In  conjunction with  con-
struction activities to  increase  the height  and  thickness
of the dikes to permit higher  pond levels, steps  were also
taken to  improve  their stability and  leakage  resistance.
These  modifications   are  further  discussed  in  a   later
section.

     The  facility's  present  disposal/evaporation  pond
system occupies 100 acres (40 ha) of land  and  has a total
capacity of 150 million gallons (5.7 x 10  1).   There are
a total of  14  ponds  in the system which  are divided into
six areas according  to  the  waste-type  contained in  each.
The six areas  are  listed and described  below.

     •  Area 1:  Fungicide ponds
        Includes  evaporation   ponds IE,  1W,  2, 3A,  and BA
        (bioaeration); total   of  45  acres (18 ha)  and used
        for  treatment and disposal  of  carbamate  fungicide
        wastewater  consisting of  primarily sodium salts
        and fungicide  intermediates  (THPA,  THPl)  with
        trace  amounts of carbamate fungicide  and  solvents

     •  Area 2:  Pesticide ponds
        Includes the "Pesticide pond11 and  ponds B and 3E;
        total  of  11  acres (4.4 ha)  and used for  disposal
        of  pesticide aqueous process waste  containing
        salts, some heavy metals,  and pesticides

     •  Area 3:  Fertilizer ponds
        Recycle,  evaporation,  and  borrow poads cover  21
        acres (8.4 ha); wastewater contains ammonium salts
        (primarily chlorides), sulfates,  and nitrates

     *  Area 4:  Storm water
        West  Pond covers about   11 acres (4.4  ha)  and
        receives  rainwater  runoff  from   the  agricultural
        chemical manufacturing areas.  Ponds 1W, 2,  and 3A
        may  also   be  used  to contain  storm  runoff,  as
        required.  Constituents of stormwater runoff are a
        combination  of materials  contained  in process
        waste streams from the various  manufacturing areas
        in  low concentrations

     •  Area 5:  Spill pond
        The emergency  spill pond  covers  about  1  acre (.4
        ha) and is available for  spill  containment
300.68(e)(2)
(i)(B) amount
and form of
substances
present
                                     1-10
-------
         Area 6:   Solid wastes
         Approximately 13,000  cubic yards  of solid  waste
         material from  the bottom  of  an old  evaporation
         pond that  no longer  exists  were  disposed  along
         Pond 3E's  southern boundary  and along pond  3A1 s
         eastern  perimeter.
 DESCRIPTION OF CONTAMINATION

      The possibility  of surface and ground water contami-
 nation from the  evaporation pond  system is controlled by
 the following factors:

      •  Thickness and  permeability characteristics  of the
         natural sediments and/or man-made dikes  and liners
         that confine and underlie ponds

      •  Hydraulics of  the pond  system,  i.e., pond levels

      •  Local area  weather  conditions,  i.e., wind  veloc-
         ity* precipitation

      •  Hydraulics of  the near-surface ground  water zone.

 Although the  evaporation  pond  system   at  the  site  had
 performed   relatively  well  over  the  years,   there  were
 incidents which suggested that  leakage and/or seepage  had
 occurred in the past.    There were two  dike areas  in  par-
 ticular  that were cause  for  concern.  One  area was  located
 along the west  dike  of West  Pond and  the  other adjacent to
 the east and west dike of the Fertilization Pond.   In  the
 first  case  wastewater seepage was  pumped  from  the adjacent
 drainage ditch,  collected  and  returned  to  the  pond.    In
 the case of the  Fertilization  Pond, ammonia  contaminated
 wastewater  was  detected  in the  sloughs  that run  along  the
 south  and west  dike boundaries  of the pond  and within  the
 storm  drain that runs  along the  outside  of the  east dike
 of  the  pond  (see Figure  1).    Ammonia  contamination  was
 estimated to be  limited  to the pipe bedding  material along
most  of  the storm drain's length starting from the  south-
 ern headwall, which  is approximately  1,500  feet (457 m).

     The  potential  hazard  of lateral wastewater  seepage
was  not  considered  high  because  the  ground water flow
gradient was  away  from populated areas and  the   low
permeability of  the underlying  Bay  Muds  inhibited waste
migration.   However, it  was  not  until February 1980, that
the overall integrity  of the site became  a critical con-
cern to  the public and  the facility's management.  During
the period  February  20-22,  1980, 3.5 million gallons (1.3
x 10   1) of  ammonia-containing liquid waste was discharged

                                      1-11
300.66(C)(2)
(iii) assess
most of the
contamination
migration
potential
-------
from  the  plant's  fertilizer  waste  evaporation ponds  in
order to prevent  overtopping  of the ponds as  a result  of
an intense rainfall.

     WQCB staff quickly decided  that  the ammonia-contain-
ing  fertilizer water  should  be  discharged  to the  bay
rather  than  releasing  the  pesticide  contaminated  pond
water.   Alternatives were limited.   Either  a controlled
release was maintained or the dikes would have been topped
and  completely breached.    If  the  latter was  allowed  to
occur, the spill could have^been as much as  40 to  50 mil-
lion gallons  (1.5-1.4 x  10  1).   Biological  studies were
conducted to  determine the  effect  of the  spill  on marine
life in the bay by the State Regional Water  Quality Con-
trol Board  and the Department of Fish and Game.  Results
revealed no  evidence of widespread  fish kill  due  to the
release.  Rapid dilution  minimized any  potential  damage.
The WQCB's response to the spill incident was  an enforce-
ment action  ordering that  the waste evaporation ponds be
upgraded to preclude any recurrence of  the discharge.  At
the  time  the  WQCB order was  given,  Anon A  had  already
retained  a  consultant  to  conduct  a  site   study.    The
objectives of  the study were to:

     •  Define  the  ground  water regime  and  water  quality
        across  the  site  and possible presence of  contam-
        ination in subsurface soils

     •  Evaluate  the integrity  (permeability  and  stabil-
        ity) of the perimeter dikes surrounding  the ponds

     •  Evaluate the permeability of the pond bottoms.

The  study was  completed in  October,  1980 and a report was
submitted to WQCB.

Using  the  results  of this study, necessary  actions were
planned for improving the overall integrity of  the evapor-
ation pond  system.   Investigative findings directly relat-
ing  to the re1ease and  seepage and  1eakage probiems are
discussed in  the remainder of this section.

     The  hydrogeologic  study  identified  two  usable  sand-
gravel  aquifers beneath the site area.    These  units were
referred  to as zones 'B1  and  !D'  in  the previous section
on the area's hydrogeology.   The  two  water  bearing  units
are horizontally  continuous  and occur at  approximate
depths  of  130  and 175 feet  (40 and  53 m)  respectively.
Direction  of  flow of these  water bearing  zones  is from
southeast  to  northwest.   The important  feature  concerning
these  two  zones  is  that  they  are  confined  by low
300.68(f)
investigation
300.68(g)
development of
alternatives
300.68(f)
investigation
                                      1-12
-------
 permeability (10   cm/sec)  silty-clay material that  acts
 as  a barrier  inhibiting  downward  migration of  con-
 taminants.

      Contamination is absent within  these  two zones  with
 the  exception  of manganese.   The presence  of manganese
 cannot be explained with existing  information.   The most
 shallow two  water bearing  zones,  zone C  and the ground
 water table zone, zone A, both contain non-potable water.
 The water  is brackish  and  exceeds federal drinking water
 standards for salinity.  The  following constituents were
 detected in high  concentrations  in  these zones:

      •  Total Dissolved  Solids (TDS)
      •  Sulfate

      •  Chloride

      •  Arsenic

      •  Heavy Metals  (Lead,  Cadmium,  and Selenium)

      •  Lindane  (one  occurrence  in  zone A).

 Concentrations  of ammonia,  carbamate fungicide, tetrahy-
 drophthalic acid  (THPA)  and tetrahydrophthalimide (THPl)
 were  also  detected,  although  not  in  quantities  which
 exceed EPA  limits.   The  areal  distribution  of arsenic,
 pesticides,  and ammonia  concentrations in the  ground water
 samples  are shown in Figure 2.  Generally, higher concen-
 trations were found around  the  treatment  and evaporation
 ponds when  compared  to samples  taken east of  Street X,
 particularly  in  the  northwest corner  of  the site.    In
 summary,  the uppermost  two water  bearing  zones  contain
 poor quality water which was initially non-potable due to
 its  high salt content.   The lower  two aquifers have high
 artesian heads indicating that  the silty-clay_  layers
 confining   them  are  relatively   impermeable   (10    -10
 cm/sec),  thus inhibiting vertical leachate movement.

      The hydrogeologic  investigation  indicated  that
 downward movement  of  contaminants would  be greatly
 retarded  by the impermeable muds underlying  the site, as
well  as  the upward  artesian pressure  from  the  deeper
 aquifers, lateral  movement  in the  upper water table  zone
 could  occur towards the bay,  away from populated  areas.
The  area of highest parameter concentrations  appeared to
be in  the near-surface zone at the northwest corner of the
 site,  where  landfilled  materials  influence   soil  perme-
ability.   This  area northwest of  Pond 3A, as previously
 stated, was historically a trash  dump.  Two former  sloughs
had  originally passed beneath  the  dikes in  the  northwest
area  of  the sites.   The permeable  fill  material  in  the


                                     1-13
-------
I
I--
JS
                             C01.1,F:CTF:n

                       HETWfXN 9/11 - 9 '17/81.
SAMPLF.5 C01,l.rCTFD
HF.TWE™ 9,'ii - vn/eo.
              Figure  2.   Groundwater Test  Results  (Source:  Anon A consultant's report)
-------
H\
                                           •oB/ti/6 - H/6 Na:«uaa
                                                        3 sa

                                                        Vd3
                                                                                                                                 to
                                                                                                                                 r-H
                                                                                                                                  I
-------
sloughs could allow rapid movement  of  fluids  through this
corner area.

     Laboratory soil chemical tests were conducted on soil
samples collected at  18  locations  in the site  area.   The
soil samples were composites which  incorporated the  upper
10  feet  (3  m)  of  each boring,  typically  in  two  depth
increments of 0-5 feet (0-1.5 m)  and 5-10 feet (1.5-3 m) .

     Analytical results indicated that only manganese
concentrations exceeded  EPA  EP  toxicity limits  for  solid
waste.   The samples  tested  were  extracted from  a boring
hole located along the eastern boundary of Pond 2.

     Ammonia was  present  in nearly  all samples  tested,
with the higher concentration (115  mg/1) occurring in the
area of a farmer depository for fertilizer materials.  The
areal  distribution of  ammonia concentrations  in  soil
samples collected on site are shown on Figure 3.

     Carbamate fungicide was detected in soils around West
Pond,  Pond  3B,  the  borrow  pond,  and  along  the  northern
boundary of  the  site  as shown in  Figure 3.   The highest
level  found  was  0.135 ppm which  occurred  in the  area of
the borrow  pond.   Small quantities of THPI  were detected
in  most  sample  locations,   along  with  concentrations of
THPA.  The highest THPA  level was 0.123 ppm.

     Arsenic  was  detected  at  most  sampling  locations,
although  no samples  exceeded EP   toxicity  limits.    The
highest concentrations were found in the borrow pond area.

     On the  basis of  the analytical results,  the upper 10
feet  (3 m)  of  soils in  the  evaporation  pond  area contain
some  significant  concentrations  of certain  organic  com-
pounds, ammonia,  and  arsenic.  However,  within the group
of  parameters that have  EP toxicity limits, only the limit
for  manganese  was  exceeded  at one location and,  as was
previously noted, there  is,  to date,  no valid  explanation
for its presence.

     Two of  the  five  most  important factors affecting the
potential  for  contamination in the evaporation pond  area
can  be controlled by  proper design and  system operation
specifications.   These  two  factors are (1) the thickness
and permeability characteristics of the man-made dikes and
liners that confine  and underlie  the ponds  and  (2) the
hydraulics  of the  pond  system.    With well  designed and
constructed  perimeter dikes  and  liners and  well planned
operating  procedures,  the   remaining  three  factors  over
which  there is  minimal  control,   i.e.,  (1)  thickness and
permeability of  natural  sediments, (2) local area weather

                                     1-16
-------
 I
Y—>
--J
            <0.5 , <0.5(
            ••0.5 \\St33.
            GW.-JJflrfi ^-'
                                                                                    SOIL
                                                                  * AI,L VALUF.S 
-------
 I
I—'
00
                                                         i SOL
                                                     EPA LIMIT - 5.0 mq/l
                                          ALL VALllfS <0.02 my/1
                                                Figure  3.   (continued)
-------
 conditions  and  (3)  the  hydraulics  of  the  near-surface
 ground  water  zone; can be  counteracted  and a balance  can
 be  achieved,  so  that  leachate migration  is  minimized.

     There  are  several reasons  for  potential dike  integ-
 rity  problems at  the  site.   Many of  the  perimeter dikes
 bounding  the  ponds  were  originally  built  using  highly
 organic  and peaty materials  from marsh areas  immediately
 adjacent  to  the  dikes.   These  soils  are  typically quite
 permeable  due  to  the  open  framework  produced by   the
 existing  roots  and  decaying  organic  constituents.    In
 addition, compaction  of the dike  material was  probably  the
 result of shrinkage from drying  and  later to traffic using
 the dikes as  roadways.  Sun and  heat  dried the mud, pro-
 ducing  shrinkage  cracks within the dikes  that  could  become
 conduits  for  leakage.   Since original construction  of  the
 evaporation pond system,  perimeter  dikes adjacent  to  the
 drainage  ditch  were blanketed with  a  clay  layer  that  was
 intended  to  improve   stability   and  reduce  leakage into
 surrounding site areas (see  Figure  4).   Clay  blanketing
 could  have  caused  dike failures because  of  the need  to
 trench  down  into the Bay  Muds  to  create  an  acceptable
 seal.    The  resulting instability  would  then  cause   the
 dikes to  fail in the  direction of the trenches.   To avoid
 this  situation,   only  very  short sections   of dikes were
 trenched  and  blanketed at  a time, minimizing  the time  a
 trench  section   remained  open.    This  procedure  helped
 minimize dike failure but  created many more interfaces  in
 the clay  thereby increasing the  potential  of a poor seal
 within the clay  lining.  As a result,  some  sections  of  the
 clay liner have experienced seepage  problems.

     The  next section will discuss  the most  recent   and
 largest  effort  to  improve the  overall  integrity of   the
 pond system and  to prevent  the recurrence of  the  February
 1980 chemical spill.
PLANNING THE SITE RESPONSE

Initiation of Site Response

     Formulation of  the  final  site response program began
on  April  2, 1980  when the WQCB  sent a  letter  to Anon A
directing it to  submit  a  technical report by May 15, 1980
on  upgrading  the  pond   system  to  comply  with  Class  I
hazardous waste  disposal  facility standards.   On May 15,
1980 Anon A  submitted  information  on the scope of a study
being undertaken by  its consultants.   On May 20, 1980 the
WQCB adopted a Cease and  Desist  Order (CDO) that required
Anon  A  to   "achieve  compliance   with  waste  containment
                                     1-19
-------
                                            ENGINEERED CLAY SEEPAGE  BARRIER,
                                            KEYED INTO UNDERLYING CLEAN BAY MUD
                                                                                      MAXIMUM POND LEVEL
I
hJ
O
                                                        BAY MUD
                                                          FIRM SOILS
                   Figure  4.  Schematic  Cross Section Through Dike Showing Seepage Barrier
                                    (Source:   Anon A consultants  report,  1980)
-------
 requirement by  October 1, 1981",  and  study and report on
 the following items:

      •  The  causes  of the  February  1980 discharge  and
         overloading of the ponds

      •  An interim plan of action and commitment to imple-
         ment the  containment  necessary to cover a 25-year
         rainfall during the upcoming winter rain season

      •  The scope  and  schedule  for permanent improvements
         to  the  pond  system,  to  comply  with  Class  I
         standards.

 This CDO provided  the  formal institutional  framework for
 the interim  response  to  prepare  for  the rain  season of
 1980-1981.

      To comply  with  the Class  I facility  requirement of
 containing  a 100-year rainfall,  a WQCB engineer determined
 that  theg  pond  system  would  need  an 87 million gallon
 (3.3 x 10   1)  surge capacity.   The particular methods  and
 materials  for  attaining  this surge  capacity were  worked
 out through discussions between  the  state,  and  Anon A and
 its consultants.  Two  general means  were  used  for this
 interim gite  response.  First,   about  77 million gallons
 (2.9 x 10   1)  of  waste water  were pumped out of the ponds
 anddisposed  of   at an immediate  removal approved facility.
 Contingency   for additional disposal was arranged with the
 facility by  Anon A.   Second,   the  perimeter  dikes  were
 upgraded by   increasing their  height and width,  as well as
 installing  an ASPEMIX  cut-off wall on the outer  sides of
 the West Pond.   The installation of the ASPEMIX  wall using
 the vibrating beam technique during the  summer of  1980
 allowed  the WQCB and Anon A to assess its effectiveness so
 that they  consider its use for  the permanent  improvements
 to  be  implemented  in  the future.

     The  final  site  response,  formalized  in  Waste Dis-
 charge  Requirements  on December 1,  1981,  included   two
 important directives that  further shaped  the  final site
 response.  The  first general directive  was  that the dis-
 posal site should be upgraded to  Class  II-l  standards,  not
 Class  I  standards as  initially  considered.   This  change
was  recommended  by  a WQCB  engineer in  an  internal memo
dated  November  25, 1981  "because the  wastes  pose  a  low
degree of hazard as  concurred with by  the Department of
Health  Services,  Hazardous Materials  Management  Branch
300.65U)
immediate
removal
300.65(b)(6)
immediate
removal

300.68(e)(3)
(iii) adequacy
of barriers
                                     1-21
-------
and since the  site will be controlled regarding input and
output, "i.e., no  wastes  generated  outside the facility
will be accepted and  no discharge from the pond system to
state  waters  will be permitted.  Class  II-l designation
will be  sufficient  for  the  containment  of  the wastes
on-site  in accordance  with  provisions  set forth  in the
California  Administrative Code,  Section  2511  concerning
Class II-l disposal sites."

     Second,  the Order included a specific  acceptance of
the proposed use of the ASPEMIX cut-off wall for providing
lateral  waste  containment.  Permission    for  using  the
ASPEMIX  cut-off wall was  orginally requested  in a March
30, 1981 letter to the WQCB.  But, since tthe WQCB did not
provide  that  acceptance by April 12, 1981 as requested by
Anon A in order  to  construct during  the  dry season, the
construction  was  not carried  out in  1981.  The  CDO was
amended  to  allow  for  a  later   completion  date  for
installation.   Officials of Anon A stated that they used
the  intervening year for testing to optimize the ASPEMIX
material.   The implementation of the  formalized permanent
site upgrading  plan  to  bring the  site  into compliance with
Class  II-l facility standards began in the summer of 1982
and  is expected to be completed  in  the summer of  1983.

Selection  of  Response Technologies

     The WQCB worked with  Anon A and its consultants  to
select   the  necessary   response technologies  that   would
bring  the   site  into   compliance with Class  II-l  facility
 standards.   The   state  waste   discharge  requirements  for
Class  II-l hazardous  waste disposal  facilities  have  two
basic  elements.   First,  the  containment  structures must
have a permeability of less than or equal to  10    cm/sec.
 Second,  no discharge to public  waters is permitted.   These
were general goals used as criteria for selecting response
 technologies.  The following section discusses  the factors
 involved  in  the  overall planning of  the  program  and  the
 selection of specific response  technologies.

      The  initial action  taken  in  response  to  existing
 conditions at  the Anon A site  following heavy  rainfall in
 1980,  wasJthe disposal of approximately 74 million gallons
 (2.8 x  10  1)  of wastewater to  create pond  system capac-
 ity.  The operation was undertaken  prior to the initiation
 of the site response program involving the installation of
 the ASPEMIX  cut-off wall.   Details  of the disposal opera-
 tion are  discussed in  the "Design and Execution" section.

      The  site  response program involving the installation
 of  an ASPEMIX wall was  organized   in  response  to a Cease
 and Desist Order issued  to  the facility  by  the WQCB,  in
300.68(e)(2)
(iii) State
approach to
similar
situation
300.68(j)
selection of
alternative
 300.68(j)
 selection of
 alternative
                                       1-22
-------
 May 1980, following the February 1980 release.  The  Order
 consisted of items with which Anon A had to comply within
 a specified period of  time.   Items that were  included  in
 the Order were  as  follows:

      •  Provide adequate  pond  containment  to  prevent  a
         recurrence of  the  February  1980  discharge.

      •  Permanently repair  the west dike of West Pond

      •  Conduct a technical  study  of  the site, and  based
         on results, design and  implement  an  improvement
         plan for  the entire site, as needed.

      The basic  plan of action proposed by Anon  A regarding
 the four points listed above  entailed the following:

      •  Increase  systemfs  surge  capacity  to handle  a
         25-year rainy  season

         -  widen  certain sections of dikes
         -  increase  pond evaporation rates
         -  transport water  off-site to extent necessary

      •  Contingency  plan  to handle rainfall up to a 1  in
         100 year  rainy season

            take some  pesticide  ponds  out of  service  and
            reserve them for excessive rainfall

         -  transport  water  to offsi'te disposal  sites
            during  winter

      •  West Pond  dike  repair

         -  use  an  asphalt seepage barrier wall

      •  Overall dike area improvements

         •*  would  be based  on consultant  studies  already
           underway.

      The  final  actions taken  to diminish the  possibility
of  another chemical discharge as it occurred  in February
1980,  generally did not involve  the upgrading  of the  dike
areas  and  because  the  remainder  of  this  report  is  focused
upon  the dike upgrading activities,  the means by which the
first  two Order  items were  complied  with,  will  not  be
discussed  in any further detail.

     As previously stated,  the main  area of concern at the
time  the  Cease  and Desist  Order was issued, was the  west

                                     1-23
-------
dike of West Pond.  The decision to use an asphalt seepage
barrier  wall resulted from careful examination of several
alternatives.   Table  1  describes  each alternative con-
sidered, and the  reasons for which it was either rejected
or accepted in the Anon A site case.

     An ASPEMIX wall  was  installed  around  West Pond  to
correct  dike  seepage  problems.    ASPEMIX  was  selected
because  it  appeared  to  be  both  economically  and
technically superior to other alternatives.

     In October,  1980, Anon  A1s  consultants  completed  a
report describing the on-site hydrogeologic investigation.
This report contained  evidence  that there  was  a low-level
ammonia contamination  problem  in the Fertilizer  Pond
slough and  its  tributaries.   The  source  was  identified as
being  the  pipe  bedding material along a 42-inch (107 cm)
storm  sewer drain that  runs  along the  east  side  of the
Fertilizer  Pond.   The  extent of  contamination  was esti-
mated  to  be  along   most  of  the  pipe  bedding  length,
amounting to about 1,500 feet  (457  m)  in total length.  A
dam-type structure was installed at  the  southeast  corner
of  the pond to  isolate the  storm  sewer and  any seepage
from the bedding material  below  it,  from the  main ditch
(see  Figure 5).   Ammonia concentrations  in  the  slough
dropped  significantly  during  the  next  3-month  period,
November 1980  through February  1981.   However,  data
collected over  the period  February  1981  to early May 1981
indicated  that  ammonia  levels  in  the  slough  were again
increasing.  The  rise and  fall of  ammonia concentrations
continued over the course of the following year.  In April
of  1982,  it was  speculated  that  the  most  recent ammonia
contamination in  the  slough was occurring  due to the same
encroachment  problem  that   had existed  along  West Pond,
i.e.,  the pond level was sufficiently high that wastewater
was encroaching  the  protective  clay cap  that overlies the
clay seepage barrier and directly seeping into the slough.
In  May 1982,  action was taken to  prevent  further  direct
seepage  into  the slough from  the  pond.    The  action con-
sisted  of  constructing a 150-foot  (46 m)  ditch along the
west side  of  the Fertilizer Pond.  The  ditch acted as an
interceptor  trench and  the   seepage  fluid  collected was
pumped back into  the  pond.   This  system, however, did not
function properly,  and during  the  summer of  1982,  addi-
tional measures were  taken and  two dams  were built  at the
southwest and northwest  corners of the slough to prohibit
further contaminant movement  through the drainageway.

     The ASPEMIX barrier wall technique was  not  officially
approved  by WQCB for  the  Cease  and  Desist  Order  until
December, 1981.   It was  at   this   point that  the facility
300.68(h)
initial
screening of
alternatives
300.68(c)
State evaluation
of proposal
                                     1-24
-------
           TABLE 1.   ALTERNATIVE  REMEDIAL  TECHNIQUES FOR PERMANENTLY UPGRADING DIKE  AREAS  AT ANON A  FACILITY
            Remedial Alternative
         Technique Description
    Rationale for Rejection/Acceptance
NCP
Reference
          1.  Bay Mud-Clay Dikes
              (Rejected)
Reconstruction  of dike exclu-
sively using Bay Hud
 I
NJ
Ln
                                                                                                         surface water
                                                                                                         controls
•  Past record of clay-soil embank-
   ments on site  not  impressive;
   continual seepage/ leakage prob-
   lems caused by clay  shrinkage and
   cracking, and  interfaces in the
   clay due to construction in short
   sections in order  to minimize dike
   instability

•  Limited Bay Mud on site due to
   past recovery  operations

•  Transport of clay  from distant
   source would create  lapses in
   placement or moisture content and
   could result in flaws in the seal

•  With decreases in  moisture
   content,  clay  shrinks and develops
   cracks; when conditions are dry
   and pond  levels dry, risk is great
   for cracking,  especially along
   higher elevations  of dike

•  Problem of dike stability during
   construction activities; dike
   failures  inevitable

•  Length of time needed to complete
   would have been 2  years
                                                                     Expense high due  to  length of time
                                                                     needed for completion
                                                                                                     (continued)
                                                                                                         300.70(b)U)(ii)
          Source:  JRB Associates
-------
                                          TABLE  1.    (continued)
  Remedial Alternative
         Technique Description
                                                              Rationale for Rejection/Acceptance
                                           NCP
                                           Reference
1.   Bay Hud-Clay Dikea
     (Continued)
                                    Coat for the wall much less than a
                                    technique uaing clay ,

                                    Time required to inatall equal
                                    lengths of an asphenix wall and a
                                    clay based structure differ
                                    greatly; the ASPEMIX wall could be
                                    installed in half the time
2.  Wastewater Disposal
    (Accepted)
    Soil-Bentonite and
    Cement-Bentonite
    Slurry Trench
    Cut-off Walls
    (Rejected)
Diapoaal of 74 million gallons
(2.8 x 108 1) of wastewater at
appropriate facilities
Construction of a seepage cut-
off wall between dike and
drainageway using the slurry
trench technique; entails
excavating a trench, using a
slurry to keep the trench
open and then backfilling with
soil-bentonite or using  the
slurry, in the case of a
cement-bentonite wall
   Most economically and technically
   feasible  means  of bringing pond
   system back into positive water
   balance and provide needed surge
   capacity
•  Bentonlte mixtures Incompatible
   with fluids in ponds

•  Possible site access problems,
   high water table and saturated
   ground conditions

•  Past experience manifested very
   little confidence in clay barriers
   of any type

•  High risk of dike collapse during
   trenching activities
300.70(b)(l)(iii)
(A)(l)
slurry walla
                                                                                                         (continued)
-------
                                                    TABLE  1.    (continued)
         Remedial Alternative
         Technique Description
 Rationale for Rejection/Acceptance
                                                                                                      NCP
                                                                                                      Reference
t—j
 I
       4.
           Interceptor
           Trenches
           (Rejected)
Construction of trenches
between dike and drainagevay
in which any seepage would
be collected and pumped back
into pond system
High water table produces poten-
tial dike stability problems

Site access problems due to
saturated ground conditions

Higher potential for surface water
contamination due to increase in
volume of water surrounding ponds

Requires continuous maintenance
                                                                                                  300.70
-------
                                         TABLE  1.   (continued)
Remedial Alternative
6. ASPEMIX Wall
(Accepted)
Technique Description
Installation of an ASPEMIX
cut-off wall between dike and
drainageway; the ASPEMIX ia
injected into the ground using
the vibrated beam method; and
consists of asphalt emulsion,
sand, cement, and water.
Rationale for Rejection/Acceptance
• ASPEMIX is compatible with all
pond fluids
• Laboratory testing revealed
permeabilities ranging between
10 cm/sec to 10 cm/sec.
• The ASPEMIX wall is relatively
plastic so as to resist cracking
• Minimal maintenance required
NCP
Reference
300.70(b)Cl)(iii)
(A)U)
slurry walla
I
K>
00
-------
Figure 5.  Sequence of Response Activities at Anon A Site
                            1-29
-------
management finalized  its  plans  to  install an ASPEMIX wall
around the remainder  of the pond site with  the exception
of  two  relatively  small  areas.   During  the months  of
August and September, 1982, a wall was installed along the
west and east sides of the Fertilizer Pond (see Figure 5).
It was then  projected  that  the  remainder  of  the pond area
would  be secured  with  an ASPHEMX  wall  during  the  dry
season of 1983.

Extent of Site Response

     Although the site  response program has  not  yet been
completed  as  of  January  1983,  the  extent of the site
response was  determined to  constitute the work necessary
to bring the site into compliance with the Waste Discharge
Requirements  for  Class  II--1  hazardous  waste  disposal
facilities under the California Administrative Code, which
were adopted for the site in December 1981.  The two basic
requirements for Class II-l disposal  facilities  are that
they allow no waste discharge to surface  drainage courses
or to  usable ground water, and  that  they provide protec-
tion from discharge during a 100-year rainfall.

     The  waste  discharge requirements  for  this  site
specifically stipulate  that  a  containment structure must
have a permeability of less than or equal to 10   cm/sec
and the underlying Bay Mud  into which  the barrier wall is
being keyed must have  a permeability  of  10   cm/sec.  The
California Class  II-l requirement to  contain  a  100-year
rainfall, is  based  on  the  dike height and  stability and
the wastewater surge capacity with contingency plans for
additional off-site disposal if necessary.
300.68(j)
extent of remedy

300.68(c)
admin i st rat ive
process
DESIGN AND EXECUTION OF SITE RESPONSE

     The  first  response action  undertaken at  the  Anon A
site was  the  removal and  disposal  of 74  million gallons
(2.8 x  10  1)  °f wastewater  from  the surface impoundment
system.   Because of the heavy  rainstorms during  1981, a
wastewater disposal  operation was  undertaken  by Anon A to
provide the needed  surge  capacity, and to bring  the pond
system back into a positive water balance.  Wastewater was
pumped  into  5 ,400-gallon (20,439  1)  tank  trucks  and
shipped  to approved disposal  facilites.   The  disposal
operation occured during the  summer  and  fall  of 1980 at a
rate of over 100 truck loads per day, and was completed on
October 16, 1980.   The different wastewater  types (e.g. ,
fertilizer and  pesticide  wastewater) were disposed  of at
different  facilities based on  their hazard  category  and
related statutory disposal  category  (see  Table 2).  Since
the  disposal  operation  was  largely  a   straight  forward
                                     1-30
-------
                 TABLE 2.   WASTEWATER DISPOSAL OPERATION  SUMMARY
Waste Type
Carbamate fungicide
wastewater
Pesticide wastewater
Fertilizer wastewater
Amount
44.6 million gallons
(1.7 x 108 1)
9.3 million gallons
(3.5 x 107 1)
20.5 million gallons
(7.7 x 107 1)
Disposal Location
Collinsville, CA
Class II-l
Martinez, CA
Class I
Unknown
soil reclamation
 pumping,  hauling  and  disposal  operation,  the  primary  focus
 of this  section is  on the  ASPEMIX cut-off wall.

      The  final  compositional design  of  the ASPEMIX wall  at
 the Anon A  site  resulted  from the  interplay  of several
 factors.   However,  past experience  with embankments
 consisting  of clay materials  had a major influence on the
 selection of  a wall  composed  of  a material  other than
 clay.   In the  case of the Anon A  pond  system,  the wall
 material  selected is  an  asphalt mixture.  The "ASPEMIX",
 as it is  termed,  is  a  combination  of asphalt  emulsion,
 sand,  cement,  and  water.   The exact  proportion of each
 constituent that was  used  in the mixture(s) was determined
 through  laboratory  compatibility  testing of various
 asphalt  mixtures  and  existing  pond   fluids.   Testing was
 performed  over a  period  of 2  to 3  months.   The asphalt
 mixture used  around the different ponds  is essentially the
 same,  with  slight variations   depending  upon the   fluid
 contained within the  pond.

     The  parameters  involved  in  the  structural  design  of
 the ASPEMIX barrier wall  are:   wall width, depth, length,
 and  1inear  configuration.  The depth  to which  the  wal1
 extends  below  the  surface,   the  length  and  its  linear
 configuration in the  case  of  the Anon A facility were all
 dependent upon  the pre-existing dikes, the geologic condi-
 tions, man-made structures  (both  surficial  and  subsur-
 ficial e.g.,  power  lines,  pipe systems) and the locations
 of the areas  in need of repair.  The width or thickness of
 the ASPEMIX  wall  was  not  dependent  upon site  conditions
but rather  was pre-determined  by the  width  of  the  beam
 used for wall installation.

     Construction of an ASPEMIX  barrier  wall  requires the
use of one crane suspended  I-beam which is  connected  to  a
vibrator.  The  beam is  locked  in a  guide  frame  for  posi-
tioning purposes and  stabilized by  a hydraulic  foot  that
                                     1-31
-------
provides guidance  and aids  in  keeping the  inserted  beam
vertical.   The ASPEMIX  material  is  mixed  and  contained
within a  small  mixing plant  at  the rear of  the  beam rig
and  is  injected through a  set  of nozzles located  at the
base of the vibrated beam  (see  Figure  6).   At the comple-
tion of each  panel,  the  rig  is moved  along  the  direction
of  the  wall.   Every  injected panel is overlapped  by the
following  insertion  in order to ensure continuity  of the
completed  wall.   This process  is  repeated until  the  wall
is  complete.   All  wall  installations required the  use of
one beam rig.

     The  first  ASPEMIX  wall  at the Anon  A  facility was
installed  during   the  summer  of  1980,  along the  north,
west, and  south boundaries of West Pond.  The  total  time
taken for  installation  was 6 weeks.   Operations  began in
the  northeast corner  of the  pond  and  progressed  southward
and  around to the southeast  corner where  the wall  termi-
nates.   The wall  is  approximately 2,000 feet (510 m) in
length,  10 inches  (25  cm)   in  width  and  extends  to an
average depth of 17 feet (5 m), passing vertically  through
the  center of  the  dike  along  the outside  of   the  clay
seepage barrier (see Figure 7).

     Pre-construction  site   preparation  activities  were
often   necessary.    These  activities  most frequently
involved  widening  the  dike structures to enable the
ASPEMIX  rig  to  move along   the  top  of  the dike.   Dike
reinforcement  involved   extending  the  dike width  to  a
minimum of 25 feet (8 m).  This widening process was  often
selective  due to the  fact  that  some dike areas already had
a minimum  width of 25 feet  (8  m).  When the installation
process  was  complete and  the rig  equipment  removed, the
dikes were then built-up to meet dike height  requirements.
Consolidation of the earthen  material due to  the weight of
the  equipment  caused  the  lowering of the top elevation of
the  dike.

     The actual wall  installation  process involved  a  great
deal of  testing  and  visual  monitoring  to  ensure an
effective  barrier.    The  two most  important and critical
features   of  the  completed  ASPEMIX  wall  are;  (1) the
verticality and alignment  of the beam-injected panels and
(2)  the  uniform  composition of  the  ASPEMIX across the
wall.   Verticality  and  precise alignment of the  ASPEMIX
panels  is  of great concern during  and after  installation,
because without precise alignment  the chances that  gaps or
windows  remain  within   the   wall  are  greatly  increased.
During  installation  along West  Pond a  general  type of
level  device used to measure the angular displacement of
the beam  as  it  was driven  into  the ground.
                                      1-32
-------
Figure 6.  Schematic Diagram of the Asphemix Injection Beam
      (Source:  Asphemix wall contractor product literature)
                              1-33
-------

                                                                                 ,—
                                                                                ,r   UCVEL
I
w
                    Figure  7.   Schematic  Cross  Section  Through  Dike  Showing

                                     Asphemix Wall  and Seepage Barrier
-------
      In addition  to beam verticality,  there  were several
 other parameters relating to  the  character  of the ASPEMIX
 that required close monitoring during installation.  There
 were five tests performed on the asphalt mixture to ensure
 that  its  consistency  did   not   vary   and  they  were  as
 follows:

      •  Mix consistency

      •  Fluid content (asphalt and total moisture)
      •  Asphalt content

      •  Aggregate particle size

      •  Stockpile moisture content.
 The  first  two  tests  (mix  consistency  and  stockpile
 moisture  content)  were  conducted  as  required; at  times
 when,  for  example, material  was brought  in  from a  new
 source or the appearance of the mix  was slightly different
 than^what it should have been.   The  remaining three tests
 (fluid  content,  asphalt  content and  aggregate  particle
 size) were each  conducted  twice daily.  At  the outset  of
 installation activities, it was necessary to  monitor these
 ASPEMIX characteristics as  often as twice daily,  however
 it  was the overall  belief that, with time,  the variability
 initially observed in  the  ASPEMIX,  over  the course of  a
 day,  would  lessen, and  such   stringent  testing would  be
 deemed unnecessary.  This  predicted  decrease  in variabili-
 ty,  however, did not  occur and  consequently  the  original
 testing schedules were  maintained.

      As  previously stated,   the  barrier  wall  installed
 around the exterior  portions  of West  Pond  terminates  at
 the  pond's southeast corner.   The  wall does  not continue
 along the  southern sides  of  Pond  1W  and  the  spill pond
 (see  Figure 5).   These dike areas contain clay  liners and
 there  has been no  evidence of  seepage  problems in these
 areas ^ and  therefore  they  were  viewed as  not  requiring
 additional  improvements.

     The  construction  season or dry  season of 1981  passed
without  any additional  work being  performed  at the pond
 site.   Prior  to any further  installation, it  was necessary
 that  the ASPEMIX wall technique  be  approved  by the WQCB.
The  time lapse between  wall  installations was primarily
due to  the fact that WQCB didn't  receive the  site response
plans  from  Anon  A  for review  until  March 30,  1981.   The
WQCB  wasn't  able  to complete  its review by  April  12,  as
requested by  Anon A in  order  to  meet the  1981 dry season
schedule.   The technique  was  approved  in  December 1981.
                                     1-35
-------
At this point, final plans were made  to  continue the wall
along the east side of the Fertilizer Pond (see Figure 5).

     Installation of the  ASPEMIX wall along the east side
of  the  Fertilizer  Pond  began on  July  15,  1982  and  was
completed on September 25, 1982.   The total time taken for
completion was approximately 6 weeks,  the same time taken
for West  Pond.   Although the same  amount of the time was
necessary  for  the  two  installations, there  were  differ-
ences between the two installation operations, and differ-
ences between the walls themselves.  The  Fertilizer Pond's
east side wall is  2929  feet  (893  m) in length, 17 feet (5
m)  in depth,  and about 10 inches  (25 cm)  in  width.   The
wall extends  from  the southeast corner  of the Fertilizer
Pond,  along  the  railroad track  for  approximately 2,200
feet  (670 m), and  then  shifts west  toward the southeast
corner  of the Borrow  Pond where  it  ends.   The approach
taken  during  the  design stages of the  second  wall were
slightly  different  than  those taken  during  the design of
the West  Pond wall.  In  the  second case  the  facility man-
agement took command of the structural design  and played  a
major role in the design of its composition.   The  facility
management  in agreement  with their  contractor, arranged
for  additional   compatibility  testing on various  asphalt
mixtures.   During  the design  of  the  West  Pond wall, the
ASPEMIX  testing  was performed exclusively by  the contrac-
tor.   This degree  of  involvement  on  the part of  facility
management  did   not result from any  particular problems.
They  believed that  the  additional testing  would  enhance
the quality of the  final  product and  its  effectiveness.

     Operations  along  the  east side of the  Fertilizer  Pond
were  somewhat more complicated  than  those for the  first
installation  due  to  the presence  of powerlines,  storage
facilities, pipeways,  and railways.   Detailed wall  design
and construction planning prior to  the actual installation
were  both critical  in  anticipating and  avoiding  problems
and  delays that could have been  caused by  these  struc-
tures.   Several  facilities were relocated  and underground
pipeways  and  railways were moved.   In addition, twice  the
entire  fertilizer  plant's power was shut  off so that power
lines  could be  relocated.  Despite the  extra construction
activities necessary  during  the  second installation  and
the additional 1,000 linear  feet  (305 m)  of area to cover,
the second installation  was  completed in  the same amount
of time as the  first.   The  difference  in  completion  time
between the two operations  was  primarily due  to  the  fact
that  during  the  Fertilizer Pond   installation,  both
contractor and  facility  management were working  with the
experience gained from the West Pond  operation and overall
 organization  was greatly improved.
                                      1-36
-------
      During the second operation  two  angular displacement
 measurement devices  were  initially  used  simultaneously.
 One  device was  a  digital  "tiltmeter"  and  the  second
 instrument  consisted  of  a laser  guidance device.   At  a
 certain point  during  operations  the  use  of the  digital
 tiltmeter was  discontinued due  to the  time-consuming proc-
 ess of using  it  which required  that  the beam be  stopped
 for each reading.   The improved laser  device permitted  the
 continuous  operation of the vibrated beam,  resulting  in a
 faster rate  of wall  installation.    The ASPEMIX  testing
 procedures  for both operations, were  the same.

      It was 6 days after  the completion  of  the  Fertilizer
 Pond's east side that installation activities began along
 the pond's  west side.   Installation  on the west  side began
 on September  1,  1982 and  was  completed on  September  16,
 1982.  The  west side wall  is  1,173 feet  (358 m)  in length,
 17 feet (5  m)  in  depth and approximately 10  inches (25  cm)
 in width.    It extends  from  the  northwest  corner  of  the
 spill pond  to  the  southwest corner of  the Fertilizer Pond.
 An ASPEMIX  wall was not installed along  the  south side of
 the Fertilizer Pond due to the  fact that seepage problems
 were  never  observed along the  south dike and  that  studies
 showed the  clay liner  to be intact.

      All testing  and monitoring procedures were  similar to
 those undertaken during installation along  the  east side.
 There was   one  considerable difference  between   these  two
 operations.   During the  west  side installation, approxi-
 mately two-thirds of  the  distance down  to the  southwest
 corner of  the Fertilizer  Pond  where  the wall was  to  end,
 the vibrated  beam rig was relocated at the  southwest  cor-
 ner and proceeded along the dike in a  northerly  direction.
 This  change in direction  was instituted  due to  the  pres-
 ence  of an  aerial powerline that ran perpendicular  to  the
 line  of installation.   Subsequent to the change  in  direc-
 tion  to avoid  the powerline,  the rig then moved  northward
 to  meet and connect  with the  earlier installed  segment.
 Other than  the  s ingle power 1 ine,  there  were no  further
 complications.  The  completion  of the east wall  ended  the
 construction activities undertaken in  1982.

      The remaining exterior dikes  through which  an  ASPEMIX
 wall  will be installed, include all the areas  not yet dis-
 cussed.  The  final wall to be  installed will extend from
 the  southeast  corner  of  the  Borrow Pond and will  follow
 the dike areas north and then east to the northwest  corner
 of  West Pond.   Construction activities  for  this wall's
 installation are  presently scheduled to  commence on July
 1,  1983.  The  wall  will be approximately 4,000 feet (1219
m)  long, 17 feet  (5m)  deep  and  10  inches  (25  cm) wide.
The entire process is estimated  to take about 6 weeks.

                                     1-37
-------
     Initially the  remaining  unfinished areas were  to be
completed  in  1982 following  the  wall  installation  along
the east side of the Fertilizer Pond.   There were problems
with this  proposal,  however,  due  to high pond  levels  and
saturated  ground  conditions  along these dike areas.   The
greatest area of  concern  was  the  north side  of  the  site.
Directly north of this boundary lies a residential area.

     There was concern that heavy  equipment  positioned on
the saturated earthen embankments  would cause a dike  fail-
ure and  possible  pond release.   The  facility  management
felt  that  the  risk  of   dike  failure  and   its  potential
hazards from a dike  failure was much  too  great  to proceed
as originally planned.   For this  reason  the decision  was
made to complete  the installation along the  east  side of
the site and continue the remaining areas  in 1983.
COST AND FUNDING

Source of Fuodinjg

     The  company  paid  for  all  projects  costs  which
amounted to a total of $10,314,276.

Selection of Contractors

     The  environmental/engineering  consulting  firm  was
chosen  for  overall   design  and  constructing  management
because of their previous  12 years  of  work related to the
site.  The general construction  contractor was chosen for
the cut-off wall  installation  because  they were  the only
company  with  demonstrable  experience  with  this  type  of
cut-off  wall.   They  also  provided  specialized  equipment
and expertise.   A local construction  company  was subcon-
tracted  to perform the installation based on  their capa-
bility and competitive price.

Project Costs

     Cost information  on  the installation of  the ASPEMIX
cut-off  wall  during  1981   and 1982  and transportation and
disposal of the wastewater during the 1980 is given below.
The  cost  information was  obtained  verbally from the
company  and its contractors, no invoices were available.

ASPEMIX Wall
                                                        2
     The total cost for the 103,734 square feet (9,637 nT)
of  ASPEMIX wall and related construction during 1980  and
1982  was  approximately   $1.8  million.   About $1.2 mil-
lion, or 68%  of  this total  was   for  the  cut-off  wall

                                     1-38
300.70(b)
(iii)(A) imper-
meable ground
water barrier
-------
 itself.   The  grading  of   a  25  foot (8 m) staging  path on
 top of the dikes to facilitate the ASPEMIX wall construc-
 tion,  cost about $350,000.  Utility alterations, including
 sewer  and water  line  reconstruction, cost about $200,000.

     The  unit construction  cost of the 17 foot (5 m) deep
 cut-off   wall,  excluding  site  preparation  and  material
 testing  varied from  about  $7/square  foot ($75/m ) during
 the 1980  installation of about 2,000  linear  feet  (610 m)
 or  34,0,00  feet   (3,159 nT),  to  about $14/square  foot
 ($150/m  ) during  the 1982 installation  of   about  4,100
 linear feet  (1,250 m)  or  69,700  feet  (6,457 mZ).   For
 most flat, unobstructed  sites, costs  for  an  ASPEMIX wall
 estimated  by the  contractor at  about  $5/square  foot
 ($54/m ).  Two  factors  that  resulted  in  increased  costs
 for the Anon  A site were:

     • Labor costs  in the  area are relatively high.  For
        example,  according  to  the  contractor,   a  crane
        operator  on this job  earned  $38.28/hour compared
        to $10/hour  in   the   Houston,  Texas  area.    The
        average  hourly labor cost was $28.50/hour compared
        to $5/hour  in Houston.

     • Equipment  operation  on  top  of the  dikes  was
        problematic  and   time  consuming.   Descending  and
        remounting  the  dike   was  necessary   for  several
        utility  obstructions.    This  cost  would  be
        insignificant with  a flat staging area.

     The  low  cost of  $7/square foot  ($75/m2)  for the 1980
 installation  was maintained at some loss to the contractor
 in  order  "to  get  a  foothold in the area" market, and also
 because the 1980  section  was  relatively easier to install
 than  the  1982  section.     The  unit  cost for the  final
 section in  1983  is  expected to be about  $8-9/square foot
 ($86-97/m2),  because  of  fewer  obstructions   and  greater
 experience with  installations through  dikes.   This  unit
 cost will, however,  depend on  material costs  at the time.

     The  component cost.s  of the ASPEMIX wall  installation
were  about equally  divided  between three  categories:
 labor, equipment and materials.  The daily equipment  costs
were  about  $2,000   (other  component  costs  were  incon-
sistently available or were claimed to be properietary).
The major  equipment  costs were:   80-ton  (73  Mt)  crane -
$600/day, vibratory pile  drive  assembly  -  $600/day,
ASPEMIX mixing equipment  -  $500/day,  and miscellaneous
support equipment -  $300/day.   Mobilization cost  was  about
$40,000.
                                     1-39
-------
     The direct  equipment  costs  for measuring  the  verti-
cality  and  alignment  of  the  beam  during  installation
proved  to  be  less  important  than  the  indirect  cost
resulting  from  their use.   The  laser  unit cost more  to
rent  than  the   Digitilt   Tiltmeter,  but  was  less  time
consuming to use.  The laser  alignment  system rental  cost
was about $1,500-2,200/month.  The  monthly rental cost for
the complete  Digitilt  Tiltmeter  system,  including  a  bore
hole sensor  and  readout display  with connecting cable and
pulley  assembly,  was about  $480-655/month.   Despite  its
lower  cost,  the  Digitilt  Tiltmeter  was   discontinued    300.68(i)
because  it was more time consuming to use than the  laser    alternatives
system.                                                       analysis cost

     The  quality  control  operation  costs  were  greatly
streamlined as Anon A gained confidence in the contractor.
During the initiation of the construction, there were more
inspectors on-site than  laborers,  but  later the number of
inspectors  was reduced   significantly  as  QC became  a
routine part  of  crew work.   The  QC testing for the compo-
sition  of  the ASPEMIX  material was performed once  a week
by a local engineering firm for a total of about $20,000.

     Future  costs  of the  ASPEMIX wall  at  the Anon  A site
include  construction  of   the  final 4,000  feet  (1219  m)
around  the northeast corner  of  the ponds  (see  Figure 2)
and  future  monitoring.    The monitoring  system and  its
costs  have not yet  been  established as  of  January 1983,
but  will be  part of  compliance with   the  site's waste
discharge  requirements  as  a Class  II-l  disposal site.
Assuming  a  unit  cost of about  $8-9/square  foot ($86-
97/nT), the  17  foot  (5 m)  deep x 4,000 foot 11219 m) long
cut-off  wall or 68,000 square feet  (6,317 m ), will cost
between $544,000  and $612,000.  This would bring  the total
project construction cost  to  about $2.3-2.4 million.

Wastewater Disposal
     The  total  cost  for  disposing of about  74  million
gallons  (2.8  x  108 D  of  various  types  of wastewater
during  1980  to  provide extra  surge capacity,  was  about
$8.5  million.   The  wastewater  disposal  contingency plan
for  controlling  surges during heavy rains  was also  used  to
a  lesser extent  during  1981  and  1982.   But,  since this
subsequent  wastewater disposal  could  not  be  quantified,
the  partial  list of  project costs  was not  summed in Table
3  to avoid the  impression  of a total project  costs.

     Because of  its differing  chemical   characteristics,
and  correspondingly  different disposal costs,  the waste-
water  was separated into  the following  three  categories:
carbamate  fungicide  waste, pesticide waste and  fertilizer
                                      1-40
-------
 waste.   Disposal of this waste was on  a  per-gallon  basis,
 which included  both  transportation and  disposal.    Costs
 are detailed in Table 3.  The costs for  pumping  equipment
 and labor, and support logistics are not  included because
 these activities were in-house costs for Anon A  and could
 not quantified.

      Pesticide waste  was considered a  State of California
 Class I  hazardous waste and was disposed of at a properly
 licensed facility in  Martinez, CA, about 15 miles (24  km)
 from the site.  The total cost for disposal and  transpor-
 tation  of 9.3 million gallons  (3.5  x  10  1) of  pesticide
 wastewater was  about $1.4  million.   The  unit  cost  for
 pesticide waste  transportation  and  disposal  was   about
 $0.15/gallon ($0.04/1)  or  $0.01/gallon/mile  ($.0024/1/km).
 The  trucks  held  5,400  gallons  (20,439  1),  hence  the
 transportation and  disposal  cost was about $810/truckload.

      Carbamate fungicide wastewater was considered a Class
 II-l waste,  and was disposed of at a licensed facility  in
 Collinsville,  CA, about 50  miles  (80  km)  from   the  site.
 The total gost  for the disposal  of  44.6 million gallons
 (1.7 x  10   1)  of carbamate  wastewater  was  about $5.2
 million.   The  unit cost  for  carbamate wastewater  trans-
 portation and disposal was about  $0.12/gallon ($.03/1)  or
 $.0024/galion/mile  ($.0004/1/km).   The  disposal and
 transportation for each  of the  5,400 gallon  (20,439   1)
 trucks was about  $648,000.

      Removal  of  the excess fertilizer wastewater involved
 only transportation costs, because  the water  was trucked
 to  a U.S.  EPA subsidized land  reclamation project at  Veale
 Tract Farms  in the  Sacramento River delta area.   At  a unit
 cost  of  SO.02-0.03/gaUon ($0.005/1),  the  transportation
 of  20.5 million gallons (7.7 x 10  1) of fertilizer waste-
 water cost about  $408,000-612,000.

     The  future  costs  for  wastewater disposal  include the
 removal costs  for future surge capacity,  as  needed.   This
 removal  is  part  of   the  contingency  plan  for  handling
 future rain  storms beyond the  pond system  capacity, and
 was  already used  in 1981 and 1982 during heavy rainstorms.
PERFORMANCE EVALUATION

     The  effectiveness  of  the  ASPEMIX  walls  currently
installed  at  the  Anon  A  pond  site,  to  date, has  been
assessed only by means  of  visual  inspection.   No monitor-
ing^ well  data  are  currently  available  because  the
monitoring well system  has recently been  installed.   The
exterior portions of  the dikes bounding  the  West Pond and

                                     1-41
-------
          TABLE 3.  SUMMARY OF  COST INFORMATION-ANONYMOUS  SITE"A"," NORTHERN SAN FRANCISCO BAY AREA, CA.
Task
A. Total Waste
Water (W.W.)
Transportation
and Disposal
1. Pesticide
W.W.
2. Carbamate
fungicide W.W
3. Fertilizer
W.W. (b)
. ASPEMIX Wall and
Related Work
1. Dike grading
2. Utility
alterations
3. ASPEMIX Wall
(d) Installation
i) 1980
11) 1982
TOTAL
Quantity
Total:
'4,1 pillion cal Ions
(19.6 million 1)
9.3 million gallons
15 miles (24 Km.)
14.6 million gallons
(168.8 million 1)
50 miles (80 km)
20.5 million gallons
(77.2 million 1)
distance unknown
Total:
LOT. 734 feet2
(9.637 m*l
25 foot (8m) wide
staging area as
intermittently needed
water, sewer and
electrical work
34,000 feet^ (3159m2)
69,734 feet2 (6478m*)

Actual
Expenditure
Total (c)
$8.53 million

($1.395 million)
($5.23 million)
($408,000-612,000)
Subtotal:
$1,784,276
($350,000)
($200, 000 )
( $238,000 )
($976,276 )
$10.3 million
Unit Cost


154/gallon (4*/l)
^/gallon/mile
(0.2^/1/km)
124/gallon (3.2*1)
0.244/gallon/mile
(0.04*/l/km)
2-3*/gallon (0.5^/1)
—
~~
—
$7/foot2 ($75/m2)
$14/foot2 ($150/m2)

Estimated
Future Cost
(a
Unknown

Unknown
Unknown

—
~
—
$544,000-
612,000

Funding
Source
Anon A.

Anon A.
Anon A.
Anon A.
Anon A.
Anon A.
Anon A.
Anon A.
Anon A.

Period of
Performance
July-Oct. 1980

July-Oct. 1980
July-Oct. 1980
July-Oct. 1980
—
Intermittent
1980 - 1982
Intermittent
1980 - 1982
June-Aug. 1980
July-Sept. 1982

I
4>
NJ
                         (a) Future dJitposal is a part of the heavy
                             rainfall contingency plan, and wan used
                             during winer  1981
                          (b) Transportation cost only, disposal was
                             free at  a U.S. EPA subsidized  land
                             reclamation
(c) Excluding in-house pumping and logistical
   cogtu

(d) 17 feet  (5m) deep
-------
 the  Fertilizer Pond are, however,  inspected  regularly for
 any  signs of  seepage.   The results  of these  inspections
 have been positive according to representatives  from  both
 the  facility management and WQCB.   Some of  the  most  con-
 vincing  evidence  that  the wall  is  performing  as it  should,
 is  the absence of  seepage  fluids  along the  boundaries  of
 West Pond,  for it  had  been  along these  boundaries that the
 past seepage problem had been most prominent  and  visible.

      In  addition to the regular   inspections conducted  to
 ensure that there  is  no further  seepage occurring along
 the  drainageway,  there  is  a test section of  the  ASPEMIX
 wall which can be  inspected directly.   The  test  section,
 approximately  30 ft x 30 ft x  6 ft (9  m x 9 m x   2 m)  is
 separate from the seepage barrier and  has been  excavated
 such that a portion of the ASPEMIX wall is visible.   This
 open  section  of  wall  will  be used  in  the  future   for
 purposes of  testing  the ASPEMIX  material  to  detect  any
 degradation  that  might be  occurring.    In  general-,   the
 asphalt-based  mixture  is resistant to most chemicals,  and
 inorganic chemicals in particular  pose no  hazard to  an
 ASPEMIX  wall's integrity and containment capability.   The
 overall  consensus  among those  involved with  the  site's
 upgrading appears  to  be that the  seepage problem has  been
 arrested.    Both  the  state and   the  facility management
 feel,  however, that monitoring well data is necessary  to
 make a complete assessment of  the present conditions.  A
 monitoring  well  system has  recently  been   installed  and
 includes a number  of wells  along the  three existing walls.
 Only when monitoring data  becomes available, will a  com-
 plete  and thorough assessment  of   the wall's  effectiveness
 be possible.

     The remedial  work at  the Anon A  site  is  not   yet
 complete due to the combination of the site's large  size
 and  the   seasonal  weather  conditions in  the  area.    The
 projected completion date for the  remaining wall  installa-
 tion activities  is  estimated to be  mid-August 1983.
 Meeting  this  deadline, however,  will  depend  upon   pond
 levels and  ground  conditions at the  time when activities
 are  to begin in July 1983.

     The  vibrated  beam ASPEMIX method  for constructing a
 barrier  wall  is a  relatively novel technique and  because
 it has not  been extensively utilized for  hazardous waste
management,  there  are  many  questions  relating  to   its
 ultimate effectiveness.  Two of the greatest  concerns with
 ASPEMIX  wall  installations  are:   (1) the vertical align-
ment  of   the   beam-injected  ASPEMIX  panels   and  (2)  the
 ability  to  key the panels  into an impervious layer below
 (unless  the  waste  to  be  contained  is  floating).    As
previously mentioned,  it is extremely important to ensure

                                      1-43
-------
that  the  individual  panels  are  identically aligned  and
overlap one  another.    If,   in   fact,  alignment  is  not
identical  and panels do not overlap, gaps  or windows will
remain within  the wall.   These  windows can then act  as
conduits for seepage.  To minimize  the  potential  for such
openings,  the process of lowering the beam  into  the ground
during  installation  must  be  scrutinously monitored  and
checked.  This  aspect of the  installation process  is  of
utmost  importance  and  must  be  ensured.   To  provide
assurance  against potential  openings   in  the  wall,  the
ASPEMIX walls  at  the Anon  A site  were  installed  under
strict  specifications  and monitoring   requirements.    To
complement  the  contractor's   specifications  and  provide
extra confidence in the final product,  Anon A designed and
implemented  additional process monitoring requirements.

     The second concern involves  the ability to  key or tie
the wall  into  an impervious  layer below.  A barrier wall
that  is not  continuous  with  depth  is  of little use  in a
situation where contaminants  are  able to migrate downward.
The key-in of a wall is not a concern if the waste is less
dense than water and floats  on  the water surface.   This
aspect of a wall installation  , the key-in, in the case of
the Anon A  site, however,  was not  a major concern due to
the presence  and extent of  the  Bay Muds  below  the  site.
The subsurface conditions at  the  Anon A site are,  in fact,
probably the most  desirable  for  an  ASPEMIX wall installa-
tion  because  clays are relatively  impermeable  and easily
penetrated,  allowing  the  undisturbed passage of  the beam
into  the ground  and easy injection of the ASPEMIX.

      There  are  numerous  site  scenarios  in  which  the
ASPEMIX barrier  wall may not  be applicable  and  prior to
any  decision,  a  variety  of  factors  must be considered.
The waste type(s)  to be contained is a major consideration
in  deciding  whether or  not  to  install an  ASPEMIX  wall.
Asphalt  is  resistant  to  most chemicals,  e.g.,  inorganic
chemicals,  dilute  acids,  lower alcohols,  glycols,  and
aldehydes.   However,  it  is  not compatible  with  concen-
trated mineral  acids,  polar,  and non-polar  solvents, and
chlorinated, aliphatic and aromatic hydrocarbons.  Ketones
will  also affect  asphalt,  and  phenols may induce  slow
degradation.   These  are  only general  guidelines  and any
remedial action  selection process  should entail an exten-
sive  compatibility  testing  program  prior to   a  final
decision.

      Another  factor  which   can  ultimately  limit  the
applicability  of an ASPEMIX wall at a  particular site is
the  site's  geologic  environment.    Subsurface  conditions
are critical  for several  reasons.   In  order to lower the
vibrated  beam into  the ground  the subsurface  materials

                                     1-44
-------
must be granular in nature.  It is virtually  impossible to
penetrate  hard  materials with  a  vibrated  beam.   Boulder
sized  rocks  are also  cause  for problems during  installa-
tion.   The  other  point  to be made  concerning geologic
conditions  involves  the issue  of  the  wall  key-in with an
impervious  layer.    The  optimal  conditions   for  this
requirement  are  those found at the  Anon A site  i.e., the
existence  of penetrable and  impermeable clays.   In most
scenarios,   the  wall  must  be keyed   into  a  relatively
impermeable  layer,  however, an impervious layer that is
impenetrable  may produce  problems  in  ensuring  that the
wall  is,   in actuality,  keyed-in.   There  is  no  method
available with which  to monitor whether  or  not .the ASPEMIX
wal 1  forms  a  seal  at depth.   Grout ing  any  open   areas
between the wall bottom and the impervious  layer  is not as
easy a  solution  in  the case of an ASPEMIX  wall  as it is,
for  example,  in  the  case  of  a  bentonite   slurry  wall
because it is not  possible to grout  through  an ASPEMIX
wall.   It  is possible, however, to inject grout  along the
sides of the wall.

     The effectiveness  of  an ASPEMIX wall in  a particular
situation,  as  with  any other  remedial  measure, refleets
the  extent  to  which the  site conditions  and  remedial
options have been investigated  and thoroughness with  which
these are  understood.  Depending   upon  the  site  scenario,
an ASPEMIX wall  can either be  highly  effective  or it can
be entirely wrong approach to the  problem.  In the case of
the Anon A site, to  enclose most  of the pond area with an
ASPEMIX barrier  appears  to  have  been,  from  a   technical
standpoint, the most  appropriate choice, and appears  to be
performing  as  anticipated  with no  reason  to believe it
will perform any differently in the future.
                                     1-45
-------
                                 BIBLIOGRAPHY

Anon A Consultants.  1973.  Reports discussing perimeter dike improvement for
   Anon A facility, California.

Anon A Consultants.  1980.  Report describing the ground water and subsurface
   conditions investigation for the Anon A facility, California.

Bishop, K.C.  1982.  Personal communications.  Anon A Facility, California.

Budgin, R.  1982.  Personal communications.  Slurry Systems, Inc.,  Gary,
   Indiana.

California Regional Water Quality Control Board.  1982.  Review of
   correspondence and file information, e.g., memorandums, letters, orders
   issued etc., California.

Heikkila, S.  1982.  Personal communications.  California Regional Water
   Quality Control Board, California.

Jogis, H.  1982.  Personal communications.  Anon A Facility, California.

Nelson, W.  1982.  Personal communications.  Slurry Systems, Inc., Gary,
   Indiana.

Piersante, M.  1982.  Personal communications.  Anon A Facility, California.

Sioco Corp.  1982.  Personal communications.  Seattle, Washington.

Singer, H.  1982.  Personal communications.  California Regional Water Quality
   Control Board, California.

Stanbolis, J.  1982.  Personal communications.  Anon A Facility, California.

White, C.  1982.  Personal communications  and file  information.  Department of
   Health Services, California.
                                      1-46
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                                ANONYMOUS  SITE B

                               NORTHERN CALIFORNIA


 INTRODUCTION                                                 NCP Reference

      A large chemical  company  operates a  manufacturing and
 packaging  plant in northern California.   In the  fall of
 1979,  Company officials learned of complaints from neigh-
 boring firms  of  bad-tasting  well  water.   Additionally,
 Company officials  noted  an  unexpected  dry-season  water
 discharge  into a  nearby  bay  from a  storm drain  at  the
 plant.   The  discharge was analyzed and  found  to contain
 herbicides.   Subsequently, the  Company  tested  ground and
 well  water  and discovered  that,  while  contamination of
 neighboring  wells was  not detected,  ground water  below
 part  of  the  plant's  wastewater  treatment  system  was
 contaminated with solvents and several   herbicides.   The
 Company reported  the  problem to  the   appropriate  state
 officials.

 Background

     The  Company  has  operated at  the   site  for  over  80
 years,  manufacturing  and  packaging  industrial  chemicals,
 and pesticides.   The  site  is  directly adjacent  to a bay,
 in a  heavily industrial urban  area.   In  1971,  the Company
 constructed  a  system to collect and treat rainfall run-off
 and rinsewater from the plant's chemical handling areas.
 The  system  included   a series  of tanks,  ponds,  carbon
 columns, and a 300-foot-long  (91  m)  underground chemical
 drain connecting a tank to  a pond.   For part of its length
 the chemical  drain  closely paralleled a  storm drain  and a
 sanitary sewer  beneath  Avenue  "X".  (See  Figure  1)  After
 conducting  a  number  of  test  borings  along and  between
 Avenues X  and Z in autumn, 1979 and finding toluene  and
 various herbicides  in shallow ground water,  Company
 geologists  concluded   that  the  sources   of  contamination
 were:    seepage  from the chemical drain;  a buried "skimmer
 tank";  a number of  small chemical  spills; and possibly an
unlined evaporation pond.

     In January 1980,  the Company presented their findings
to the State.  Over the next six months,  Company  and  State
officials  further  investigated the nature  and  extent  of

                                    2-1
-------
contamination  and  reached  an  agreement on  response
measures that the Company was to take.

Synopsis of Site Response

     Between August and November of 1980, the company took
three  measures  to  reduce  contamination  at  the  site ,
including:   installing  a  subsurface  interceptor  drain,
taking  out  of  service  and  decontaminating the  skimmer
tank, and  replacing  the  300-foot  (91.4  m)  chemical drain.
The  interceptor  drain,  or  "French drain",  was  the major
element  of the  response.   The  drain  is  261 feet  (80  m)
long, and  12 to 17  feet (3.6-5.2 m) deep.   It  is filled
with gravel  and  contains a perforated  pipe  at  the bottom
which drains  into  a  sump.   Intercepted contaminated water
is pumped  from the sump  through the chemical drain to the
same  carbon  treatment  columns  that  treat the  plant's
wastewater.   The  Company decommissioned  the skimmer tank
by  remov ing  sludge,   r ins ing  the   tank,  perforat ing it  to
allow ground water to  fill  it,  filling  it with gravel, and
capping  it with soil.
 SITE DESCRIPTION

     Site  B,  located in  northern  California,  is  situated
 along  the  tidal flats  of a bay in  an industrial center.
 It  is   approximately  82  acres  (32.8 ha)  in  size and  is
 within  1500  to 2000  feet  (457-610  m) of  private  resi-
 dences.  Figure 1  shows a schematic diagram  of Site  B.
 Surface  Characteristics

      The  region   in   which  Site  B  is  located  maintains  an
 average  annual  temperature of  59°F  (15°C).   The  frost-free
 season is  260 to  300  days and  the  average   annual  precip-
 itation  is 14 to  22  inches (36-56 cm).

      The site  itself  is  relatively  flat  with elevations  at
 or near  sea  level in  some  places  and  between 10  and  20
 feet  (3.0-6.0 m)  in  most.   The  southern and  eastern  por-
 tions of the  site lie along  marshland, while the southern-
 most  boundary is  adjacent to a mudflat  located in the  bay.

      The soils  at the site  are predominantly classified  as
 Urban Land,  while those  in  the  southeastern  corner  are
 classified as  Reyes  Silty  Clay.   These  are  small areas
 where 20  to 40  inches (51-102 cm)  of  silty  clay  loam  or
 loams have been  deposited.  Generally,  the  entire  site  is
 of the  Clear  Lake-Cropley   Association.   These  soils  are
 nearly  level to  gently sloping, very poorly  drained,  and

                                      2-2
300.68(e)(2)(i)
(E)
climate
-------
ho
I
                 Figure  1.  Anonymous  Site  B  Schematic  Diagram

                 ("Source:  California Regional  Water  Quality Control  Board,  1982.)
-------
moderately well-drained  clays  on valley  fill and  in
coastal valley  basins.   Hence,  permeability is  slow and
available  water capacity  is  0.5  to  3.0  inches  (1.3-7.6
cm).  Runoff is very slow,  therefore there is no hazard of
erosion.   Some  areas are, however,  subject  to  inundation
during  high  tides.   Thus, the  soils  are  moist  and the
water table is high to very high.  Vegetation in this area
includes pickleweed, saltgrass, and some sedges.

Hydrogeology

     A  hydrogeologic  investigation of  the site included
soil auger borings and  installation of ground water moni-
toring wells in the areas  shown in Figures 2 and 3.  These
studies  revealed that  surficial fill materials, as thick
as 2 feet  (0.6 m) in some  instances, overlie a 3 to 4-foot
(0.9-1.2 in) thick plastic  to  very  firm and dark gray clay
layer.  This clay layer eventually grades through a 2-foot
(0.6 m) interval into a light gray silty clay.  This light
gray  silty clay  contains  some  pebbles  and   streaks  of
white,  crumbly  sand.   It  is  underlain by a yellow-brown,
clayey  fine sand  that  is  very clayey  and  firm  at the top
and  gradually  becomes  less  clayey (as  the sand  and/or
pebble  content  increases)  with  depth.   The  upper clayey
interval  is  usually moist  but not  saturated.   The thick-
ness of this  layer  of  clayey  sand  and gravel is variable,
ranging from a  few  feet  to approximately 20 feet (6.0 m) .
The next  layer  which underlies  the clayey sand  and gravel
layer  is  a very firm,  unsaturated  silty  clay  layer.   The
water bearing zone  is therefore, only a few feet thick and
confined  at  both  the  top  and  the bottom  by unsaturated
clayey beds.

     Cross sections of some  hand  auger borings  taken on
Avenue  X  are  shown in Figure 4.   As  these cross sections
show,  the subsurface  materials  are   predominantly   fine-
grained with some coarser  material.   The horizontal
distribution  of the coarser material varies  at the  site.
Very  little  coarse  material  is  found north of  Avenue  Y
(see Figure  2).  A gravel and  coarse  sand  zone however,
does exist in a southeast-northwest trend from  the skimmer
tank area.  This area  is  characterized as  a fine clayey
sand with  gravel lenses separated from other gravel lenses
by the  fine clayey  sand.

     Ground  water  level   elevations  were  determined  for
Site  B  from  October  1979  through December  1980.   The
ground  water  levels for  representative Wells 2  and 10 are
shown  in Table  1.   It is important  to note that the levels
shown  from August  1980  and  beyond represent  the ground
water  levels  that were present once the remedial action of
ground  water  pumping  at  Site B  had begun.    As  Table  1

                                     2-4
300.68(e)(2)(i)
(D)
hydrogeological
factors
-------
ho
I
Ui
                         O 16
                               15
                          31
                          0
                                    21
                                    O
               Lower
                Pond
                                             Skimmer
                                              Tank
                                            30
                                           -o-
                    10
                    o-
                   32
                   O
                     Scale,- feet
                                     29
                                     - O
                                               20
                                               -O
                                                             19
 5
. e-
                                                                                   AVENUE
                                                                              O
                                                           AVENUE  Z
                  50
0
50  100
                                        O Monitor well and no.
                                        0 Suil|P an(l
            Figure 2.   Anonymous Site B  Ground Water Monitoring Well Locations
            (Source:     Anonymous Site B  Company Geology Department,  1980.)
-------
                             .16
t-0
I
                    LOWER
                    POND
                                   *-*-
                                       '17
                                                   SkiramerTank
                                                 ia      I_JL
      >-*	^
                                                                              AVENUE  X
15 4 	
1
A 20
Am
1
0»
V °«
» o»
t
*L» . 	
c£i 	 • — o^ 	 —* *~ '
° Auger Hole and Number
 Scale in feet

M   0  CO  t*»
                           Figure 3.  Anonymous Site B Auger  Boring Locations
                          (Source:    Anonymous Site B Company  Geology Department,  1980,)
-------
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                                                                       TO
                                                                                     Sand/
                                                                                     Silt
                                                                                      firavel
                                                                               *f
   Figure 4. Cross Sections of Selected Hand Auger Borings Along Avenue X
  (Source:   Anonymous Site B Company Geology Department, 1980.)
-------
                 TABLE 1.
WATER LEVEL ELEVATIONS IK WELLS 2 AND 10
AT ANONYMOUS SITE B
                            ELEVATION OF WATER ABOVE  SKA T.mT  (ASL)
                         WELL #2  (FT. ASL)
                                                      WELL #10  (FT. ASL)
  10/5/79
  10/25/79
  11/5/79
  11/20/79
  12/15/79
  12/25/79
      10.0
      10.125
      10.25
      10.50
      10.75
      11.0
  1/5/80
  1/25/80
  2/5/80
  2/25/80
 3/10/80
 3/25/80
 4/5/80
 4/25/80
 5/5/80
 5/25/80
 6/5/80
 6/25/80
 7/5/80
 7/25/80
                      START  OF  TRENCH PUMPAGE
8/5/80
8/25/80
9/5/80
9/25/80
10/5/80
10/9/80
(Source:   Modified from data from Anon B Co. Geology Dept.)
                                    2-8
-------
 shows,  there was  less  than 2 feet  (0.6  m)  of water  rise
 during  the  rainy season and by the  end  of July 1980, the
 water level  in Well 2 was only slightly above  the  level of
 the  previous  October.   This,  along with the fact  that the
 water  levels in Wells  1  through 5  rose  only  from 1.4 to
 2.6  feet  (0.43-0.79  m) during the  rainy season,  indicate
 that this aquifer  system is not very dynamic or responsive
 .to rainfall.   This assumption is probably valid consider-
 ing  the overlying clay-confining bed  and the  amount of
 fine-grained  sediments  that comprise the  aquifer.

     Figure  5 shows  the ground water elevations of Site B
 from  July  1980  well  readings.    The  ground  water  flows
 generally  southward  under  a  slight  artesian  head.   The
 gradient  flattens  out  to  the south of Avenue Y which is
 most  likely  because  of  the  greater  amount of gravel
 present.  This increases the  permeability and  thickness of
 the water bearing  zone.
WASTE DISPOSAL HISTORY

     Site  B  is  both  a  chemical manufacturing  and  a
research  facility that has been  in  operation for over 80
years.  The manufacturing facility formulates  agricultural
chemicals.   The  research program involves the manufactur-
ing and testing of pesticides and herbicides.  A  schematic
diagram of the facility is shown  in Figure 1.

     The only on-site disposal of waste at Site B was  that
of  iron pyrite  residues  which  resulted  from  a  sulfuric
acid manufacturing  process that  was discontinued at  the
site in  1960.   According to a  State  official, iron .oxide
residues were deposited along the Bay well above  sea  level
prior to 1960  and there was  probably no cinder deposition
there prior to 1950.

     The  old  cinder  bed  lies  underneath the  area where
clarification ponds 1 and 2 now lie, and extends  about  100
feet (30 m)  to the north of  these ponds  (see Figure  1).
In  1971,  following  a  State  request,  Company   officials
encapsulated the  cinder bed area.   A 2-foot (0.6 m) layer
of clay  was placed  atop  the cinder  bed  area.   A 1-foot
(0.3 m) layer of topsoil was placed on top of the  clay  cap
and the entire area was seeded with grasses.   State offi-
cials  have  determined  that  the  old cinder bed area is
stabilized  and does not pose a threat to human health  and
the environment.

     As  Figure  1  shows,  a  chemical drain  feeds  into a
carbon treatment and neutralization system  just  above  the
Tidal Dilution Basin.   This  system was constructed in 1971

                                     2-9
300.68(e)(3)
(iii)
extent and
adequacy of cur-
rent containment
barriers
-------
I
1—•
o
                    UPPER

                    POND
                                Note: Feet Below Ground Surface
                    Figure 5. Ground Water Elevations Prior  to Trench Construction,  July 29,  1980

                   (Source:   Anonymous  Site B Company Geology Department, 1980. )
-------
 at the same  time  that the  clay  cap was placed  on  top of
 the iron cinder beds.   The  clarification  ponds  were  dug
 into  the  cinder beds  at  a  depth which varies from 8.5 feet
 to 9.5 feet  (2.6-2.9  m).   This  is  approved by  the  State
 because the ponds are lined  with Hypalon and do not have
 direct contact  with  the  cinder beds.  The activated carbon
 system consists  of   two  carbon  columns, each  containing
 12,000 pounds  (5,400 kg)   of activated  carbon.    Treated
 wastewater  passes from  the  carbon  column  system through
 3-inch (7.6 cm) fiberglass  lines into  the  neutralization
 system.  As  Figure  1  shows,  this  neutralization  system
 serves to treat the  wastewater  from both the pilot  plant
 and the  manufacturing facility.    A  lined  neutralization
 pond  feeds  into the  neutralization  tank  which is equipped
 with  a pH  adjustment system.   Caustic  is  added to neu-
 tralize  the  acid  and  this  then  feeds or  overflows  by
 gravity to  clarification  pond 1  and  then into  clarifica-
 tion  pond 2.   The wastewater  then  flows by gravity into
 the upper evaporation pond and next  into the lower evapor-
 ation  pond.   The  treated  wastewater is released  into  the
 Tidal  Basin  at  discharge  point  001.   Discharge  into  the
 evaporation  ponds  is allowed  year  round.   However  strict
 limitations to  prevent overflow are  applied.

     After  this  carbon column treatment and  neutralization
 system was  installed in  1971,  a  smaller  carbon  column
 treatment system  was  installed  at  the  pilot  plant  area
 (see  Figure  1)  to treat  contaminated storm water  runoff
 and rinse water  from the  equipment cleaning procedures.
 Since  there had been spills  in  this  area  throughout  the
 history of  the  plant  from  both pilot  plant  operations  and
 unloading of  tank  trucks,  the ground surface contains many
 contaminants.   Hence, storm  water  runoff  from   this area
 can^ by  highly  contaminated.    The Company  installed  a
 series  of trenches around  the area which feed contaminated
 storm  water runoff into a  50,000-gallon (189,000  1) under-
 ground  tank.   This  tank  stores  the  stormwater   runoff  as
 well  as  rinse  water which   has  been  contaminated  from
 cleaning  the  pilot plant machinery.   The water   from this
 tank  is  fed  through  a small  carbon  column  bed   and then
 into a  30,000-gallon  (4,000 1) above-ground  steel holding
 tank.   This  water  is then laboratory tested on-site  for
 contaminant concentration.    If it  is  highly contaminated
 it  is  shipped off-site.  If it is fairly clean it is sent
 to  the lower carbon  treatment and  neutralization system
via  the  chemical  drain.   The  only  direct  discharge   of
 untreated  rinse water  or  storm  water  runoff   into  the
chemical  drain  j.s  overflow  from  the  underground  tank
during extremely heavy rains.

     Prior to 1971,  wastewater from the  pilot  plant area
 flowed  through  the chemical drain and was treated through

                                     2-11
-------
a neutralization  system and unlitied  settling  ponds.   Any
acid  drips  from  manufacturing  on  the west  side  of the
plant  were   intercepted  in  the  plant  sewer   system and
carried to a neutralization  system.   The  skimmer tank was
also used as part of this process for treating wastes from
the pilot plant  process area.   The  tank  (shown in Figure
1), which measured  approximately 5  feet  by 56  feet  by 8
feet (1.5 x 16.8  x  2.4 m) and had  a capacity  of approxi-
mately  15,000  gallons  (56,800  1),  had  an inlet  and  an
outlet  pipe  leading  from  the  chemical  drain  which was
located 8  feet  (2.4  m)  away.    Organics present  in the
process wastewater would either float to  the top or settle
to  the  bottom of the  skimmer  tank depending  upon  their
density.  The  skimmed  wastewater would  then  be directed
back  into the  chemical drain for treatment  in the carbon
column  and  neutralization treatment system.   The  skimmer
tank  was  taken out of operation in  October  1980 because
the  Company  found  that chemicals  were  seeping  from it.
The chemical drain  line was disconnected from the  skimmer
tank  and  it  now  only  feeds pre-treated  rinse  water from
equipment  cleaning  processes,   storm  water   runoff,  and
direct  overflow (during heavy rains)  from the underground
storage  tank  in  the  pilot  plant   area, into  the  lower
carbon  column  treatment system.   At  the  present time, no
process rinse  water is  run  directly through the chemical
drain.  Any process wastes are shipped  off-site  to  a  State
approved  land  disposal  site.   The  pilot plant, formula-
tion, and handling  areas are enclosed by berms to  contain
spills.   Any  spills which occur  are  swept  up and  removed
or recovered.
DESCRIPTION OF CONTAMINATION

     Between  April and  September  of  1979,  personnel  at
Site B  noticed a dry weather  discharge  into Bay  Channels
near  the storm  drain outlet  002  (see  Figure  1).    This
seemed  unusual  as there is not  normally a discharge  from
the  storm drain  during  the  dry season.   Additionally,
Company  officials learned of complaints  about  a disagree-
able taste in the water from neighboring  companies'  wells.
This led the Company to drill and sample  from  several  test
wells in the area.

     The  sampling points were chosen based on  assumptions
about where the contamination  might be  originating.   The
most obvious source of contamination appeared  to be  one or
more of  the three drainage lines  which run  parallel  to one
another  along  Avenue X.   As  Figure 1  shows,   these 1 ines
are a chemical drain, a sanitary  drain,  and a  storm  drain.
Therefore,  the Company  analyzed  samples  from the  first
water-bearing  stratum  at  several   points  alongside  the
300.68(e)(l)
(iii)
contaminated
drinking water

300.64
preliminary
assessment
                                      2-12
-------
 sand-bedded  pipeway containing  the  three  parallel  drainage
 lines.   Additional  samples  were taken  and analyzed  from
 wells  used by neighboring companies on Avenue Z about  250
 feet  (76 m)  east  of the  chemical drainage line.

     The   analytical  results   showed  the presence  of  the
 solvent  toluene   and  several herbicides  (referred to here
 as  Herbicides  I,  II,  and  III)  in   concentrations greater
 than   0.01   ppm   (parts  per   million)   along  Avenue   X.
 Herbicide  I  which  had  been test   manufactured at the pilot
 area but is  no  longer  produced  at the  site,  was present in
 the shallow  ground water at  a maximum  concentration  of  7.4
 ppm  near  the skimmer  tank and  at  a concentration  of  1.2
 ppm  north  of  the  upper  evaporation  pond.   Toluene  was
 present at a maximum concentration  of  46  ppm and Herbicide
 II (which  is presently manufactured at the pilot area)  was
 present at  0.87 ppm, both near  the pilot plant.   None  of
 the suspected chemicals  were detected in  the wells  of  the
 neighboring  companies, however  the  use of these wells  for
 drinking water  has  been  discontinued.

     In January of  1980,  having completed  their  analyses
 and determined  that  contamination at the  site was  present,
 Company  officials   notified  State authorities that they
 suspected ground water pollution along the eastern edge of
 their  facility.    A  series  of meetings  were then held
 between  Company officials and  State authorities to  deter-
 mine the proper site response.    This  resulted in  further
 investigations  as  to  the  source and concentration  of  the
 contaminants.

     These investigations  determined  that  herbicide con-
 tamination   was  found   in the   storm  drain.   Additional
 levels of  contaminants  were  detected in  the  pilot plant
 area.  Further  research  revealed that 12  years previously
 there  was a  significant   spill  of  Herbicide I  which  had
 been test manufactured at  the pilot plant.   This spill  was
 be I ieved to  be  routed to  the  upper evaporat ion  pond   for
 containment.  The data from the  hand auger (HA) samples  at
 locations^shown in  Figure  3,  revealed high  concentrations
 of herbicides near  the Herbicide  II manufacturing  facility
 at HA-2, near the skimmer tank  at  HA-8,  and downgradient
 of HA-8 at HA-12.

     A television  monitoring  inspection was conducted
during August and  September of  1980  along the  1800-foot
 (549 m)  length of the  storm  drain  to  determine  if   the
 contamination was  coming  from  one  or more leaks  in   the
 storm drain.  The inspection determined that two joints of
 the storm  drain line showed some leakage, but  not  enough
to indicate  that  the drain was  a significant  pathway   for
contaminant transport.
300.68(e)(3)(ii)
extent of
present or
expected
migration
300.63(a)(3)
notification of
release by
Federal or state
permit holder
300.68(e)(3)
(ii)
extent of
present or
expected
migration
                                     2-13
-------
     Company and State officials discussed  the  results of
the television monitoring inspection in light of the other
sampling  and  site  inspection results.   The Company
geologist  found that  the  path of migration of contaminants
in the  ground  water  was  southeast  from  the  skimmer tank.
This is downgradient or  in the direction of ground water
flow which  correlates  with  the fact  that   the  migration
occurred  through  an  area  of coarser, more  permeable
sediments.   An  example  of  this  southeasterly flow  of
contaminants  in  the  ground  water   is  shown  in Figure  6
which  shows the  concentration of  Herbicide  III   in  the
ground water at Site  B.

     State  and  Company officials  concurred that the con-
tamination was  the combined result of spills in the pilot
plant  area  and  seepage from the  skimmer tank.   Various
spills  had  occurred  at the site, including the spill of
Herbicide I 12 years  previously.  Contaminants  from these
spills  had  slowly moved  downgradient and  into the  area
along Avenue X by surface runoff.   The major cause for the
contamination  however,  appeared to  be  seepage from  the
skimmer tank which  was  part  of  the  process  wastewater
treatment  system described previously.

     During the dry season in 1979, the contaminants found
in the  storm drain along the tidal basin were  the result
of skimmer  tank seepage which  was  manifested in the storm
drain.   The storm drain  apparently had carried  the con-
taminants along Avenue X and eventually  to  the monitoring
well at the NPDES permitted discharge point (storm drain
002 in Figure 1) where they were discovered.
300.64(a)(2)
identification
of the source
and nature of
the release
PLANNING THE SITE RESPONSE

Initiation of Response

     Company and State officials agreed that the contamin-
ation  did  not pose  an immediate threat  to  human health.
The  direction of  ground  waste  flow in  the contaminated
area was southeast, toward the bay and away  from any wells
or buildings.  Soils  in  the  area were predominantly clays
with  relatively   low  permeability.    Finally,  no  contam-
ination was detected  in  neighboring  wells, the closest of
which  were about  250  feet  (76 m) northeast of the contam-
inated  area.  The  Company and  the  State agreed however,
that measures should be taken to prevent  further migration
of contamination  that might  threaten  aquatic life  in the
bay.
300.68(e)(2)(iv)
environmental
effects and
welfare concerns
                                     2-14
-------
LOWER
POND
                                                   Auger Hole and Number
                                                  Scale in Feet
                                                 50   0   so too
  Figure 6.   Concentrations of  Herbicide III  in  Ground Water(mg/l)  May 6, 1980
 (Source:     Anonymous Site B Company Geology Department, 1980.)
-------
Selection of Response Technologies
     Company officials worked closely with State officials
to  determine  an  effective  plan  for   site   response.
Although  State officials aided the Company in determining
what options were available, the final plan for corrective
action was  designed by  the Company  and  approved by  the
State.

     Company  officials  considered  the  following  three
options:

     •  Wellpoints and pumping for ground water removal

     •  Slurry wall containment

     •  Interceptor drain  with carbon  treatment;  discon-
        nect skimmer tank.

     The  Company examined wellpoint pumping as a possible
solution  to  the  contaminated  ground  water  problem at
Site B  because this could act to lower the water table by
creating a cone of depression.   Company  officials deter-
mined that this was cost prohibitive.

     Another  consideration  was that of installing a bar-
rier such as a slurry wall to isolate the area.   This did
not  seem  feasible  because of the original deposition or
iron pyrite cinders at  the site.   There was concern that
during construction these would be  disturbed and possibly
carried into  the  Bay, particularly if  the  tide seeped in
and  removed  any  cinder material.   Company officials
realized  that  this  did  not  meet  with  their  primary
objective which  was  to  not only  contain  the  plume,  but
also to pump  out  the  contaminated water.   A cut-off wall
would neither  remove  contaminated  ground  water,  nor  the
threat that  contaminants might still  leach  into  the Bay.
Further,  a  slurry  wall  was  rejected because  there were
indications that  sand  lenses  were  present  in the aquifer.
A cut-off wall may have erroneously been keyed into sand
lenses  instead  of  impermeable  mud  and  would  not  form a
complete  hydrologic barrier.   Additionally,  during  cons-
truction, a  sand  lense  itself  could  become contaminated,
again posing the risk of release of contamination into the
Bay.

     The  alternative  selected  was  installation  of  an
interceptor drain to collect the contaminated ground water
and  pump  it  into the carbon treatment system already in
operation at the site.   This seemed to be the  most  feasi-
ble alternative because  it would meet the objective of not
300.68(g)
development of
alternatives
300.68(h)
initial screen-
ing of alterna-
tives
300.70(b)(l)
(iiiXO
ground water
pumping


300.70 (b)(l)
impermeable
barriers
300.70(b)(l)
ground water
pumping;  sub-
surface drains
                                     2-16
-------
only containing the plume, but also of removing and treat-
ing the contaminated ground water using a treatment system
that was already in place.  Hence, the cost for dewatering
in this way was much  lower than the cost of  installing a
wellpoint system.  Company officials  also determined that
the best solution to the  seepage problem from the skimmer
tank  would be to  disconnect the  skimmer  tank  from the
chemical  drainage  line,  pump  out  the  materials in  the
tank, rinse the tank, and finally encapsulate it.

     In June of 1980 Company officials  submitted detailed
plans  to the  State  outlining the response  technologies
which they had chosen.
Extent of Response

     The  State  concurred  with  the  Company's choice of
response  measures  because the actions  appeared adequate
to remedy the  spread  of contamination.   The contamination
was  confined  to a relatively small  area  near  the skimmer
tank  and  the  chemical  drain,   and posed  no  immediate
threat.  Decommissioning the tank and replacing the chemi-
cal  drain  provided  reasonable  certainty  that  additional
chemicals would  not  seep into  the soil, and the intercep-
tor  drain  seemed likely  to prevent  further migration of
contaminants.   The State was willing  to  wait  until these
measures were  executed and their  effectiveness evaluated
before deciding whether additional work would be required.
Since completion of the work, the State has concluded that
the  Company's  response actions  were, in fact,  adequate to
control the contamination.
300.70(b)(2)(ii)
neutralization;
carbon
adsorption
300.68(c)
state or federal
evaluation of
clean-up
proposals
300.68(j)
extent of remedy
DESIGN AND EXECUTION OF SITE RESPONSE

     Company  officials  submitted to the State specifica-
tions  for  installing  the interceptor  trench and decom-
missioning the   skimmer tank.   The trench was designed to
intercept  contaminated  ground  water and  direct it to a
sump  with  a submersible pump that would pump it into the
on-site carbon column treatment system.  Once ground water
flowed  into  the trench, the resulting cone of depression
would  induce additional flow of contaminated ground water
into  the trench.  This  in addition  to  closing  out the
skimmer tank, would then confine the migration of the con-
taminated ground water.

     The  most  critical  design consideration  was  the
determination  of where  the  interceptor trench  should be
installed.   Trench  placement  (see Figure 7)  was  based on
the  geologic  investigation  conducted by  the Company
 300.70(b)(l)
 UiiXO;  (D)(l)
 ground water
 pumping; sub-
 surface drains
 300.70(b)(2)(ii)
neutralization;
carbon
adsorption
                                     2-17
-------
                                                                           Surface Drain
ro
I
00
                                                                                        PLANT FACILITIES
                               HUMMOCKY
                               FILL
                                           Line of Proposed Drainage Trench
                                                                      POST TRANSPORTATION

                                                                      TRUCK YARD
                                                                          PLAN
                                                                                                     Skimmer Tank
                                                                          I" = 30'
                      Figure  7.   Line  of Proposed Drainage  Trench

                      (Source:     California Regional  Water  Quality  Control  Board,  1982.)
-------
geologist.   The  auger  samples  as  described  previously
showed  predominantly  fine-grained  with  some  scattered
coarser   sand   and   gravel  deposits.    The  horizontal
distribution of the  coarser  material   is  variable  with
little coarse  material present  north of  Avenue Y.   The
gravel deposits appear  to  follow a  southeast-northwest
trend from the  skimmer tank area.  This  zone contains much
clay and  silt and is  best  described  as  a fine clayey sand
with gravel lenses.   The Company geologist determined that
although  the gravel  lenses are  clayey  and discontinuous,
their relatively higher permeability controls ground water
flow and  contaminant transport.   The greatest  extent  of
migration was  found  towards the  southeast  (see  Figure  6)
which is  roughly perpendicular to the water level contours
(see Figure 5).  Therefore,  by installing  the trench on a
southeast-northwest  trend  from  the  skimmer  tank  towards
Avenue Z, the most permeable zone would  be dewatered along
its  length.   Once trench  placement  had  been determined,
the final design plans were made.

     The  site  response  was designed  to  take  place  in two
phases:    trench  installation  followed  by  skimmer  tank
decommissioning.  The following  discussion  will describe
the  trench design  and  installation first  and  then  the
design and implementation  for  decommissioning the  skimmer
tank.  The  Company had  a full-time  industrial hygienist    300.71
on-site during  the installation of the trench and closing    worker health
of the  skimmer tank  to make sure  that the operation was    and safety
carried   out  safely  and  that personnel were wearing the
proper safety equipment.

     The  lowest end  of the  trench was  the sump end.   It
was  installed  near  the  skimmer tank so  that the  highest
level  of  contamination would  be  intercepted  before  it
would  have  a  chance  to migrate  downgradient.    This
location  would  also  have  the practical  advantage of being
near  the carbon column treatment system,  minimizing the
amount of piping needed.

     A diagram  of the trench design  is  shown in Figure 8.
The  original design  required that the  trench be 500 feet
(150 m) in length.  This determination had been based on a
series of shallow wells which showed the high point of the
water table to be present  at  a depth between 3 and 4 feet
(0.9-1.2  m)  at a distance of  approximately 500  feet (150
m) along  the area where the trench was to be  placed.  How-
ever, Company  geologists  conducted  ground water analyses
at the same time which showed that the contaminants in the
ground  water  decreased  significantly  at  distances  less
than  500  feet  (150   m)  from  the skimmer  tank, hence  a
trench of 500-foot  (150 m) length was  not needed.   Addi-
tionally,  if   the   trench  was  as  long   as originally
                                     2-19
-------
                            Tall**
                            I !• •'

                              I

                                                              . >00*
                                                                                              Hut !• •<:•!«
r
CO
o
       ••rfllll


W-nrfJ^"""
                   ontinto C-ll
                      Fabric Uiur
                   Around Hol«i In 't
            OI*UM* rip*
            ll"fl, Jahni tUn*IIU
            r»for*t*d rip* Und«rdr*ln
            T<*n*lt*
i
                                                                                                                                 ,i
                                                                      10' V«i«lt'l (*••••«•«<
                                   Figure  8.   Design of  Interceptor Trench

                                    (Source:   California  Regional  Water Quality  Control Board,  1982
                                                and Company Engineer, 1982)
-------
 designed,  it  would have been  almost to, or  actually at,
 the lower evaporating pond.  The  natural  clay barriers of
 the pond could  have been damaged, inadvertently promoting
 on-site contamination  from the  release of pond water.  The
 final length of the trench  was  261 feet (79.6 m).  Company
 officials had determined that this would be sufficient for
 the  maximum amount  of  dewatering  as  long  as the  sump
 system was constructed properly.

      The trench was designed as Figure 8 shows, with the
 drainage pipe  sloping  to the  northwest where  it  empties
 into a 4-foot  (1.2 m)  diameter sump  of approximately 350
 gallon (1,330  1)  capacity.   The  sump was designed  to be
 float controlled and automatically pump the  water  up into
 the lined pond which is  normally used to collect and store
 storm  water.    The  nominal  capacity  of  the  pump  was
 designed to equal  the  expected  initial drainage rate of 20
 gallons per minute (76  1pm).  The  pumped water was  to pass
 through  a  totalizing  flow meter   in  the  line.   Company
 engineers calculated  that  the  lined pond  with a  30,000
 gallon (114,000 1) capacity would  initially  fill up in 25
 hours.   Company engineers also  planned  to have laboratory
 personnel  sample   the  collected  water  before  the  pond
 filled  up to ensure that the pond did  not  contain  suffi-
 cient organics  to  deplete the carbon  beds  of the treatment
 system.   If  the level of  organics was substantial,  then
 the management could have opted to have the  pumped water
 hauled  to a  licensed  disposal   site.   After  testing,  the
 pond pump  was  to  be manually started to  transfer  the
 collected water  into  the  chemical  sewer  system  at  200
 gallons  per ^ minute  (760  1pm).   The  lined  pond  level
 instrumentation was designed to be connected  to the  sump
 pump so that  the sump would automatically  stop if the pond
 filled  up before testing  was  completed.  Company engineers
 had designed  the system  so  that as the  ground  water level
 stabilized,  the  sump pumping  rate  could  be decreased to as
 low as  200 gallons per  day  (760  Ipd)  if  desired.    Three
months  after  start-up, the Company was to  connect the  sump
 pump up directly to the  chemical  sewer  system  and  bypass
 the  lined pond.  This would  leave the pond free to  carry
out  its normal  function of storm water collection.

     Construction  of the  trench  commenced   in August  of
1980.   The  original design  had  been for the contractor  to
supply  the  materials, however   the Company  purchased  the
materials itself believing  that  this  was more  economical.
The  contractor  did  provide  the  construction equipment  and
the  steel  sheeting which  was   used   for  shoring  up  the
interceptor trench.

     The  trench was designed  to  cut through the thickness
of  the  water  bearing  zone  which  would  allow for   the
                                     2-21
-------
maximum amount of dewatering.   The  sump  end of the trench
was excavated  to a depth  of  17 feet  (5.2  m).   The  sump
itself, 4  feet  (1.2  m)  in  diameter, was  extended  to  a
depth of 20 feet (6 m)  so  that  the  water collected in the
pipe would flow  along  the  pipe  and  into  the sump as shown
in Figure 9.   The  depth of the  sump was determined based
on  the geologist's  findings  that  contamination  did not
exceed  15  feet (4.6 m) below  the  surface.    This extra 5
feet  (1.5  m)   in depth  would ensure that the contaminated
ground  water  was being intercepted.   The  far  end of the
trench  was excavated  to  a  depth  of  12 feet  (3.7  m)  in
order  to  provide the  necessary slope for  drainage  along
the  trench to the  sump end.   A layer  of  filter fabric,
known  as Bidim,  was laid on the  trench bottom and  a 6-inch
(15 cm) layer  of gravel was placed  on  the fabric.  Next, a
perforated  12-inch (31 cm)  concrete  asbestos  drain pipe
was  installed.  An additional  layer of  Bidim  supported by
screening  was wrapped  around   the  drain pipe to prevent
plugging  of  the perforations   by  fine-grained  sediments.
The  trench was then backfilled  with gravel  to a depth of 4
to  5  feet  (1.2 - 1.5 m) below  the  surface.   The remainder
of  the  trench  was  then  backfilled with  compacted clay
material.

      During   trench  construction normal plant  operations
continued.    However,  it became  necessary  to  make  a
 significant   modification  to   the  trench  itself.   When
excavating for the  installation of  the sump west of  Avenue
X,  a 4-foot  (1.2 m) thick concrete  slab  made it impossible
 to drive  the  needed piling.   The  construction crew
 attempted  to  offset  the  trench around  the slab  but  this
meant improperly placing  the piling which  resulted  in  the
 trench sides  caving  in.    This produced an  ever-widening
 trench which  extended  almost to the edge of  Avenue  X (see
 Figure 1).   This  resulted in  the  damage of approximately
 30 feet (9.1 m)  of  the chemical drain.    At that time the
 Company  decided  to repair the 30  feet (9.1 m) of damaged
 pipe.   However,  upon closer  examination,  they determined
 that perhaps  it  would be advisable to  replace  the remain-
 ing 300  feet (91  m)  of the chemical drain.   Hence,  the
 chemical  drain was repaired from its position  parallel to
 the  skimmer  tank  and  south   for   300  feet  (91 m)  (see
 Figure  1).    The  replacement  pipe,  repaired by  the same
 contractor  that  installed the interceptor  trench,  was
 8-inch (20 cm)  ceramic tile sewer pipe.

      To repair  the caved  in trench, the Company decided to
 excavate  caved  in material  and to  fill  the  trench with
 coarse gravel,  thereby allowing ground water to  enter the
 sump  from which  it could  be  pumped  into  the  treatment
 system.   This did  not reduce  the  functional  efficiency of
 the  interceptor trench.   The trench design was  modified so
300.70(b)(l)(iv)
(B)
pipe relining
and sleeving
                                       2-22
-------
 that a  second  sump was  constructed on  the  east  side  of
 Avenue X.   Installation of  the trench  was  completed  in
 October 1980.

      The  skimmer   tank  was  taken  out  of  operation  in
 October 1980 and was  closed out by  November 1980.  Company
 engineers determined that  the  first  step  for  closing  out
 the skimmer  tank  would  be to  install a  pipe  along  the
 chemical drain  which would  bypass the line that leads into
 and out of the skimmer from the chemical  drain.   Once  the
 bypass sewer line  was installed, the skimmer tank connec-
 tions  were blinded off  at  both the  skimmer  tank  and  the
 sewer  manholes.  The  intervening  pipes were disconnected
 so that  if later  the  empty  skimmer  tank had  tended  to
 float  due to buoyant action  of ground  water,  there  would
 no longer  have  been any pipe  connections to  disturb  the
 integrity of the sewer  line.

     The accumulated sludge  in the  tank  was  analyzed  so
 that  its  constituents  were  known  for proper  treatment.
 The Company contracted with  a  permitted  waste  hauler  to
 pump  out the contents of the  skimmer tank and haul  it  to
 their  treatment facility  approximately  15 miles  (9  km)
 from the site.   The permitted  waste  hauler also rinsed  out
 the tank to remove  any  residuals and  also  transported this
 rinse  water to  their  treatment  facility.   The skimmer tank
 was rinsed a second  time and  the  rinse  water  was  pumped
 into  the  chemical  sewer for  treatment  in the  activated
 carbon  system.   As  soon as  the  skimmer  tank was empty,  six
 1-inch  (2.54 cm) holes were drilled  in the bottom of  the
 skimmer  tank to collect  any  perched ground water.    The
 perched  water that was present  was  immediately  pumped into
 the chemical sewer  for  treatment in  the   activated carbon
 system.   The skimmer tank was  then  filled  with  sand by  the
 same  contractor that had   built the  interceptor  trench.
 The skimmer  tank was then covered with  local soils.   Vege-
 tation  soon established itself  in the area.

    ^At  the present time the  dewatering  of the  trench  is
 continuing  and both sump pumps  are operating at a combined
 rate of 18  to  20  gallons  per minute  (68-76 1pm).  This
 rate, equivalent to approximately 28,000  gallons per day
 (106,000  Ipd)  is maintained steadily throughout the year
 except  for  times when one  or  both of  the pumps malfunc-
 tion^).   The  pumps  each  have their  own discharge line
 into  the carbon  treatment   unit so  that   if  one  is not
operating  the   other  can.   Repair  is  usually  completed
within two weeks.   The  only other times  the  pumps do not
operate  are  during  heavy winter rains because the  plant
treatment  system   can  not handle   the  water  from the
intercept trench in addition to the  storm water runoff.
300.70(b)(l)(ii)
(A); (D)
surface seals;
revegetation
                                     2-23
-------
     Ten permanent ground water monitoring wells have been
left in  place  at Site  B.   These  are checked  monthly by
Company  officials and  reported to  the  State to  ensure
that the dewatering system is operating properly.
COST AND FUNDING

Source of Funding

     The  Company  paid for all investigation and response
actions at the site.

Selection of Contractors

     The  Company  used  its  own  geology and  engineering
departments to  investigate  the  site and design the inter-
ceptor drain, therefore contracting was  not necessary for
these elements  of the response.  For  construction of the
trench, the  Company initially  requested  fixed-price bids
from a number of contractors.  However, all bids submitted
were  far  in excess  of the  $65,000 that the  Company had
estimated  the  work  would  cost,  ranging from  $90,000 to
over $100,000.   Consequently,  the  Company  elected to act
as  its  own  contractor,  directly purchasing most  of the
materials required  for the  drain  and  hiring an excavation
contractor on a  time and materials  contract.  The Company
selected  the  excavation  contractor on the  basis  of  past
favorable experience with the firm.

Project Costs

     The  total   cost of  the  investigation  and   remedial
actions was  $268,217.   The bulk of  the cost,  almost 80
percent,  was for  constructing  the interceptor drain.  The
remainder  was   for  investigation,  engineering,  replacing
the chemical drain,  and  decommissioning the skimmer  tank.
A summary of the costs appears  in Table  2.

Site Investigation
     The  site investigation  cost  $23,974.   Most   of the
expenditure  was   for in-house work by  the  Company geology
department, which  totalled 80 man days  at $274 per day, or
$21,920.  Most of  the investigation took place between the
fall  of  1979 and  June 1980,  but  the  geology department
also  performed  some  data  analysis  during  the drain  con-
struction between  August  and  November 1980.    The  work
included:  drilling 32  soil borings,  19 with a hand  auger
and 13  with  a  power auger; analyzing the borings; mapping
water  levels and  the zone  of  contamination; and working
with  the  Company engineering department on design of the
300.68(c)
responsible
party
300.68(f)
investigation
                                      2-24
-------
  TABLE 2.  SUMMARY OF COST INFORMATION - ANONYMOUS SITE B
Task
Site Investigation
Engineering
Intercept drain
Installation
Chemical drain
replacement
Closing skimmer
tank
TOTAL
Estimated
Expenditure
N/A
N/A
$65,000
N/A
N/A

Actual
Expenditure
$23,794
$21,177
$207,046
$ 9,000
$ 7,200
$268,217
Variance
N/A
N/A
+21 ex
N/A
N/A

Estimated
Future Cost
N/A
N/A
$150/year
N/A
N/A

Funding
Source
Company
Company
Company
Company
Company

Period of
Performance
9/79-6/80
4/80-11/80
8/80-10/80
10/80
10/80
9/79-11/80
(Source:   Company Engineer, 1983)
-------
drain.   In  August 1980,  the  Company spent $1,874  for an
outside contractor to  conduct a  television  inspection of
1,800 feet (549 m) of the storm drain.

Engineering
     Engineering  for  the  remedial  actions cost  $21,177,
all of which was  in-house work by the Company engineering
department.  This work  included  reviewing remedial alter-
natives;  designing  the  interceptor  drain; preparing  bid
specifications; reviewing bids;   and  overseeing installa-
tion of the drain.  This work took place between April and
November 1980.

Execution of Remedial Actions
     The  total  cost  of installing the  interceptor drain,
replacing  the  chemical  drain;   and  decommissioning  the
skimmer tank was $223,246.  This  includes $206,523 for the
construction contractor, $9,662 for materials purchased by
the Company,  $6,250  for  off-site disposal of  waste  from
the  skimmer tank,  and $811  for 66.5  hours of  in-house
labor.

     Since all three tasks were performed at the same  time
by  the  same contractor, the  available data do  not permit
an exact breakdown of  the  cost  of each task.   However, it
is  possible  to  make  the  following reasonably  accurate
estimates.

     Drain  Installation -  The  bulk  of  the cost, about
$207,000,  was  for  installation  of  the  261  foot  long
(80 m) ,  12 to 17 foot  deep  (3.6-5.2 m)  interceptor drain
and 20 foot (6 m)   deep sump.   This figure includes about
$197,500  for  the  contractor, $9,000 for  materials, and
$500  for  in-house  labor.   The   contractor  cost  includes
labor,  equipment  rental,   and  gravel   fill.    Of  the
materials  cost,  the  largest  element  was $2,921  for 550
feet (168 m) of 12-inch (30  cm)  pipe purchased before the
planned trench length was reduced from 500 feet (150 m) to
261 feet  (80 m).   Other material costs  were:   $1,189 for
147  feet  (45 m)  of  2-inch  (5 cm) carbon  steel  pipe and
fittings, used for carrying intercepted water from the two
sumps to  the  treatment system; $799 for  submersible pumps
and  accessories;  $537 for 2,700  square  feet (251  m2) of
vinyl-coated wire  screen for  wrapping  the pipe;  $213 for
338 square  yards  (283  m ) of Monsanto C-22 permeable  pipe
wrap; and other miscellaneous items.
     The  Company1s  initial  estimate  for  installing  the
 interceptor  drain was $65,000.   While  it is difficult  to
 determine  why the actual  cost was 218  percent more  than
 that figure,  there were  some factors that  clearly  added  to
 the cost.   First, two sumps, rather than only  one,  had  to

                                     2-26
300.70(b)(l)
ground water
controls: sub-
surface drains
-------
 be  built,  both  with  pumps  and plumbing, when  the first
 sump  excavated  west  of  Avenue  X  was  found  to  be
 obstructed.   Second,  some  steel  sheet  piling  rented for
 the  trench  excavation  could  not  be  removed   after  the
 trench  was  completed,  and had  to be purchased and left in
 place.

     Chemical Drain Replacement  -  The  Company   paid  the
 construction  contractor about  $9,000  to  replace 300 feet
 (91  m)  of the chemical  drain with 8-inch (20 cm) ceramic
 tile pipe,  buried 4  feet  (1.3  m) below  grade  along the
 east  side  of  Avenue  X.    This  figure  includes  all
 materials.

     Decommissioning  Skimmer  Tank -  The Company  spent
 approximately  $7,200  to disconnect,  clean out,  backfill,
 and  close the 15,000 gallon (57,000  1)  skimmer tank.  Most
 of  this cost was  the  $6,250 spent  on transportation and
 disposal of sludge and  rinse water at  a licensed hazardous
 waste  landfill.   There  were   no available  data on  the
 quantity of waste  removed.   The rest  of  the  cost was for
 in-house  labor  and  plumbing  and  backfilling by  the
 construction contractor.

 Operation and Maintenance
     Operation  and  maintenance  costs  for  the interceptor
 trench  are  very  low.   There  are no costs for treatment of
 contaminated  water  because  the water  is treated  in  the
 plant's  existing  treatment  system,  which  has ample capa-
 city.   The  cost  of  electricity  for the two 0.5 horsepower
 sump  pumps  is negligable.   The pumps  are  replaced  about
 once  per year, at  a cost of  about  $150 each.    Company
 personnel  monitor  water levels  in observation  wells
 monthly, which takes about 30 minutes per month.
PERFORMANCE EVALUATION

     The response  actions  taken at Site B appear  to  have
been timely and effective for controlling and removing the
contaminated  ground  water discovered.   The  selection  of
the interceptor trench as opposed to a wellpoint system or
a barrier wall  was the most economically  and technically
feasible choice  in view  of the past history  at  the  site.
Additionally, the  choice to decommission the  skimmer  tank
by removing  its  contents,  rinsing,  and  then  filling  it  in
appeared to be the best way to eliminate the source of the
contaminant  problem.   However,  because the  skimmer  tank
was the primary source of the contamination,  it might  have
been advisable to have emptied  its contents prior to  or  in
conjunction  with,  the  installation  of  the  interceptor
trench as opposed to  after, so  that the  possibility of any

                                     2-27
-------
further contaminants entering the ground water would have
been eliminated.

     The interceptor trench and ground water  pumping have
apparently met the  objective  of  creating a  cone  of
depression  intercepting  and  containing  the  contaminated
water.  However data is not available  to  indicate  whether
or  not the concentration  of contaminants  in the  ground
water has been reduced.

     Hydrographs were  prepared by  the Company geologist.
As Table 1 shows, there was only  a  slight  decline in water
levels  from April  to July  1980.   Thus,  the  ground water
level  at   the  end  of  July prior  to  trench  construction
appeared  stable.   The  changes in water  level noted once
trench  construction  had  begun were  the  result  of trench
dewatering.  A sharp decline in ground water levels can be
seen  during the  period  from  August  to  October  in both
Wells  2  and  10.    This   indicates  that  the  dewatering
process  was  indeed  effective.    The difference  in  the
change  between  Wells 2 and  10  is  because  Well  2  is  430
feet  (131  m) from  the  trench  while Well  10  is much closer
to  the trench  at  a  distance  of  24  feet  (7.3 m).   Addi-
tionally,  Figures  5, 9, and  10 show  water  levels prior to
construction of the  trench,  water  levels  during trench
construction,  and water   levels  after one   and  one-half
months  of continuous pumpage during  trench  construction.
By  the  end  of September  1980  a   pronounced  cone of
depression had  been  produced by  the trench dewatering.
Water  levels continued to  decrease  through  December 1980.
Apparently  the  interceptor trench has  succeeded  in
intercepting  and  containing  the  contaminated water.   In
order  to  determine  whether or  not  the  contaminant  con-
centrations  have decreased  it would  be  necessary to
compare monitoring data  before,  during,  and  after trench
construction.    Because  this data  is  not   available,  a
complete  evaluation  of the system cannot be made.
                                      2-28
-------
I
KJ
               Figure 9.  Ground Water Elevations During Trench Construction, September 26, 1930
              (Source:    Anonymous Site B Company Geology Department, 1980.)
-------
I
U>
o
                 Lower
                 Pond
                                                                   Skimmer
                                                                    Tank
                       Scale, feet
                                        O  Monitor well and no.

                                        2
                                        O  Sump and no.
                   Figure  10.  Ground  Water Elevations After Trench Installation,  December 8,  1980
                   (Source:      Anonymous Site B Company Geology Department, 1980.)
-------
                                 BIBLIOGRAPHY


Anonymous Site B Company Geology Department.  1980.  Report on Ground Water
     Intercept Trench for Anonymous Site B Facility, CA.

Company Engineer.  September 1982 - February 1983.  Personal communication.
     Anonymous Site B Facility, CA.

California Regional Water Quality Control Board.  September 13, 1982.  Case
     Study File Review.  Conducted with the assistance of Mr. Harold Singer,
     California Regional Water Quality Control Board, CA.

Company Official and Company Engineer.  September 15, 1982.  Case Study Site
     Visit Made to Anonymous Site B   Facility, CA.  Personal Interviews
     Conducted with Mr. Lee Erickson and Mr. Stewart Baldwin, Anonymous Site B
     Facility, CA.

Knapp, Hobart C.  December 1982 - January 1983.  Personal Communication.
     California Regional Water Quality   Control Board, CA.

Knapp, Hobart C.  September 16, 1982.   Case Study Personal Interview.
     Conducted at California Regional  Water   Quality Control Board, CA.

Singer, Harold.  September 16, 1982.  Case Study Personal Interview.
     Conducted at California Regional  Water   Quality Control Board, CA.

Soil Conservation Service.  September  1977.  Soil Survey   of Anonymous
     County,  California.  U.S. Department of Agriculture in Cooperation with
     University of California Agricultural Experiment Station.
                                     2-31
-------
-------
                                 ANONYMOUS SITE C

                                 DEPERE, WISCONSIN
  INTRODUCTION

       Anonymous  Site  C  is  a  small  chrome  plating  shop
  located in a  residential  neighborhood  in DePere,  Wiscon-
  sin,  near Green Bay.    In late  1978  and early  1979,  the
  Wisconsin  Department of  Natural  Resources (WDNR)  responded
  to  neighbor s  complaints  of spillage  of liquid  chromium
  waste  from the Anonymous  Site  C facility.   Investigation
  by  the  WDNR  and  by an  engineering contractor  hired by
  Anonymous  Site C showed  that  soil and shallow ground  water
  at  the  site  were  heavily  contaminated  with  hexavalent
  chromium,  and  that  some  contamination  had migrated into  a
  garden  adjacent  to  the site.

  Background

      Anonymous  Site C  has  occupied the DePere  site  since
 1971,  performing  custom  chrome  plating on industrial
 machinery.    From late 1978  through June 1979,  the  WDNR
 investigated  a  series  of  complaints   from  neighbors
 adjacent to  the  site reporting  that  Anonymous  Site  C
 personnel were dumping yellow liquid on  the  ground on the
 west side  of  the building  (Figure 1).   The analysis  of
 ground water  samples from  the site  in June 1979  indicated
 hexavalent  chromium contamination levels up to 1,200 mg/1.
 The  WDNR ordered Anonymous  Site  C to conduct  an  investiga-
 tion of the extent  of soil and ground water  contamination
 at the  site.  A preliminary investigation  in  June  1979 and
 a detailed  investigation  during July  to  December  1979
 revealed that soil was  contaminated with  as much  as  1,406
rag/kg  of total  chromium and  ground  water  contained up  to
 1,440  mg/1  of  hexavalent   chromium.   The WDNR   ordered
Anonymous   Site C to submit  a plan  detailing  the  measures
that the  company  would take   to  remedy  the contamination.
At the time  of the  order,  all  parties  assumed   that   it
would probably  be necessary to excavate and remove  as much
as 600  cubic  yards  (460  cu.  m)  of  soil,  in  addition  to
controlling the flow of surface and ground water
 NCP  Reference
300.68(e)(2)
amount and form
of substances
                                     3-1
-------
       Figure 1.   Surface  Characteristics and Ground  Water Flow Patterns at Anonymous  Site C


                                                                                  RH Track
I
ro
Approximate
ground water
elevations
                                                                                             Direction of
                                                                                             ground water

                                                                                             flow
-------
       In   April  1980,   Anonymous Site C engineering  con-
  sultant,   Soil  Testing  Services  of Wisconsin (STS) sub-
  mitted  a  plan to  the  state proposing construction of a
  12   foot  deep  (4 m)  interceptor drain around the two down-
  gradient   sides  of   the  contaminated  area,   in  lieu of
  removing  contaminated soil.   The plan also proposed a dike
  and  an impoundment to control surface water.

       The  WDNR  accepted  the  concept  of  the  plan,  but
  required  further  sampling  to  ensure  that  the  proposed
  trench would  extend  below  all  contamination.  Subsequent
  well  sampling   indicated   ground water   contamination  at
  25 feet (7.6 m)  beneath the  ground  surface.  Consequently,
  in August 1980 the WDNR  ordered Anonymous Site C  to  con-
  struct  the  trench to a  depth of  25 feet  (7.6  m)  which
 would  have  cost three to  four times  as  much as  the  orig-
  inally  proposed 12  foot  (4  m)  depth.   Anonymous Site  C
  rejected  WDNR's  order,  responding  that  the  deeper  contam-
  ination  detected  was  a  result  of  seepage  through  the
 monitoring well  casing.

      During  the  fall  of  1980,  the   state  initiated  an
 enforcement action against  Anonymous  Site C, to bring  the
 company  into  compliance with WDNR's   remedial  action
 requirements.   The enforcement action was prompted by  the
 company's protest  against  excavating a 25-foot  (4.6 m)
 deep  trench.   The owner  of  Anonymous Site  C,  basing his
 opinion on earlier test  result data,  claimed that  contam-
 ination did not  extend  beyond 12 feet (4 m)  and a  25-foot
 trench was unwarranted.   In defense  of  this position the
 company conducted  additional  soil  borings and  groundwater
 sampling at the  site  and  confirmed  the fact  that contami-
 nation didn't  extend  beyond 12  feet  (4  m).   Consequently
 in December 1980,  WDNR approved  Site C's original plan,
 allowing the drain to be  installed  at a  depth  of 12 feet
 (4 m).

 Synposis of  Site Response

      The remedial actions  at  Anonymous Site C consisted of
 two  major  components:   ground  water  control and  surface
 water  control.   The ground  water control  was  constructed
 in January 1981  and consists  of a 240  foot long  (73 m), 12
 foot  deep  (4 m), L-shaped  subsurface  drain  running along
 the southern  and western boundaries of the Anonymous  Site
C property, sloping toward  a  sump at the  northern  end.  The
drain  is  a  perforated  pipe  at  the bottom  of  a  gravel-
 filled,  clay-capped trench.

     The surface  water control was  built   in May 1981,  and
consists of a 2  foot high  (0.6  m) earthen  dike paralleling
the trench,  which  diverts runoff  to   a  25  foot  (7.6 m)
300.70(b)(l)
(iiiXD)U)
ground water
controls:  sub-
surface drains
                                     3-3
-------
square  surface impoundment.   The  collected  surface and
ground  water  is pumped  through  a  sanitary sewer  to the
DePere sewage treatment plant.

     In addition, in July 1981, a contractor for Anonymous
Site  C  excavated  the  top  3  feet  (l  m)  of soil  from a
garden  immediately  west of   the   trench   on  neighboring
residential property,  and  replaced  it  with clean topsoil.
Some of the excavated  soil  was added  to the dike, and the
remainder  was  spread  on  the Anonymous  Site  C  property
southwest of the plating shop.

     Currently, Anonymous Site C submits quarterly surface
and ground water monitoring reports to the  WDNR.
SITE DESCRIPTION

     The  surface  characteristics  and  hydrology  of  the
Anonymous Site C site are discussed separately below.

Surface Cjaa_r_acter_i_s_t_ic_s_

     The  company  occupies approximately  three  acres in  a
residential  community.    The northern  and eastern  bound-
aries of  the  site  are defined by a city  street  leading to
the plant entrance and a  railroad track,  respectively (See
Figure  1).    A shallow ditch runs parallel  to  a 2 foot
(0.6m)  berm  along  the  western  site boundary  with four
residential  properties abutting the site to the  south  and
west.  Most   of  the land on the site  is  relatively flat
except  for   a downward  4   to 5  percent slope from  the
plating shop  toward  the south and southwest  corner of  the
property.

Hydrogeology

     The  first 25  to 30 feet (7.6 to  9.1 m) of  soil under-
lying the site consists of glacial  till  composed primarily
of a reddish  brown  silty clay laced  with lenses of clayey
sand, fine   sand,  and  fine  gravel.   In  the   site area
specifically, there  also exists  fill material  consisting
of clay chunks,  and trace roots,  extending to  a depth of
about 5  feet.  This  uncontrolled fill was  backfilled into
the area south  southwest of the  plating shop  during an
unspecified  period of time.   The  deeper zone of contami-
nation  may  be attributed to  this fill material  because it
provides  a more  permeable path for  contaminant  migration.

     Beneath  this layer  is  a layer  of Galena-Plattville
dolomite,  approximately   200 feet  (61 m)   thick  and
characterized by small horizontal  fractures  which prevent

                                      3-4
300.68(e)(2)
population at
risk
300.68(e)(2)
hydrogeo logical
factors
-------
  significant  downward migration  of water.   This  formation
  is  also  a low yielding  (generally less than 10 gallons [38
  1]  per minute) drinking  water aquifer which  is  tapped by
  several  private  wells  in  the  area.   A  major  aquifer,
  heavily  used  for  all purposes  in the area,  lies  beneath
  the dolomite  layer and  is  composed  of Saint  Peters
  sandstone.

      Water movement in  the upper  25  feet (7.6 m)  of  soil
  at  the site   generally  follows the surface  elevation  con-
  tours  (See Figure  1)  and, because of  the uneven  distribu-
  tion of  clays,  sand,  and  gravel,  the  rate of  ground water
  f low^ would  be expected  to be  quite  variable;  probably
  ranging  from  slow to  very slow  to  no  movement  at   all
 within short  vertical sampling intervals.
 WASTE DISPOSAL HISTORY

      In January 1979 WDNR documented  one spill of  concen-
 trated chromic acid  plating  bath from the western  door of
 the  Anonymous Site  C  facility.   Prior to and  immediately
 following  that  spill,   local  residents  reported  numerous
 incidents of  intentional  dumping of  chrome  plating waste
 in  the  same  area.    Some  of  these   complaints  included
 reports^ of  damage to  the vegetation on  two neighboring
 properties.    It   is  uncertain  whether  any  intentional
 dumping  actually occurred at  the  site,  however,  there was
 no question  that   large  amounts  of  chromium  had  escaped
 from the  plating  shop and  seeped into  the  surrounding
 soil.
 HISTORY OF CONTAMINATION

      The Wisconsin Department of Natural  Resources  (WDNR)
 was  called to the site several times during  1978 by local
 residents  who  claimed that  the  facility  was engaged  in
 illegal  dumping  and  that  this  dumping was  damaging
 neighboring  lawns  and gardens.   During these  visits,  WDNR
 officials  were  not able to document any evidence that  the
 dumping  had   actually occurred.   Finally,  in  January 1979,
 a large  spill  of  chromic   acid plating  solution escaped
 through  the west door of  the  plating shop  and covered  much
 of  the  southwestern  corner  of the  site.   A lot of  this
 spillage,  described  in WDNR  reports  as  several  pools  of
yellow  liquid mixed  with snow,  apparently  seeped  into  the
ground  despite  efforts by Anonymous Site  C employees  (in
 response^ to  a  WDNR   request)  to  shovel  chromium contam-
 inated   ice  and snow back   inside the plating shop where
it could  melt  and   enter  the  floor  drain  leading   to
the sanitary sewer.  To  minimize  the  migration of   the

                                     3-5
300.63(a)(4)
discovery
300.68(c)
administrative
process
-------
unrecoverable chromium, WDNR officials directed Anon. Site
C  to  cover  the  entire  affected  area  with  a  synthetic
liner.  The  WDNR  also  required  Anon.  Site C to hire a
consultant  to  do  some preliminary soil and ground water
sampling  at  the site.  The sampling effort, conducted in
June of 1979, included the construction of 16 shallow soil
borings (using  hand  augers)  at between 0 and  2.5  feet (0
to  0.8 m)  deep  and  8  wells  (also  using  hand  augers)
between 2.5  and 3.6 feet  (0.8  to 1.2 m) deep.   Figure 2
shows  the  location  of  these  sampling  areas  which  were
backfilled  after  the sampling  was complete.   It  should be
noted that  the  synthetic  liner  was only  temporarily
removed  during   these  investigations  and  that  the  liner
remained  in  place until  all of the  remedial  actions were
completed at the  site.

     Hexavalent  chromium in  well  #16 was measured at 1200
mg/1  and  only  two (#19  and #21)  of the eight sampling
wells   showed   no apparent  chromium contamination.  The
22  soil  samples taken  from  the soil  borings  could not be
reliably  quantified  because they were not  digested with
acid  prior  to  analysis;  rather,  10 grams of  each sample
was leached  for 24 hours with 200 ml  of water.   However,
the  results of  these  soil  leaching  tests  strongly indi-
cated  chromium  contamination because  of  the  large ranges
of  values obtained from  samples  taken within such a small
area  of land.    Also  indicative  of  contamination  was the
high  concentrations of  hexavalent chromium which  is not
normally present  in the natural environment.

      On   the  basis  of  these  preliminary findings, WDNR
required  Anonymous Site C   to retain  a  consultant to:   1)
conduct   a  full  scale soil and  groundwater  study of the
site,  2)  determine  the   areal  extent  of the  contamina-
tion,  and 3) propose possible  remedial measures.

      The  sampling for  the  second  investigation at  the  site
was conducted  from July to December 1979 and  involved  the
drilling  of 10  wells between 5 and 27.3  feet  (1.5  to 8.3m)
deep  and exploratory  borings  between  11.5  and 15.6  feet
(3.5  to 4.7 m)  deep  (Figure  3).   Both  the soil borings  and
well  holes  were  drilled with  a  solid stem auger  attached
to a CME-55  rig  mounted  on  a  Bombardier  all-terrain
vehicle.     Occasionally   there  were  problems  with  hole
collapse  necessitating a change from the solid  stem  auger
to a  roller bit attachment.  In  these  situations,  a 3  3/8
inch  (8.6 cm)  casing was driven to  the depth  of the  auger
hole  and the roller bit was activated using water  as  the
drilling fluid.  After  completion of   each well  boring a
1  1/4 inch (3.1  cm) diameter  slotted  PVC observation  well
was installed with a 4 inch (10  cm)  diameter,  carbon steel
protector pipe  and  lock.    The  annulus  of  each well  was
300.64
preliminary
assessment
300.68(f)
investigation
                                      3-6
-------
Figure  2.
Locations of Shallow Borings and  Wells
Sampled  During Preliminary Investigation
at Anonymous Site  C
               Plating Shop
             Ot     O2   3O
                                             on        \
                                                012
                               SHED
                                                            \&Z2
                                                   ©13
                                                               114
                           COW.
             O4    OS    SO

                      OT
                                «  — — J?^-=""=' ^^-~— ""              *2I     \
                        a ia
           a zo
 A19
                                                  G  SOIL SAMPLE
                                                  &  WATER SAMPLE
                               3-7
-------
                      Figure 3.   Location of Soil Borings and Wells Constructed During
                                 the Second Round of Sampling at Anonymous  Site C
                                                                                   RH Track
LO
I
Co
-------
filled first with pea gravel, then with a bentonite slurry
followed  by a  sand  and  gravel  layer,  another bentonite
layer,  and  a  concrete  plug  at  ground  level.   All   soil
borings  were  backfilled  with  bentonite-sand  mixtures.
Soil samples were taken in most of the well and bore holes
at 2.5 foot (0.8m) intervals with a  split spoon sampler.

     The  results of  this second  round of  soil   sampling
revealed  an average total chromium  level in  the  soil  of
about  L90 mg/kg  (dry  basis) .   This level  was determined
using  agressive hydrofluoric  digestions  of the   soil
samples to  completely solubilize all  the chromium  bound  by
the soil.   The use  of  this method on uncontaminated soils
from  the  same  general  site  area  established a background
total chromium level of 60 mg/kg (dry basis).   The highest
level of  chromium found in the  contaminated soil  area was
1400 mg/kg  (dry  basis).   Figure 4 outlines the  approximate
surface area beneath which the chromium-contaminated soils
were  found.   The depth of the  contaminated  soils in  this
area ranged  from zero  to 12  feet  (3.6m)  with the highest
concentrations   generally occurring  between  3  to 5  feet
(1 to 1.5m).

     Ground water samples  taken during  the second  round  of
sampling  were  found  to  contain  up to  1,511  mg/1 total
chromium  and  1,440  mg/1  hexavalent  chromium.  Background
total  and hexavalent chromium  levels in the  ground water
were measured  at < 0.1  and < 0.05 mg/1,  respectively.  The
areal  extent  of ground water contamination was not deter-
mined  conclusively,  however  the  general  flow of  ground-
water  in  the  area was  demonstrated to be very  slow due  to
relatively  impermeable soils.   It  should  be noted  that
seams  of  silty  clayey  sand  found in  the  area could  have
transported  contaminated  ground  water  beyond the bound-
aries  of  contaminated  soils  shown  in Figure 4.   However,
it  is  just  as   possible that  these  seams,  which   were
encountered in  all  but  the dry wells,  may  not  be  con-
tinuous .
PLANNING  THE  SITE  RESPONSE

Initiation  of Response^

     The  WDNR  order  to  implement  a  remedial response at
the  Anonymous  Site   C   site   was   based  on a potential,
rather  than   immediate   threat  to human  health  and the
environment   posed by uncontrolled  hexavalent  chromium
contamination.  The contaminated  surface water  or  ground
water  could have  entered a  storm sewer, a  pathway  likely
to carry  the  contamination a great  distance from the site.
The  contaminated  surface  water  ponded  on  the  site  also

                                      3-9
300.68(e)(2)
(i)(A) popu-
lation at risk
-------
            Figure 4'  Approximate  Boundaries  of  the  Contaminated Soil at  Anonymous Site C
I
I—'
o
-------
 posed some potential for exposure to humans or animals by
 direct contact.

      Further,  contaminated   surface   or  ground  water may
 have  posed  some  threat   to vegetation near the  site.  A
 neighbor  adjacent   to   the Anonymous   Site  C   property
 alleged that  trees  and  grass  in her yard  were  killed by
 chromium migrating  from  the site.  Another neighbor, whose
 garden abutted the Anonymous Site C property, feared that
 her produce would be rendered inedible by the chromium.

      The  contaminated   ground  water  posed  no immediate
 threat  to  drinking water supplies,  since the  contami-
 nation was  limited  to a small area  in soils of relatively
 low  permeability and  all  homes  in  the area were  supplied
 by the city water system.

 Selection of Response Technologies

      The WDNR and  the   Anonymous  Site  C were  in  regular
 communication  as  the extent of contamination at  the site
 was  being  determined.   During  this  period,  it  was
 generally  believed  by both  parties   that  all  of  the
 chromium-contaminated  soil  needed  to  be  excavated  and
 removed  from  the  site.    In   December  of  1979',  the
 consultant  to  the  Anonymous  Site C  determined  that
 approximately  300   to   600 cubic yards (229 to 459 M3) of
 soil   would  have  to  be   excavated  and  removed  if this
 initially-proposed  option  was  selected.   However,   the
 final   report,  submitted  by  the  consultant in April of
 1980,  recommended a different remedial design option which
 included  the following components:

     •  A  ground water  interceptor  trench to   collect
        contaminated ground water  for pumpage to the city
        sewage treatment  plant.

     •  A  surface impoundment  to  collect  surface  runoff
        from the contaminated areas.

     •  Excavation of contaminated soils from a neighbor-
        ing garden.

     These  recommendations  were  followed  by  lengthy
negotiations between officials from  the  state,  the  city,
and the Anonymous  Site C.
300.68(e)
(2)(iv) environ-
mental effects
300.68(e)(2)
(i)(D) hydro-
geological
factors
300.68(h)
initial
screening of
alternatives
on:
     The major  issues  raised  during these talks  centered
     •  The relative cost  and  benefits  of excavation  and
        removal vs  trenching  and  collection
                                     3-11
-------
     •  The appropriate depth of the interceptor trench

     •  The  potential  for  added  costs  to  the  city
        resulting  from their acceptance  of  chromium-
        contaminated water from the interceptor  trench.

     The  excavation issue was  resolved  in favor  of the
trenching and  collection option  because  the  chromium
adsorbed to the soils was primarily in the trivalent  state
which  is  virtually nontoxic  and  immobile;  therefore the
relative  risks posed  by  the  site  would  not  have been
significantly  reduced  by the more  costly  option  of soil
removal.   It  should be noted that  this  reasoning did not
apply to  the chromium  contaminated  soils in a neighboring
garden.   Here,  there was additional  concern over chromium
uptake by vegetables grown in the garden.

     The  issue of  trench  depth  resulted  from  review of
ground water sampling  data after  the recommended remedial
response  was  proposed.   Samples  from one  of  these  wells
indicated  that the  depth  of  contamination was  about  10
feet (3m) lower than originally believed.  To resolve this
issue, 3  additional  soil borings  were  made in the area of
the  suspect  well.  The  results of  these borings revealed
that  seepage  must  have  occurred   from  the  upper soil
layers through the annular space of the well.

     The  issue of  contaminated interceptor  trench  water
was  resolved through a formal agreement between officials
of the city sewerage system, the Mayor,  and Anonymous Site
C officials as described in the following section.

Extent of Response

     The  WNDR  faced  three  issues  in  deciding what the     300.68(j)
extent of the remedial action   should be:  -the question of     extent  of  remedy
whether  the  soil  should  be  excavated;  the  appropriate
depth of  the  subsurface  drain;  and the effluent  criterion
that  would determine  when operation  of  the  surface and
ground water  collection systems could  cease.   During the
site  investigation  in  late 1979 the  WDNR assumed that, in
addition  to  installing some  kind  of ground water control,
it would  probably  be  necessary for  Anonymous  Site C to
excavate as much  as 600 cubic yards  (459  cu. m)  of contam-
inated  soil  and  dispose of  it  in  a  licensed   hazardous
waste  landfill 120 miles  (193 km)  from the  site.   This
requirement would have increased  the cost of the remedial
actions 500 to 1,000 percent over the cost  of  the remedial
actions that were finally  implemented.   Anonymous Site C,
a  small  business,  probably  would  not  have had the
resources to finance such  a project.


                                     3-12
-------
     Upon  further  study, however, the WDNR concluded that,
because  of  the  chemical   properties   of  chromium,  soil
removal  would  not  be necessary  provided  a  ground water
control  was   installed.  Hexavalent chromium, the valence
state  of  the   chromium spilled  from the Anonymous Site C
shop,  is  highly   toxic  and  mobile in  water and soils.
However,  as  hexavalent  chromium moves through  soil,  it
tends  to  react with organic  matter   or  other  electron
donors  and  is reduced  to  trivalent  chromium,  which  is
readily  adsorbed  to the soil particles  and  is relatively
non-toxic.   Consequently,  the WDNR  concluded  that  it was
permissible  to  leave the  soil  in  place.    Much  of  the
hexavalent  chromium in  the  soil  and  ground  water could be
expected  to  be reduced  to trivalent  chromium,  and  the
remaining  hexavalent  chromium could be  expected  to even-
tually be  removed by  the subsurface drain.

     The   second   issue concerning  the  extent  of  the
remedial  action was  the  appropriate  depth of  the  drain.
The  WDNR and  the  company's  engineering consultant  agreed
that  the  drain  should  be  placed  below  the  contaminated
zone.  After the  consultant submitted  the remedial  action
plan, there  was some  dispute between Anonymous Site C and
the  WDNR about the actual  depth of contamination.   When
the WDNR concluded  in December 1980 that the contamination
only  extended to approximately  12  feet (4 m), Anonymous
Site C was permitted  to  construct  the  drain  as originally
proposed.

     Finally,  the  WDNR established criteria  defining  the
duration  of  operation  of  the  surface  and  ground  water
collection  systems.   Anonymous  Site   C is   required  to
continue  pumping  water from  the  sump  and   the  surface
impoundment  into  the  sanitary sewer until discharge
monitoring  shows,  in  a  consistent  trend,  that  total
chromium   is  below 0.5 mg/1, and that  hexavalent chromium
is  be low  0.05 mg/1.  The  WDNR  based  its  criteria  on
chromium  discharge limits established  in  the  Wisconsin
Pollution Discharge Elimination System (WPDES).

     The remedial  action  plan submitted by  the company's
consultant  in April  1980  qualified  that at a  minimum,  a
2-year  pumping period  would  be required  before  ground
water levels would  fall below the discharge  limits.   Addi-
tional time  extensions  would be available  if  groundwater
flow rates were slower  than anticipated.   Recent sampling
indicates  that  groundwater  still remains highly  contami-
nated, suggesting  that  it  will  be necessary  to  continue
the operation of the system.
300.68(e)(2)
(i)(C) hazardous
properties
300.68(e)(2)
(iii) state
approach to sim-
ilar situations
                                     3-13
-------
      The DePere sewage treatment  authority  agreed  to
 accept  the   effluent   from  the  system without pretreatment
 because the  chromium   concentrations  were low enough that
 the   contaminated   water posed no danger of impairing the
 operation of the treatment  plant.   Anonymous Site C signed
 a  contract  with the  city that  contained  a  number  of con-
 ditions regarding   the  city's  acceptance  of  the  effluent,
 requiring Anonymous Site C  to:

      •   Record   the quantities   of  water  pumped  into  the
         sanitary sewer,

      •   Sample  the  water regularly,

      »   Pay  a  fee for  regular  city  inspections  of  the
         collection  system,

      *   Indemnify  the  city for  any  additional  costs  of
         disposal   of   sludge  that  might  result   from
         Anonymous  Site  C effluent  causing the sludge  to be
         classified  as hazardous.
300.70(b)(2)(ii)
direct waste
treatment
methods
DESIGN AND EXECUTION OF  SITE  RESPONSE

     The  remedial response  at  the Anonymous  Site C  site
consisted of  three major  components.   These  were:

     •  A groundwater  interceptor  trench
     •  A surface impoundment

     *  Soil  removal at  a neighboring  garden.
     In  January  1981,  the ground water  interceptor  trench
was  constructed  with a small backhoe  to an average  depth
of  12  feet (3.6  m)  around  the  perimeter of the  contamin-
ated  area  (Figure  5).   This  depth  was  estimated  to  be
between  2  or  3 feet (0.6 or 0.9m) below the extent  of  the
contaminated  soil.   After  excavation,  the  bottom of  the
trench was  lined  with  a 4 foot (1.2m) wide  sheet  of  poly-
ethylene and  240  feet  (73 m) of 6-inch  (15.2cm)  diameter,
slotted  PVC  pipe was  installed.   This  drain  pipe  was
intersected vertically at 3  locations with 4-inch  (10cm)
diameter PVC  sampling  pipes  (R-l, R-2,  and R-3 in Figure
5).  Each  of  the sampling pipes  extend  about  1 foot  (0.3
m)  below the  drain  pipe  to  ensure  collection  of  adequate
sample volumes.   The drainage pipe has an  average  slope of

                                     3-14
300.70(b)(l)
                                                               subsurface
                                                               drains
300,70(C)(2)(i)
excavation
-------
                           Figure 5.   Remedial  Design Installed  at Anonymous Site C
          Sewer
          clean-out
          location
                 O
LO
I
^z

Sanitary sewer

Plating
shop




**%% ConcreteV
V& pfld






#-
—
«
J
                                                            Strip 3 feet deep
                                                         and replace with garden
                                                         topsoll
              Surface
              water
              Impoundmen
-------
5)
           the

                                                      with
clay material.
     The  excavated material  from  the  trench  was  tem|o-
                        »-ch
 ±nect.T  r-       .alons the  western
 border  of  the   site so  that all surface water would flow
 toward the  surface impoundment.

      The surface  impoundment was  completed  in May  1981
 usinfa SFord  7500P front-end  ^er/bacKhoe  «d  was
 designed to  c«t.» . tb. runo^  r^  aj .^ *     .^

 25^:°^ onVch^side'and 4 ?f eet deep and -as a 3-inch
 f7.fi delp coarse i-^H-- prevent  er „„ »^ The
                                                        300.70(b)(l)
                                                        (ii)(B) surface
                                                        water diversion
                                                        and collection
                                                        systems
 Figure  5) .
The
           excavation of contaminated soil from  •
  cubic yards (230 m   of "V" *£    (0.9 m).  The excavated
  area to an average depth ot J teec w.5
  !ni1 throuehout  was  spread on the Anonymous  Site  C prop
  "ty.  ^e elated area was then filled with topsoxl.

  COST AND FUNDING

  Source of Funding

       Anonymous  Site  C   paid   for   all   remedial  work   and
                                   osp
                          to^determine the  appropriate  depth
                                                          300.68(c)
                                                          responsible
                                                          party
   of the  drain.
                                        3-16
-------
Selection of Contractors

     Anonymous Site C did not engage in a competitive  con-
tractor  selection  process;  instead  they chose local
contractors who were qualified to do the  work.   The  first
contractor  selected  was Foth  &  Van Dyke  and  Associates,
Inc.,  a  consulting  engineering  firm  in  Green   Bay,
Wisconsin.   Foth  and Van Dyke performed  the initial  site
investigation  in   July  1979,  and  continues  to  perform
quarterly sample analyses.

     In  the  fall  of  1979,  Foth  and  Van Dyke  referred
Anonymous  Site  C   to  Soil Testing  Services  of  Wisconsin,
Inc. (STS),  another  consulting engineering firm  in  Green
Bay, when  it became apparent  that  the  site investigation
and  remedial design  would   require  STS's more  extensive
geotechnical  expertise.   STS  performed  further  site
investigation,  designed  the  remedial   actions,  and  gave
Anonymous  Site C technical  assistance  in meetings  and
legal proceedings with the WDNR.

     Anonymous Site C chose DeGroote Construction Company,
an  excavation and  construction contractor  in Green Bay, to
implement  STS's remedial action  plan  in January, May, and
July of 1981.  Anonymous  Site C used DeGroote,  rather than
STS,  to  implement  the  plan because  Anonymous  Site  C
believed  that DeGroote  could perform the work  for a lower
cost.

Project Cost

     The  total cost  of  the investigation  and remedial work
at  Anonymous Site C from September 1979  to July 1981 was
approximately  $23,000.    In  assembling the data  for  this
case  study,  it was  not  possible  to determine  the  exact
cost of the  work  because  Anonymous  Site C  records were not
available  for review.   Consequently, only  a general break-
down of expenditures, based  on estimates  provided verbally
by  persons  involved  in  the  clean-up,   is  possible  (see
Table 1).

Site Investigation and  Remedial Design
     Anonymous Site  C  incurred  approximately  $15,000  in    300.68(f)
expenses   from STS  between  the  fall of  1979 and  the fall    investigation
of  1980.   Of this  amount,  about $8,000  was for the site
investigation,  including soil borings, well installation,
sampling,  and  interpretation of  data.    Design of the
surface  and  ground  water   collection  system   cost   about
$2,000.   Anonymous Site C incurred a cost of about $5,000
for the  time STS  spent after the remedial action plan was
submitted,  helping  Anonymous  Site C  negotiate  with the
WDNR over  the depth  of  the drain.

                                     3-17
-------
              TABLE 1.   SUMMARY OF COST INFORMATION-ANONYMOUS SITE C, DEPERE, WISCONSIN
Task
Site investigation
Remedial design
Technical assistance
in negotiations w/
WON II
Installation
of drain, surface
controls
Operation and
maintenence
TOTAL
Expenditure
$8,000
$2,000
$5,000
$8,000
N/A
$23,000
Estimated
Future Cost
N/A
N/A
N/A
N/A
$r,qoy
year (a)

Funding
Source
Anon C
Anon C
Anon C
Anon C
Anon C

Period
of
Performance
7/70-12/79
12/79-3/80
4/80-12/80
1/81-7/81

9/79-7/81
i
h—'
CO
                        (a) Duration of operation undetermined.

                               Figure does not include sampling.
-------
     Foth and Van  Dyke  also  performed  some initial inves-
tigation, but  an estimated of  the  cost of that  work was
not available.

Construct ion  of  Intercept  Drain  and  Surface Water
Diversion System
     DeGroote   Construction's  execution  of the remedial
actions  cost about $8,000.  This included:  all labor and
materials  involved excavating  the 240 foot long, 12 foot
deep  trench;  installing the drain, sump and pump; build-
ing the dike; constructing the 25 foot square, 4 foot deep
surface  impoundment;  and  replacing  300 cubic  yards  (230
cu. m) of topsoil  in the neighboring garden.

Operation and Maintenance
     The cost of operating and maintaining the surface and
ground water collection systems is probably less than $600
annually, excluding  sample analysis.   The major  cost  is
regular  inspections  by  the  DePere  sewage  treatment
authority,  which  are  performed  two  or  three  times  per
month,  and   cost  $15  per  inspection.    DePere  does  not
charge  Anonymous  Site  C  for  treatment  of  the  effluent
because  the  city's sewage treatment charges  are  based  on
water consumption, rather than on discharge.

     The  cost of  electricity  for  pumping the  collected
subsurface and ground water  approximately  100 feet (30  m)
to  the  sanitary  sewer  is negligible.   During  1981,  the
sump  pumps,  operating  intermittently  for  a  total of  60
hours, pumped about 72,000 gallons (275,520 1) of water to
the sewer, at a rate of 20 gallons (76 1) per minute.

     No  cost   information  was   available  for  sample
analysis.  Every three  months,  Anonymous  Site C personnel
collect  samples  from  eight   locations  in  the  collection
systems and monitoring wells, and deliver them to Foth and
Van Dyke, where  they are analyzed  for  total  chromium and
hexavalent chromium.

PERFORMANCE EVALUATION

     WDNR now requires  the  Anonymous  Site  C  to  submit
quarterly monitoring  reports  on water  samples  taken  from
the R-l and R-2  sampling  points,  the  surface  impoundment,
the trench  sump,  and  from wells  1-A, 2,  3, 5,  and  16.
These monitoring data  are eventually  expected  to  show  a
decline of total and hexavalent chromium at these sampling
locations.
300.70(b)(F)
ground water
controls: sub-
surface drains
     To  date  however,   there  is  no  indication  of  a
reduction  in chromium  levels  at  any  of these  sampling
locations.   In  fact,  the  four sets  of  monitoring  data

                                     3-19
-------
compiled in 1982 show that hexavalent chromium levels in 3
wel1s  have  exceeded  the  previously  detected maximum  of
1 511 mg/1; reaching  a  new maximum chromium concentration
of 4,300 rag/1.   Seven of the 12  samples  taken from these
three wells  in 1982 had  hexavaleat  chromium levels above
2,500 mg/1 and  six  of these seven were at  or above 4,000
mg/1 hexavalent chromium.   Samples  taken  at R-l, R-2, and
the sump have chromium levels in the same general range as
the well  samples.   The  surface  impoundment is  generally
low  in chromium,  usually ranging  from <  0.1 mg/1  to  a
maximum of  0.2 mg/1.   However, on  occasion,  levels have
been as  high as  60  ppm.    Although all  the samples were
analyzed for both total and hexavalent chromium, virtually
all the chromium  present  was found to be  in  the hexavalent
form.

     The high  chromium  levels  found in all  sampling  loca-
tions except the  surface  impoundment,  indicate that  a very
long time period  will be needed to flush all  the chromium
from  the  site.   This does  not  necessarily  mean, however,
that  the  chosen  remedial response was  inadequate  or was
poorly  installed.  Rather,  the long time period needed to
restore  the site probably reflects  the  slow and  uneven
drainage  in  the area.  It is not possible  to  draw  affinal
conclusion on  whether the remedial  response was  sufficient
to  arrest the further escape  of chromium from the  area
because  several  more  soil borings  would  be  needed to
determine  whether  the  sand and gravel  seams in the  area
 are  continuous; and, if  so, whether they extend below  the
 interceptor  trench.  In  any event,  it can  be stated  with
 confidence  that:    1)   surface water  runoff  from the
 contaminated  area has been  adequately controlled and 2)  if
 any continuous sand or gravel  seams do exist  in the area,
 they would  not be likely to contaminate any drinking wells
 or cause any other adverse exposure  situation.   The first
 of these statements  is  supported by  the  past performance
 of the runoff  control  system  which consists  of  the berms
 and the  surface impoundment.    It  is felt by some  that
 supporting evidence  for  the  second statement is  found  in
 the local  geology  which  includes  of a 200-foot  (61  m)
 layer of dolomite beneath the contaminated  area.  Although
 this  is  not   condoned  by all  parties   involved  it  is
 generally felt that despite the  dolomite layer  being used
 as a  source  of  drinking water in the area,  its alkaline
 chemistry would  precipitate  out any  chromium moving down
 with  the  water  from  the upper  contaminated  zone.   As
 previously mentioned,  the  homes  in the  immediate  area of
 the Anonymous  Site  C site are supplied  by the  city water
 system.
                                      3-20
-------
                                 BIBLIOGRAPHY


DeGroote, Dan.  January, 1983.  Personal communications with JRB and ELI.
     DeGroote Construction Co., Green Bay, Wisconsin.

Hermann, Douglas J.  January, 1983.  Personal communications with ELI and JRB,
      Soil Testing Services of Wisconsin, Inc., Green Bay, Wisconsin.

Kraft, George J.  December, 1982.  Personal communications with JRB and ELI.
     Wisconsin Department of Natural Resources, Green Bay, Wisconsin.

Pagels, Jeff C.  December, 1982.  Personal communications with ELI and JRB.
     Wisconsin Department of Natural Resources, Green Bay, Wisconsin.

Rossberg, Douglas C.  December, 1982.  Personal communications with JRB and
     ELI.  Wisconsin Department of Natural Resources, Green Bay, Wisconsin.

Soil Testing Services of Wisconsin, Inc., Green Bay, Wisconsin.  September,
     October, 1979.  Reports on test results regarding chromium contamination
     at Anonymous Site C.

Soil Testing Services of Wisconsin, Inc., Green Bay, Wisconsin.  April 16,
     1980.  Remedial Action Plan for Chromium Contamination, Anonymous Site C

Thorsen, John W.  November, 1982.  Personal communications with ELI.  Roy F.
     Weston, Inc., West Chester, Pennsylvania.

Thorsen, John W., Stensby, David G. , April 1982.  Impact of Chromium Waste
     Spill in Glacial Till Soils.  1982 Hazardous Material Spills Conference,
     Government Institutes, Inc., Rockville, Maryland.

Wisconsin Department of Natural Resources.  December, 1978 to December, 1982.
     File materials, Anonymous Site C, Green Bay, Wisconsin.
                                     3-21
-------
-------
                             BIOCRAFT LABORATORIES

                                 WALDWICK, NJ
INTRODUCTION

     Biocraft  is  a  small  synthetic  penicillin manufac-
turing  plant  located on  a  4.3-acre (1.72 ha)  site in an
industrial  park of  the  town of  Waldwick,  NJ  (population
10,800)  (see  Figure 1).   Sometime  between  1972, when  the
plant  opened, and  1975,  when  the  pollution  problem  was
discovered,  two pipes  leading from  the plant  to under-
ground waste  solvent  storage tanks  leaked into  the  ground,
contaminating  an  area 360 feet (110  m) x 90  feet (27 m)
about 10 feet  (3 m)  thick.  The waste  solvents  seeped  into
a  storm  sewer,  which flowed  into a  nearby  creek   (see
Figure 1)   and also  contaminated  the shallow aquifer.   The
pollution  was  suspected by  local health  officials as
having  been  responsible  for a fish kill in 1973.  A  town
drinking water  well  less  than a 1/4  mile away  draws  from
a deep  aquifer.  The town of  Waldwick  was concerned  that
the high  level of  contamination  would eventually  contam-
inate the well,  but the  state believed  that contamination
of wells was unlikely because of  hydrogeology.   On  July 1,
1981 before the ongoing ground water decontamination oper-
ation began,  a test well was installed on-site,  upgradient
from  the pollution   source and an  artificial ground water
mound.  Chemical  analysis  revealed   85,000 ug/1 acetone,
55,000 ug/1 methylene chloride and  648 mg/1 COD (chemical
oxygen demand) in samples taken from this well.

Background

     Between  1972,  when  the  plant  opened,  and  1975,   when
the pollution problem was discovered,  two pipes  connecting
underground waste solvent storage tanks  leaked  an undeter-
mined amount  of butanol,  acetone  and methylene chloride
into the ground.   The amount of  leaked waste  solvents is
unclear, but it could have been   as much as 33,000  gallons
(125,000 1),  assuming that  the  gauging  system would  not
have  detected less  than 50  gallons  per transfer  of  lost
solvent  and  about  660  transfers,   were  made  prior to
problem discovery.  The  waste solvent   traveled through a
NCP Reference
300.68(e)(2)(iv)
environmental
effects

300.65(a)(2)
drinking water
threat
300.68(e)(2)
hydrogeological
factors
300.68(e)(2)
amount and form
of substances
present
                                     4-1
-------
                                                         N
-——J'^- ^-^^-:r^^'i^f^:\  -I'-f
   /fifeV&m Jacinto \&&tf \//', .$ ' /fi^V274  "V
                 LABORATORIES-f;
                     1 INCH -^ 2000 FT
Figure 1.   Location  of Biocraft Laboratories.  Ualdwick,  N.J
                             4-2
-------
storm sewer that ran through and in front of the site, and
led into a  tributary of Allendale Brook (New Jersey State
stream designation FW-2 non-trout).

     In the  spring of  1975 the director of the Northwest
Bergen Regional  Health Commission (NWBRHC) called the New
Jersey  Department  of Environmental  Protection  (DEP) to
report  an "obviously...degraded  ecological condition" in
the  Allendale  Brook  and  its  tributary, Hohokus Brook.
Wastes from Biocraft were  suspected  to  be  responsible for
a  1973 fish  kill  in  a pond into  which  Hohokus  Brook
empties.   The mayor of Waldwick  was concerned  about the
lack  of  a report from the Fish and Game Commission about
the fish  kill, and  about the  health of the children who
played in the brook.

     On June  2,  1975,  a  representative  of  the Passaic-
Hackensack  Basin  Element  of  the  DEP  and  two  NWBRHC
officials  performed a  preliminary  investigation of  the
Biocraft site  for possible discharges  into the tributary
leading  to  the  Allendale  Brook.   A  storm  sewer  was
reported  to  be discharging  contaminants  into  the  tribu-
tary, based on observations of "a strong pungent odor... in
the brook  and  in  the  sewer  pipe",  and a  "grayish-black
algal growth covering the entire bed of the tributary down
to  its  junction  with  Allendale brook" and in the storm
sewer.  The  odor and the  discharge flow were traced back
to  the storm  sewer junction leading  from  the  Biocraft
plant site, where a water sample was taken.  An inspection
of  the storm  sewer grates showed  no discernible  flow
coming from above  the  pipe leading from Biocraft.   A dye
test of the sanitary-industrial waste sewer did not reveal
any leaks  into  the  storm sewer,  that  would have suggested
the presence of an underground leak or unknown connection.
A  study  subsequently  performed  by  Biocraft's  consultant
revealed  that  a  leak  in  the  lines  to underground  waste
solvent storage tanks was responsible for the discharge.

Synopsis of Site Response

     The  underground feed lines to the storage tanks were
sealed in  the winter of 1975  and above ground feed lines
were  installed  to  prevent  future  ground water contam-
ination.   On  February 13,  1976,  Biocraft, with  its con-
sultant Princeton Aqua Science  (PAS),  began selectively
pumping five wells and disposing of the contaminated water
off-site  at  an industrial wastewater plant in Tonawanda,
NY.  An  incinerator at  Tricil, Inc.  in Canada was later
used to  dispose of the  contaminants, and  a pretreatment
facility in New Jersey also served briefly as the disposal
site.   Because of  the expense and  problems with disposal
300.70(b)(l)
contamination of
sewer line
300.64
preliminary
assessment
300.68(e)(2)
population at
risk
300.63(a)(4)
discovery
300.65(b)(4)
controlling
source of
release

300.65(b)(6)
off-site removal

300.7000(1)
subsurface drain
                                     4-3
-------
site availability, Biocraft sought other alternatives such
as  biodegradation,  using  in-house  expertise  from  its
antibiotic manufacturing staff.

     Biocraft initiated the currently (as of January 1983)
ongoing  remedial  action  on  June 30, 1981, using a  new
new ground  water collection system, on-site treatment and
reinjection  into  the  ground.  The  contaminated  ground
water  is  collected  from  a recovery  well (#P13)  in an
interceptor  trench  located  on  the  west  side  of  the
Biocraft building  and from two shallow wells (#'s P30 and
P32A)  on  the west  property  line  (see Figure 2).  This
contaminated  water  is  piped to settling  and activation
tanks where  aeration and nutrient addition accelerate the
activity  of  microorganisms  that  degrade  contaminants  in
the water.    The  treated  water  with  elevated  levels  of
aerobic  bacteria  is  injected into  two  trenches   on  the
southwest side of the property, upgradient from the source
of  the  contamination.   Nine  underground  aeration wells
were installed  along the  path  between the  injection  and
withdrawal trenches  to enhance  the  aerobic biodegradation
in  the  ground water.    In September  1982 air  injection
through two monitoring wells was  added.
300.60(b)(2)
microbiological
degradation
300.70(b)(iii)
(c)
groundwater
pumping
300.70(b)(2)(ii)
300.70(b)(2)(ii)
(A) (3)
biological
reactors
SITE DESCRIPTION

Surface Characteristics

     The Biocraft  site is  located  in a  small industrial
park  in the  Borough  of Waldwick,  Bergen  County,  New
Jersey.

     Climate  is typical  of the northern New Jersey area.
Winter  months  are  moderately cold  with average temper-
atures  of  35 °F  (0.56°C).   The  average  daily  minimum
temperature  is  27°F   (-2.8°C).   Lowest  recorded  winter
temperature  for this  area  was -7 °F  (-22°C)  recorded in
Newark  in  1949.   Average summer temperature  for  the area
is  73°F (23°C)  with  an average  daily  maximum of 82°F
(28°C).    The  highest  recorded  temperature  was  105°F
(37.8°C) in 1953 and 1966.

     Precipitation  averages 42 inches  (107  cm)  annually
with  a range of  30  to 56  inches  (76-142  cm)  annually.
Thunderstorms occur about 26 days  a  year  predominantly in
summer.   The  average  seasonal  snowfall  is 28  inches  (71
cm).   Storms producing more than 4  inches (10 cm) of snow
occur on the average of twice per winter.

     Relative   humidity  averages   54  percent   in  mid-
afternoon, with   higher values at night,  averaging about
300.68(e)(2)(i)
(E)
climate
                                     4-4
-------
73  percent near  dawn.   Prevailing winds  are from  the
Southwest, with an  average  speed of 10 miles  (16  km)  per
hour.

     The Biocraft property  is  about  4.3 acres  (1.7 ha) in
size.  It  lies in a  relatively flat  area  with  slopes from
0 to 3 percent.  The original  topography  of the surround-
ing  area has  been  somewhat modified by  regrading  for
buildings, parking lots, and streets.  About 30 percent of
the  area  of  the  property  is  paved  or  covered  with
buildings.  The  area  around  the  main  building,  roughly
10 percent  of the   property,  is grassed.   The remaining
60 percent  is  lightly forested with water  tolerant hard-
woods and undergrowths of ferns, grasses,  and sedges.  The
properties to the  east  of the  Biocraft  site are  pre-
dominantly covered by asphalt paving and office buildings.

     Three  basic  soil types were found  to occur  in  the
vicinity in  a  1925  soil  summary, i.e. Merrimac  gravelly
loam, Papakating silt  loam,  and muck.   Drainage for these
soil  types  ranges  from  very  well  drained  to  poorly
drained.   Ponded  areas  were  observed  near the  .southern
property boundary indicating shallow groundwater.

     The  western  property boundary  is located about 350
feet  east of a small creek, which flows toward the south-
west.  The  creek  receives  stormwater  runoff  from  the
Biocraft  site  and  from other  plant sites in the indus-
trial park.  The creek  empties into  Allendale  Brook which
drains into Hohokus  Creek.   Allendale Brook  and  Hohokus
Creek are  designated by the State of New  Jersey  as "FW-2
Non-trout;  suitable  for  potable,  industrial,  and  agri-
cultural  water supply;  primary  contact  recreation;  and
maintenance, migration,  and  propagation  of natural  and
established biota."

     A municipal ground water  well  is  located  about 1,000
feet southeast  of  the  contaminated  area.    Biocraft  also
operates a  deep  well that  is  directly under  the  contam-
inant  plume.   Figure  2  shows  surface features  of  the
Biocraft site.

Hydrogeology
     The  Biocraft site  is located in an area of unstrat-
ified and  stratified  drift  deposited by the "Wisconsin"
Glacier and  its melt waters  during the Pleistocene Epoch
of the  Quaternary Period.   A  geologic column showing the
underlying  substrata at the site is  shown in Figure  3.
Thin layers of silt and gravel  can be found at  the surface
up  to 3  feet  (1  m)  thick in the area, presumably  due to
300.68(3)(2)(i)
(A)
population at
risk
300.68(e)(2)
hydrogeo logical
factors
                                     4-5
-------
Figure  2.  Configuration  of  Biocraft  Site,  Waldwick,  N.J.
                K 3501
          Leak Occuned Here
          Appioxiinaie Conliymalion
           ol Coniaminant Plume —
            [> 100 mn/1 CODI

                  Deep Well •-
                                                                              •— Undeigfound Tank Farm
                                                                         Wed Location About
                                                                        1000 FM( from Area ol
                                                                           Conwnirwlian
                                                                                 ^ ponded Aicas
-------
Figure  3.    Geologic  Column  for  the Biocraft Site
                              .v
                                   0-3 FMt.* Sat and Gravel
3-15 PMI.* Gtacial THI and Stratified Drift
                                   40 Fact.* Samiconaolidateti sat and Fine Sand
                                    >60FMt.* 8run«wick Shale
                                                        Formation ThirJiiwws
                                 4-7
-------
earlier  stream  deposition.    In  addition, regraded  soils
can  be  found  near  the  surface  due   to   construction
activities.

     Glacial  till   (unstratified   drift)  underlies   the
surface at a thickness of about 8 to 15 feet  thick.   It is
a  poorly sorted  mixture  of boulder,  cobbles,  pebbles,
sand, silt, and  clay.   Some  stratification  occurs  within
the  till  layer  due  to glacial meltwater  deposition which
is believed to have resulted in large permeability differ-
ences around the site.   Permeabilities  (hydraulic conduc-
tivities) have been  calculated  for five  monitoring wells
from slug tests and have been found to  range from 0.02 tg
36 gallons per day per square foot  (9.4 x 10    1.7 x 10
ro/s) .

     Approximately 40  feet  of  semiconsolidated  silt  and
fine sand underlies the  till  layer.   Visual  inspection of
the  material  in  this  deposit  suggested  very  low  perme-
ability, but no  actual  testing  was conducted on  this
strata.  This formation was considered to be an aquiclude.

     Brunswick Shale  of  the  Triassic Newark Group  under-
lies the site at a depth of 50 to 60 feet (17 - 20 in) » and
a  thickness  of several hundred   feet.   The Brunswick
formation  is  the  primary water  supply  aquifer for  the
area,  yielding  an average  of  125 gallons (473  1)  per
minute for 29 wells in the area with an average well depth
of  320   feet.    Primary  ground  water  flow  occurs  in  the
interconnecting fractures, vertical joints,  and faults in
the  shale,  while little  or  no yield  is  obtained  in  the
rock.   Most of the  wells  of substantial yield have been
drilled  to  great  depths  in order  to  contact a sufficient
amount of water bearing  fractures.

     A  municipal  deep well  is  located  in  the Brunswick
formation   approximately   1,000  feet   southeast  of  the
underground discharge area.   Biocraft Laboratories  have
also installed  a deep  well (in  the Brunswick   Shale)
on-site  to  supply water  to  their  chemical  manufacturing
operation.

     Ground water  elevations, flow rates,  and directions
were calculated  by  Geraghty &  Miller,  Inc.,  Consulting
Ground Water Geologists  and Hydrologists, Port  Washington,
N.Y.  in March,  1979.    Twenty-two wells  with continuous
level  recorders were  used  to  define the  ground water
regime.   Figure 4  presents  ground water monitoring well
locations,  and  typical  elevations,  isopleths,  and   flow
directions  at the  Biocraft   site.   As  can  be seen  from
Figure  4,  ground  water  flow is  somewhat irregular  in  this
area,  being  affected  by  heterogeneous  geology,   surface

                                     4-8
-------
Figure  4.   Water Table Configuration at  Biocraft site
                   (Source:  Geraghty & Miller. 1979)
-------
cover, and possibly  other  factors.   The  configuration  is
not constant but can change  substantially with  the  season
and the amount of precipitation.

     A noticeable  ground water mound  is present,  corre-
sponding  to  the south  and  east  ends  of the  blacktopped
area  (see Figure  2).   This has  been explained by  the
consulting geologists  to  be  an area  of  ground water
recharge due to higher relative permeabilities in the area
of well number 22 and surface characteristics conducive to
recharge (wooded rather than blacktopped).

     Ground water flow  from  the mound  is  omni directional
with  the major  flow  regimes  moving towards  the northwest,
northeast, and  south.   In November, 1980  the predominant
flow  direction  was  to the south,  confirming the variable
flow regime.

     A distinct  ground  water  flow regime  trough occurs in
the northwest corner of  the  property,  corresponding  to an
area  of  surface  coverage  and  higher  permeability.    As
shown by  the  flow direction lines in  Figure 4,  a contam-
inant  plume  emanating  from  the leak  area  would  tend  to
flow  northwest toward the  trough  area.    It  is  also
possible  that the plume could  travel  toward the northeast
and south  given the changing  nature  of the  ground  water
configuration  and the  fact  that  the  area  of subsurface
leakage is inside the highest  isopleth in this particular
plot.

      Available  monitoring well  data  indicates  that  the
average ground  water   depth  ranges   from zero  to  about
9  feet, depending  on  seasonal  fluctuations.   Average
ground  water   temperature   ranges  from   50°F  to  54  F
(10-12°C).   Ground  water  velocities  were  calculated  by
Biocraft's  consultants  based  on  the  range  of  perme-
abilities  [0.02  to 36 gallons per  day  per square  foot (9.4
x  10   -  1.7  x 10  m/s)] and hydraulic gradients  [0.002 to
0.03  feet per  linear  foot  (0.0006 -  0.01  m/m)]  found at
the site.  Flow velocities were calculated  to  range from  a
maximum   of   1.5  feeE  (0.5 m)  per day   to  a  minimum  of
0.0002  feet  (7  x 10   m)  per day.  Average  flow velocities
on the more  permeable  zones  were calculated  to average
about 0.4 feet  (0.1  m)  per  day.   This  value  indicates  that
the time  required for  ground water to  travel from the  leak
area  to the eastern  property  boundary (collection point)
would be  about  11/2 years.
                                      4-10
-------
WASTE DISPOSAL HISTORY

     The  Biocraft site  is a bulk manufacturing plant that
produces  a  wide  variety  of  semi-synthetic  penicillin
products  including  6 aminopenicillanic  acid, ampillicin
trihydrate,   amoxicillin  trihydrate,   sodium  oxacillin
monohydrate,  sodium  cloxacillin  monohydrate, D(-)alpha-
phenylglycine  methylacetoacetate   potassium   salt,   and
D(-)-p-hydroxyphenyl glycine  methylacetoacetate potassium
salts.   A number of organic  and inorganic  raw materials
are  used in  the process.  Organic  feedstocks  include
potassiuro   penicillin   G,  methylene   chloride,   N-butyl
alcohol, acetone, methyldichloro silane, dimethyl aniline,
ethylene  glycol,  and   ethyl  chloroformate.    Inorganic
chemicals used  on-site  include  phosphorus   pentachloride,
liquid  nitrogen,  ammonium  hydroxide,  and  hydrochloric
acid.

     Ten  10,000-gallon   (37,800  1)  underground  storage
tanks are located at the  southeast corner of the building.
Seven  tanks store virgin and recovered  N-butyl  alcohol,
acetone,  and  methylene   chloride.   The eighth  tank  holds
process  wastewater  which   is   periodically  shipped  to
Earthline  Services,  Newark,  NJ  for  pretreatment.    The
ninth   tank  holds  spent  solvents  and  centrifuge  cake
washings  from   penicillin  cleavage   and   includes   the
following identified substances:
        Acetone
        Methylene chloride
        D ime thy1ani1ine
        ^N-bjjtyl alcohol
        Phosphorus acid
        Ethyl alcohol
        Methanol
        Ammonium chloride.
The  tenth  and  last  tank  stored  spent  solvents  from
ampicillin  processing,  including  acetone  and  methylene
chloride.  Stored  liquids  from the  last two storage tanks
were trucked  about twice  per  week to  Chemical  Pollution
Systems, Old Bridge, NJ for solvent recovery services.

     The underground  discharge causing  the contamination
problem was  traced to a  leaking  transfer  pipe  which  fed
storage tank  number nine, which  held spent  solvents  and
centrifuge cake washing liquors.  It is not known when the
underground line started  leaking, however  an  estimate has
been made  on  the  amount  of  material discharged  from the
time the plant opened  in  June,  1972 to  November 24, 1975,
the date when  the  lines  were  replaced.  The  estimate  is
based  on:   (1)  the actual  number of transfers  to  the
300.68(c)(2)
amount and form
of substances
present
                                     4-11
-------
storage  tank  during the  above period  (660);  (2)  a  tank
gauge accuracy  of  50 gallons  (190  l),  i.e.  discrepancies
under  50 gallons  (190  1)   could not  be   detected;   and
(3)  the  average  composition  of the  mixture.    Biocraft
estimated quantities discharged  into  ground  water for the
major components of  the mixture, as shown in Table 1.

     Trace  substances  included  phosphorus  acid,  ethyl
alcohol, methanol,  and  ammonium  chloride.   Other trace
substances, later  detected  in  the  ground water  which were
not  clearly  associated  with   Biocraft's  processes  were
heptane,  octane,  dissobutylene,   chloroform,  trichloro-
ethylene,     tetrachloroethylene,     benzene,    toluene,
m-p-xylene, and dichloroethane.
DESCRIPTION OF CONTAMINATION

     Contamination  at  the  Biocraft  site was caused by  the
leaking  underground lines  feeding  spent  process  solvents
to  an  underground  storage  tank.   Although it is not known
from the  plant's  investigations,  contamination could have
occurred  for  as long  as  3 years, from when  the plant
opened  to when  the source of  contamination  was  found  and
repaired.   It has  been estimated by the plant itself that
over 285,000 pounds (130 Mt) of solvents  and other organic
substances may leaked  into the subsurface  during this time
period.   Quantity estimates of  individual compounds have
been previously  given  in Table 1.

     The  contaminant  plume  flowed predominantly north  and
northeast toward the  eastern  edge  of  the  property and  a
storm  sewer,  and also  south toward the southern  property
boundary.   The storm  sewer discharged  into a small  creek
which  emptied  into  Allendale  Brook.   A contamination
problem was  first  suspected  in  1973,  when a  fish kill
occurred  in a pond receiving  flow from Allendale  Brook.
Subsequent inspections in  1975 revealed that  the  tributary
to  Allendale Brook was in a  degraded condition,  charac-
terized by grayish-black  algal  growth.   The storm  sewer
was suspected  of being the source  of pollution, since  the
same algal growth appeared in portions of the line and an
organic odor was  detected  at  the  discharge  point.  Data
 from  sampling of   the  flow  in  the sewer indicated  that
concentrations of  methylene  chloride,  n-butyl  alcohol,  and
dimethyl  aniline were  as  high as  114, 343,  and  32  mg/1,
respectively.  Chemical oxygen demands (COD)  were  found to
be  as  high as  7,539  mg/1.   Contaminated  flow  from  the
 sewer   was finally  attributed  to  joint  infiltration  of
 grossly polluted ground water emanating  from  the  Biocraft
 site.      The   leaking  underground   transfer  line   was
 discovered as a result of  an underground  tank  and  pipe

                                      4-12
-------
TABLE 1.  ESTIMATED QUANTITIES OF ORGANICS
      DISCHARGED AT THE BIOCRAFT SITE
       (Biocraft Laboratories, 1983)
Substance
Methylene chloride
N-Butyl alcohol
Dimethyl. aniline
Acetone
Water and trace substances
Percent
50
30
10
5
5
Estimated
Quantity
Pounds Metric tons
181,500
66,825
26,300
10,890
10,890
82.33
30.31
11.93
4.94
4.94
                 4-13
-------
testing  program  initiated  by  Biocraft  after  they  were
issued a New Jersey Department of Environmental Protection
Cease (NJDEP) Administrative Order.

     Six  ground  water monitoring  wells  were  installed
on-site   in  January,  1976  under  the  supervision  of
Princeton  Aqua  Science,  New Brunswick, N.J.  These were
2 inch (5 cm) well points  with depths  ranging from 10 to
15  feet  (3.3 - 5  m).   The  maximum depth  corresponds to
refusal resulting  from contact  with the semi-consolidated
silt/fine sand layer (see  section  on  hydrogeology).
Monitoring data from February,  1976 to  June  1976  for the
six  wells  showed  ranges  of concentrations  of  general
pollutant parameters as shown in Table 2.
     TABLE 2.  RANGES OF INITIAL MONITORING WELL DATA
                   AT THE BIOCRAFT SITE

                FEBRUARY, 1976 TO JUNE 1976
Parameter
pH
BOD
COD
TOG
Chloride
5.2
2 -
8 -
2 -
5 -
Range
- 7.5
21,000 mg/1
31,000 mg/1
9.625 mg/1
6,246 mg/1
 In  the  period from June,  1976  to early in 1979,  16  addi-
 tional  wells (making  a total  of 22)  were  installed  for
 monitoring  and  selective  pumping  of contaminated  ground
 water.   Geraghty and Miller used these 22 wells  for  their
 investigation of hydrology and contamination at  the  site.
 Eight  of the 22 wells were drilled  specifically for  the
 Geraghty and  Miller  investigation early in  1979.   No  wells
 were drilled  into  the  semi-consolidated  silt/fine  sand
 layer,  since  this was  not  required  by the NJDEP.

     Monitoring  data from  1977  through 1978  indicated that
 Chemical Oxygen  Demand (COD) was  the  best  indicator  param-
 eter for showing levels of pollution  in the  ground  water.
 Geraghty and Miller  plotted COD isopleths  for  the  1,000
 mg/1 and 100 mg/1 level based  on levels found in the wells
 on  March 5,  1979.  Figure  5 shows  the COD  isopleths along
 with COD  levels in the  various wells.   The  north-south
 flow components of  the   contaminant  plume  are easily
 distinguishable   from this  plot.  Also,  some  wells outside
 the main  plume   boundary  have  elevated concentrations of
 COD.   Geraghty  & Miller  stated  that these  areas  were
                                      4-14
-------
Figure  5:   Groundwater COD Isoplethe at the  Biocraft Site
                    (Source:  Geraqhty & Miller. 1979)
-------
contaminated  during  periods when  the water  table had  a
different flow configuration.

     Wells 2,  3,  8,  10  or  13  were  selectively  pumped at
different  time  intervals from  January 1977  through  1978
after monitoring  data  showed an increase in  COD.   At the
time  of the  Geraghty  and  Miller  study,  COD levels  had
dropped significantly (2% of initial value, in some cases)
due  to  this  selective  pumping  procedure.    As  mentioned
earlier,  no  monitoring  wells  were   drilled  into  the
Brunswick  shale  aquifer.   However,  Biocraft's  deep  well
taps  this  aquifer directly under one  of  the  most contam-
inated  portions of the southern component of  the plume.

      Data from this  well  in  1979 indicated a COD  of  1
mg/1,  suggesting   that  no  contamination  had  entered the
deep  aquifer  at the  well location or within  the radius of
influence of  the  well.


PLANNING  THE  SITE RESPONSE

Initiation  of Site Response

      In a letter  dated November 20,  1975, the DEP  directed
Biocraft  to  cease discharges   and  to begin  studying the
contaminated  storm sewer  discharge  problem.   The ^letter
responsible party stated  that  the wastes  were entering the
Allendale Brook through  the storm  sewer  serving  Industrial
Way and the DEP  had determined  the  discharges were  of "a
continuing nature"  and  thus  were  in violation of  State
law.   The  DEP letter  was  in response to  discovery of
surface water pollution due to  the  Biocraft site and  the
need to determine its  cause and potential impact on Aground
water.   Biocraft  performed a hydrogeological study in 1976
 in response to the DEP request.

      Ground  water  pumping and disposal  was initiated on     300.65(b)(6)
 February 13,  1977,  and  was  undertaken  pursuant  to  an     off-site removal
 Administrative Consent Order (AGO) dated January 12,  1977.
 This AGO was  agreed  upon by  DEP  and  Biocraft  based  on  a
 recommendation by the company's consultant, Princeton Aqua
 Science  (PAS).   The January 12,  1977  AGO provided that  if
 the  DEP  was  not satisfied that  sufficient  progress  was
 being made to decontaminate the affected  ground water,  it
 could  pursue other statutory  remedies.   Additional ground
 water  was extracted  through  the  use  of  bucket  wells
 installed  along  the storm  sewer  line along the northern
 and  western  property  lines.   This  pumping was  undertaken
 because  DEP  was  not  satisfied  with  progress  of  the
 original pumping  system.   In an Administrative  Order dated
 December  6,   1978,  NJDEP  ordered Biocraft  to   add   these

                                       4-16
-------
bucket wells and to  otherwise  comply  with  the January 12,
1977  ACO  and  to  develop  an  improved  decontamination
program for NJDEP approval.

     A  biostimulation process  for decontaminating ground
water  was instituted  in July 1981 pursuant to plans that
were  codified in  a September 25, 1980 ACO.  This process
was  developed  pursuant  to  the  December  1978 Adminis-
trative  Order  by  Biocraft  in  conjunction with  its  con-
sultants,  Geraghty and  Miller,  PAS,   and  Sun  Tech,  Inc.
This new  system  was  installed to  improve  the containment
and accelerate the decontamination of the ground water.

Selection of Response Technology

     A  number  of  alternative response  technologies  were
considered before  the colleetion/biostimulation/injection
process was undertaken.  These included the following:

     •  Collecting  and  treating  all  discharge  from the
        storm sewer  (interim  measure  to alleviate surface
        water problem)

     •  Resleeving   sewer  pipe,   grouting   joints,  or
        replacing pipe with non-infiltrating sewer pipe

     •  Excavating  entire contaminated  soil  column  under
        Biocraft site

     •  Surrounding  area with  a  grout  or  slurry cutoff
        wall.
300.70(b)(2)(ii)
biological
reactors
     In  December,  1975, NJDEP  proposed  collecting and
treating  all  of the  discharge  from the storm  sewer  as a
temporary  measure  to prevent  further  discharge  to the
stream.  Biocraft rejected this alternative on the  grounds
that  this  would require  collection of  runoff  from  other
properties  in the Industrial  Park as  well,  and enormous
flows  from precipitation  would  have  to  be treated or
disposed.     Biocraft   felt   that   this  alternative  was
inequitable   and  impractical.  In  June,  1976,  Biocraft
proposed  that  the town  of Waldwick replace or repair the
sewer pipe  to  prevent infiltration of  contaminated ground
water in  the sewer.  Technically,  this  alternative  would
not  adequately  deal with  the ground water  problem  since
contamination could  spread  in  the other  subsurface   flow
directions.
300.70(b)(l)(iv)
contaminated
water and sewer
lines
                                     4-17
-------
     From  January,  1977 through 1978 Biocraft selectively
pumped five  wells  to control  the plume, including  some
bucket wells installed in compliance with a December 1978,
NJDEP  Administrative  Order.  Collected  ground water had
been transported  to  three different  disposal  facilities,
including NEWCO, a landfill in Tonawanda, New York; Tricil
an  incinerator  facility  in  Canada;  and  Earthline,  a
pretreatment  facility in  Newark,  N.J.   This  additional
Administrative  Order also  stipulated  that  clean-up  was
proceeding  too  slowly   and   an  improved  decontamination
program should be developed.

     The  Town  of   Waldwick  indicated  concern  for  an
accelerated  clean-up  program, because of  degraded water
quality in  Allendale  Brook  and the possibility of future
contamination of their  municipal production well, located
about  1,000  feet from  the contaminated  area  (see Figure
3).  They proposed that the contaminated soil be excavated
from  under the  Biocraft  site.  Biocraft  rejected  this
alternative  because   it  would require  shutting  down^ the
entire Biocraft  facility, which it considered impractical.

     As  another possible alternative, NJDEP proposed that
a  slurry  wall  or  grout  curtain be constructed around the
site, and contaminated ground water pumped from within the
cut-off wall and treated  or disposed.  Biocraft found this
alternative to  be infeasible  because  of the dual costs of
constructing  the cut  off wall  and either treating or
disposing  of  wastes.  Also,  pumping did not  insure that
contamination would  be  removed from  the underlying soil,
which could preferentially absorb the wastes.

     Biocraft   and    their   consultants,   Princeton  Aqua
Science, Geraghty and Miller, and Suntech,  Inc.  developed
the  selected alternative  in May,  1979, which  included:
      (1)   Collecting   the   contaminant  plume   in   a  down
           gradient  subsurface  drain

      (2)   Treating    collected  ground  waters   to  remove
           contaminants   in  an  aerobic biological treatment
           system

      (3)   Injecting  treated  water   upgradient   in   two
           trenches  to  flush  soil  and  ground water of
           contaminants

      (4)   Enhancing in-situ biodegradation of  contaminants
           in soils and  ground  waters  by installing  a
           series  of continuous aeration wells.
300.70(b)(l)
ground water
pumping
300.68(h)
initial
screening of
alternatives

300.70(c).(2)(i)
excavation
300.70(b)(l)
impermeable
barriers
 300.70(b)(l)
 (iiiXD)d)
 subsurface drain

 300.70(b)(2)(ii)
 biological
 reactors
                                      4-18
-------
The selection of this process was believed to provide both
contaminant plume containment and removal of the source in
a  cost  effective manner,  since  collected ground  waters
were treated on-site biologically and the treated effluent
could be reinjected into the ground water, eliminating the
added cost  of disposal or sewerage.  Carbon treatment was
considered  but  was found  to be cost prohibitive.   Ozone
treatment  was  also  considered  but  bench scale testing
indicated it was relatively  ineffective.   Initial studies
of microbial  population  in the contaminated  ground  water
suggested that an adapted population was presently feeding
on  the  methylene  chloride  and  other  organics  present.
Later bench scale  work  to  optimize  the process  proved
successful.

 Extent  of Site Response

     Reduction in the  level of ground water contamination
is the  primary criterion  by which  clean-up  progress is
measured  at  the Biocraft  site.    Sealing of  the  storage
tank  lines  and the  storm sewer  were  important  in  elim-
inating the  source of  the contamination,  but did  not
directly  mitigate  threats  to  the  public health and  the
environment.  Treatment and reinjection of ground water is
directed at mitigating  these threats.   Contaminated soil
that  was   excavated   during  the   construction  of  the
injection  and  collection  trenches is  being  aerated to
background  (as  of  December, 1982).  These  actions were
directed  by   Administrative  Orders  and  Administrative
Consent  Orders, and  were  completed  in  accordance  with
these orders.

     The  ground water  quality  clean-up  goals for  the
decontamination program  were set  forth  in the  ACO  dated
September 25, 1980.  This ACO required Biocraft to operate
the decontamination  system until the DEP determined that
the ground  water has  an acceptable  quality,  or  until the
system  is  found to be  incapable of  achieving acceptable
levels of clean-up.  To this extent the goals set forth in
the ACO are  tentative.   Acceptable  water  quality  is
defined  in the ACO by the following parameters:
     BOD
     COD
     TOC
     chlorides
     PH
     Acetone
     methylene chloride
     butanol
 6.0 mg/1
23.0 mg/1
18.0 rog/1
153  mg/1
4.0 - 7.5
100  mg/1
 8.0 mg/1
100  mg/1
                                  300.70(b)(2)(ii)
                                  (B)
                                  chemical methods
                                  300.68(j)
                                  extent of remedy
                                  300.68(c)
                                  administrative
                                  process
                                     4-19
-------
     No  time  limit  was  set  for meeting  these  standards,
but the  DEP  may order  other  measures at  any time  if  it
deems them necessary.   Biocraft has stated that  at  least
18 months (from the July 1981 start-up) would be necessary
for the decontamination program to show results.
DESIGN AND EXECUTION OF SITE RESPONSE

     Installation   of   the   ground   water   collection/
treatment/injection  system was  completed  in  June,  1981.
The  research  and  development  stage  for  this  operation
included a hydrogeologic  study (discussed  earlier),  bench
and  pilot scale  studies for  the  biological treatment
system, and  design  and construction  of  system components
(collection and injection trenches, aeration wells, mixing
tanks,  etc.).   Research  and development of  the  bio-
stimulation process spanned a period of 2 1/2 years.  This
process  was   subsequently   patented  by   Biocraft   and
subsidiary,  Ground  Water  Decontamination  Systems  (CDS),
which  was  formed to  sell  the biostimulation process  to
other  parties  having  similar  ground  water  problems.   A
description of  the  design and  construction  of the essen-
tial system components is given below.

Bench and Pilot Studies
     A  number  of  studies  were   conducted  during  the
research and development stage to determine if the contam-
inated ground  water was amenable to biodegradation.  Past
research  indicated  that  acetone, n-butyl alcohol (BuOH)
and dimethyl  aniline  (DMA)  ranged from  fair  to  good with
respect  to  biodegradability.    The  biodegradability  of
methylene  chloride  (MeCl),   the  major  contaminant,  was
uncertain  based   on   past  research   and   Biocraft  was
concerned that methylene chloride's toxicity would inhibit
biodegradation.   Biocraft  conducted an  initial  survey in
August 1978 to determine the presence of microorganisms in
the  ground  water.    The  survey  showed  that  a  mixed
microbial population  existed in  all  the  ground  water
monitoring wells  at  a concentration of  10,000 to 100,000
cells/ml.  This suggested that the microbes were using the
contaminants as a carbon  source  since  two to three orders
of  magnitude  fewer  cells are  found  in  uncontaminated
ground water.   Biocraft  conducted shaker flask studies to
determine optimum growth conditions.  Addition of nitrogen
and phosphorus were  found  to  increase  cell growth as much
as  four  times the control.   Results of the shaker study
are shown in Table 3.  The first pilot  study was initiated
in December,  1978.  A small paint type  compressor was used
to  supply air  to monitoring well  #3  via a flexible air
diffuser.   Nutrients were added  directly to  the  well in

                                     4-20
300.70(b(2)(ii)
direct waste
treatment
methods
-------
                                      TABLE  3.   NUTRIENT STUDY

                                   (Biocraft Laboratories,  1983)
CHEMICAL
(NV2S°4
NH. NO-
4 0
Na,HP04.7H20
Soaiutn Phosphate dibasic
NaHjPO^. H20
Sodium Phosphate monobasic
KH PO^
Potassium Phosphate monobasic
MgS04 .7H20
Magnesium Sulfate
Na C03
Soaium Carbonate
CaCl2
Calcium Chloride
MHSO.
H
Manganese Sulfate
FeSO^ .7H20
Ferrous Sulfate
Concentration of cella
(mg/1, dry weight)
Total Count (cfu/ml)
CONCENTRATION
— rsrgvn
100
100
40
40
100
20
100
1
2
0.5


FLASK #
1
X

X

X
X
X
X
X
X
24.1
1.3xl07
2

X
X

X
X
X
X
X
X
25.7
1.6xl07
3
X

X
X

X
X
X
X
X
21.6
4.5xl07
4
X

X
X

X
X
X
X

23.3
3.0xl07
5
X

X
X

X
X
X


22.4
2.4xl07
6
X


X

X
X



20.0
1.9xlO?
7
X

X
X

X




19.2
2.3xl06

8
X

X
X






19.6
io7

Control










7.7
2.2xl05
Incubation temperature 18-20'C
I
ro
-------
aqueous solution.  After 7 days, the total count increased
from 10,000  to  1 million cells/ml.  Batch  and continuous
process bench scale  studies  were carried out  using water
from well #13  in 3.7  gallon  (14  1)  glass fermentors .
Batch  studies were  run at 68°F (20°C) with  the  nutrient
mix used  in  Flask #2  (see  Table 3).   A  large  decrease in
COD was observed  on  the eighth day.   A  large  increase in
cell count was  observed on day  nine.   A residual  COD of
300 to 400 rng/1 was  observed after the  12th day,  and was
attributed to biomass.   Studies conducted  at  86 °F (30°C)
showed  a  slight  increase  in  biodegradation rate  at the
higher temperature.  When  10  liters per  minute of air was
added, the rate  of biodegradation  increased dramatically.
Results are  shown in Table 4,  in which levels of specific
organics  were   steady for  the first  2  days  and  then
dropped.   This   suggests  that  volatilization  of  organics
was not a significant  factor  in reduction  of contaminant
levels.   Acetone  levels   increased in day  3.    This was
explained  by the  presence  of  isopropyl  alcohol,   (IPA)
which  is  transformed to acetone under  aerobic conditions.
The IPA was  formed from acetone in anaerobic conditions in
the ground water and  was reconverted  upon  aeration.   The
IPA was  masked  in  the  GC/MS   analysis  by  the  methylene
chloride peak.

     Continuous  process  experiments were  also done  with
two 3.7 gallon  (14  1)  glass fermentors  set  up in series.
The first was used  as the aeration tank while the second
vessel was used  as a  settling tank.   A  retention time of
17 hours  was maintained  in  the  aeration  tank.  Other
process parameters such as temperature and  nutrients  were
similar to that  of the batch studies.   Results of two runs
are shown in Tables  5 and 6.   After 4 days, MeCl^ was
reduced about  98% and  BuOH  was reduced 99%.   Levels of
acetone rose as  predicted and dropped  to 60 percent of the
initial value on the  fourth  day.   In another  run, MeClj
decreased more  than  90% in  3  days while DMA  was reduced
     A  pilot  scale  study  was carried  out to  give basic
information for  design of  the full  scale  treatment unit.
Two 55  gallon  (208  1)  drums arranged vertically were used
as  aeration  and  settling  tanks.    An air  sparge  system,
immersion heater, circulation line, and refrigeration line
were installed  in the aeration drum.   Four additional 55
gallon  (208  1)  drums were used to  store  and feed  contam-
inated water to the pilot plant.  A schematic of  the pilot
plant  is shown  in Figure  6.   Continuous biodegradation
studies were performed for  17  days.  Retention time in the
aeration tank  was  17 hours.  A nutrient solution was
pumped  at  1  percent of  the feed volume  and the aeration
                                     4-22
-------
 TABLE 4.   BATCH EXPERIMENT
(Biocraft  Laboratories, 1983)
Day
0
1
2
3
4
5
6
7
8
9
10
COD*
4326
3970
1499
2715
1346
912
678
513
307
255
241
Acetone*
-
84
69
230
134
92
21
11
ND
ND
ND
MECln*

3290
3190
826
311
28
ND
ND
ND
ND
ND
BuOH*
-
29
27
ND
ND
ND
ND
ND
ND
ND
ND
ND: Not detected. (Limit 1 rag/1)
*A11 values in rag/1
         4-23
-------
                                    TABLE  5.   CONTINUOUS PROCESS STUDIES RUN #47

                                             (Biocraft Laboratories, 1983)
-e-
i
Is)
-p-
INFLUENT CONCENTRATIONS*
Day MeCUt Acetone! BuOHt CODt
1
2
3
4
5
6
7
8
9975
4571
4847
4690
5040
4725
4583
4448
29
20
21
43
48
78
79
147
1091
491
518
508
584
501
476
431
11939
6320
6360
6460
6460
6115
5933
6437
CONTINUOUS
AERATION TANK
MeCl0t AcetoneT BuOHt CODt
9045
3285
1943
719
707
818
891
227
64
73
143
43
20
32
34
57
893
303
81
ND
3
30
ND
6
11497
5287
1908
1113
518
1127
759
440
                   ND:   Not  detectable.   Detection limit 1 mg/1.

                   tAll  values  in mg/1

                   *Extracted daily from Well #13
-------
                TABLE 6.  CONTINUOUS PROCESS STUDIES-BATCH #50
                         (Biocraft Laboratories, 1983)

Day
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
WELL #13
MEC1 *
— • 2
29
7
13
15
14
6
3
16
9
ND
7
5
10
5
ND

DMA*
64
63
69
61
61
67
57
66
65
72
64
45
59
34
6

COD*
342
271
397
305
311
405
174
344
337
334
342
266
297
149
187
ACTIVATION
MEClrt*
10
4
ND
ND
ND
5
ND
ND
ND
ND
ND
ND
ND
ND
ND
TANK
DMA*
18
23
28
16
22
20
24
15
7
1
1
1
1
ND
ND

COD*
190
182
184
164
168
170
178
141
.118
117
130
122
120
86
118
•
ND:  Not detectable.  Detection limit 1 mg/1

*A11 values in mg/1.
                                    4-25
-------
                                           Figure  6:   Pilot  Plant Design



                                                  (Source:  Blocraft.Laboratories, 1983)
•t-
I
                                                                                                 HH1 UM

                                                                                                 (fllM
                                                                                                 fUJWUM
-------
rate  was  0.1  gallons  (0.5  1)  per  minute.
shown in Table 7.
Results  are
     Methylene   chloride   levels   indicate   an   average
reduction of more  than 99%.   Butanol  levels  were reduced
an  average  of more  than  96%.    The  DMA  average removal
efficiency  of  59% was substantially  lower than  that  of
bench  scale  studies.    Average  removal  efficiency  of
acetone for the  17 day period was only 8 percent, because
of  the  formation of  acetone by  aerobic  transformation of
isopropyl  alcohol.     Average   removal   efficiencies  of
acetone, calculated  for the  period after  day 4,  indicate
an  average removal of  more than  81 percent, which is more
representative of  steady  state removal efficiencies.  The
COD  removal  efficiency averaged  about 58  percent.   This
relatively low efficiency may result from  the contribution
of residual biomass to COD.

Full Scale System

     The  full  scale  system consists of  a ground  water
collection trench  (Trench  A), a  four  tank dual biological
treatment   system,   two   effluent    injection   trenches
(trenches B and  C),  and a series of nine in-situ aeration
wells placed along the path of  contaminant flow.   A site
map  showing   the   locations  of   the  treatment   system
components  is  shown  in Figure 7.   Essential  elements  of
the  system are described below.

     —Ground Water Collection System
     The  primary  ground water  collection  system consists
of   a  subsurface  drain   (Trench A)   about 80 feet  (24 m)
long,  4 feet (1.2 m)  wide, and about 10  feet (3 m) deep.
A backhoe was used to  excavate the trench.  Wooden shoring
was  used  to support  the   sides  from  caving  in  until the
gravel and  piping  could be installed.   The configuration
of  the  ground  water  collection   trench is  shown  in  Figure
8.   A  central  collection well  was   used in the  system
design.   This  well  (#13)  is a  12 inch  (30  cm)  diameter
steel casing with a 2.5 foot (0.76 m)  slotted screen and a
10  gallon  (38  1)  per  minute stainless  steel submersible
pump.  It was originally  installed as  a bucket well  (large
gravel filled well) to  control the contaminant plume.  Two
16-  inch  (15  cm)  galvanized  steel collection  pipes were
hand slotted  and  welded  to  the  12  inch  (30  cm) casing.
Slot size is 1/4 inch  by  3 inches (0.6 x  7.6  cm) and the
position of  the  slots  are at 3  and 9 o'clock around the
pipe wall.   The  collection pipes  are  sloped  at  1 percent
toward  the  collection  well.   The  trench  has  two  2-inch
diameter PVC monitoring wells installed  on each  side  of
the  central collection well.   The envelope consists of a
                300.70(b)(l)
                subsurface
                drains
                                     4-27
-------
                                          TABLE  7.   PILOT  PLANT  STUDIES
                                          (Biocraft  Laboratories,  1983)
 I
NJ
00
INFLUENT CONCENTRATION (WELL #13)
Days MeCl,, Acetone BuOH DMA COP
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Avp.
£
980
865
145
1200
1145
1180
1060
1020
1140
1085
967
900
830
865
1170
1080
1187
989
93
105
27
20
9
9
23
12
20
10
10
5
8
5
10
15
29
24
54
53
54
52
53
57
57
57
59
51
50
46
45
46
71
76
71
56
240
235
412
430
417
445
425
419
420
335
320
305
300
290
357
365
357
354
1843
1664
2608
2683
2593
2713
2638
2488
2765
2178
2269
1842
1912
2158
2996
3112
3276
2455
EolidB MECl*
512
741
HA
NA
NA
NA
1047
740
951
596
853
NA
NA
836
936
746
NA
796
10
5
50
5
5
5
5
4
5
90t
1
5
525t
5
5
5
5
B
AERATION TANK*
Acetone BuOH
98
53
80
50
1
1
23t
1
5
7
1
NA
at
Nb
ND
ND
5
<22
ND
ND
ND
1
2
2
1
ND
3
7
ND
ND
36
ND
SD
ND
ND
<4
DMA
102
90t
173
169
162
184
167
150
152
150
113
128
256t
96t
132
120
45t
146
COD
647
574
1002
968
947
1043
934
1167
1147
1385
1160
942
1719
972
913
1007
1219
1041
                      ND:  Not detected.  Detection  limit 1  mg/1.
                      NA:  Data not analyzed
                      *A11 values  in mg/1.
                      tAnalytical  results questionable.
-------
Figure  7:   Elements  of  the Groundwater Decontamination System.
                        (Source:  Blocraft Laboratories,  1983)
-------
I

U)

O
                             Figure 8=   Configuration  of Collection  Trenches






                                              (Source:  Blocraft Laboratories,  1983)
                        PL»N VIEW
                                                                         T
                                                                          ¥


                                                                         1
                        IftMf VI|W

~\
-T
f
cr —
TTT ' T-f i-r


n
\-
IC^TT^-™-.





JP-






[ /—j~ .-j"1"
                                                                                         1
-------
 dual media gravel pack with a 6 inch bottom and side layer
 of 1/4 inch  (0.6  cm)  washed  stone,  about 4.5  feet (1.4 ra)
 of 1 1/2 inch (3.8 cm) washed  stone,  and a 1  foot (0.3 m)
 top layer  of 1/4 inch (0.6 cm) washed  stone.   Additional
 shoring was  required  to  install  the  side layers  of fine
 aggregate.   The  envelope was  covered with plastic  sheet
 and backfilled with earth to grade.

      Ground water pumping is also being carried out in two
 bucket wells  (#30 and #32A) on  the southern  edge  of  the
 property to  collect the  southern  component of  the contam-
 inant plume.  They  consist  of backhoe dug  trenches  about
 10 feet (3 m) deep by 4  feet  (1  m) wide by 16  feet  (5  m)
 long.   Well #30 has an 8-inch PVC fully slotted casing and
 well #32A has a 12-inch PVC fully slotted casing installed
 in the trench.  The trench has  been backfilled with 5 feet
 (1.5 m)  of 1 1/2 (3.8  cm) washed stone and about 5 feet  of
 earth finished to grade.

      Initial  pumping  rate  to  the  biological   system  was
 about  5,760 gallons (21,800 1) per  day which was  steadily
 increased during  a 1  year period.  Presently,  an average
'of 13,680  gallons  (51,780 1) per  day is pumped  from  the
 collection trench and  the bucket  wells  to  the biological
 treatment system.

      —Above-ground  Biological  Treatment  System
      The   above-ground biological  treatment   system was
 completed in  June,  1981.  It  consists of a dual system  of
 two  aeration  tanks and   two  sludge  settling  tanks, each
 tank  having a capacity of about  5,400 gallons  (20,000  1).

     A drawing of the  process  layout is  shown  in Figure  9.
 The stainless  steel   tanks  were  originally used  on milk
 trucks  and  after  the trucks  became  unserviceable,  the
 tanks  were modified by Biocraft  for process use.

     Influent water from the  collection  trench  and  two
 interceptor wells is  pumped  first  to the  aeration  tanks,
 where  most of the biodegradation occurs.  Air  is  added  to
 each  tank  through   a  series   of  porous  ceramic,, tube
 diffusers  at  a rate of 20 standard  cubic  feet  (0.8 m  ) per
 minute.  Temperature is kept  constant  at  68°F (20°C)  using
 a  single  pass steam  coil unstalled  in  the tanks.   The
 tanks have 2 inches  (5   cm)  of insulation which helps
 buffer ambient temperature effects.   A nutrient  solution
 is metered  in from mixing  tanks  in  the pump house  to
 obtain the  following concentrations  in the  aeration tanks.
300.70(b(2)(ii)
      e
biological
reactors
                                      4-31
-------
                      Figure  9:   Above-Ground Biological Treatment System  Design
                                         (Blocraft Laboratories. 1983)
 I
U)
NJ
-------
     Nutrient  Salt    Concentration (mg/1)
         MgS04
         Na2S0

         CaCl
         FeSO,
500

270
410

 14
  9
  0.9
  1.8

  0.45
     The system is presently operating  at  an  average flow
rate of  9.5  gallons  (36  1) per  minute with  a  retention
time in the aeration  tank  of 17.5 hours.   The system has
the capability to handle a flow of up to 14 gallons (53 1)
per minute  or 20,000  gallons  (76,000  1)  per day  with  a
retention time  of  12  hours,  but the  pumping wells  are
presently at capacity flow.

     Effluent  air  from  the  aeration  tanks  is  passed
through replaceable  activated  carbon adsorbers  to remove
any volatilized organics.  The amount of volatilization is
not believed to be  substantial, based  on indications from
pilot plant studies and the fact  that the carbon adsorbers
have not yet  required  replacement in over  1  1/2 years of
operation.

     The effluent  stream from the aeration  tanks  is com-
bined  and  pumped  to  two sludge  settling tanks  in which
some biomass  solids are settled  out and  recycled to the
aeration tanks.   The supernatant  from  the settling tanks
is  pumped  to the  reinjection  trenches.   Much  of  the
biomass is  allowed to pass with  the supernatant  into the
recharge  trenches  in  order  to continually  inoculate the
trench  and  subsurface with microorganisms.   Waste  sludge
production  is minimal,  at  approximately 11 gallons  (42 1)
per month because  of  (1)  sludge recycling to  the  aeration
tanks  and  reinjection  trenches,  and (2)  low cell  repro-
duction  rates   associated   with   the  biodegradation  of
relatively refractory organics.

     Process  influent  and  effluent   concentrations  are
given  for  1  1/2  years of  operation in  Table  8.   The
                                      4-33
-------
                                            TABLE  8.   BIOLOGICAL  TREATMENT
                                         ORGANIC  INFLUENT  & ORGANIC EFFLUENT
                                             (mg.  per  liter unless  noted)
I
Lo
                                                                                         (continued)
-------
                                           TABLE 8.   (continued)
INFLUENT
Date
9/16- 9/30
10/ 1- 10/15
10/16- 10/31
ll/ 1- 11/15
Average
I PA
ND
ND
ND
ND.
52
MeCl2
151
170
165
142
98
Acetone
51
63
67
57
47
BuOH
42
71
55
43
43
DMA
6
13
10
9
23
EFFLUENT
I PA
ND
ND
ND
ND
<1
MeCl2
4
5
6
7
<2.2
Acetone
7
5
5
2
<5.6
BuOH
ND*
ND*
ND* 1
ND*
<1.4
DMA
ND
3
5
4
<8.3
I
UJ
Ui
        *mcg  per  liter


        ND  -  Not  Detected.   Detection limit 1 nig. per  liter


        ND* - Not Detected.   Detection limit 10 meg. per liter
       NA  -  Not  analyzed
-------
 average removal efficiency  for  contaminants  in Biocraft's
 ground water is given below.

      Substance                    Removal Efficiency (%)

      Isopropyl Alcohol (iPA)             >98

      Methylene Chloride (MeCl-)           >98

      Acetone                             >88

      Butyl  Alcohol (BuOH)                 >97

      Dimethyl  aniline (DMA)                64

      —Reinjection Trenches
      Effluent  from  the  biological treatment  plant  is
 reinjected  in  two recharge trenches located at  the  ground
 water mound to flush the soil and subsurface with  treated
 water,  in order to remove  residual contaminants.

      The two injection trenches  (B and  C  in Figure  7)  were
 excavated  with  a backhoe.   Wooden  shoring was  used  to
 support the  trench walls until gravel and backfill were  in
 place.   The dimensions of  each  trench  are approximately
 100 feet (30 m)  long,  4 feet  (1 m) wide,  and 10  feet (3  m)
 deep.   The  trenches are lined on the  bottom,  ends, back,
 and top with a  15 mil (0.025 mm) plastic liner, so  that
 injected water  is  allowed  to  exit from  only the  front  side
 of  the trench.   The  bottom section  of the  liner was
 covered with a  3  inch (7.6  cm)   sand  layer and then  hand
 filled  with  2  inch (  5 cm) washed stone  to a thickness  of
 5  feet (1.5 m).   Piping  consists  of  a  2  inch  (5 cm)
 vertical inlet pipe ending  in a "Y" connection.   Two  20
 foot  (6m) sections  of  2-inch   (5  cm) slotted pipe  were
mounted to  the "Y".    The  trench  was  then backfilled  with
 2  inch (5  cm)   washed  stone  to the surface.   A four  foot
 (1.2 m) high manhole  was  installed  over the recharge  pipe
 for access.  A four  foot  (1.2 m) high  soil mound was  then
placed  over the  top  liner  to  insulate   the  trench  from
 freezing.    Each  trench has  two  monitoring wells,  one  on
each end of  the  trench.  These wells  can  also  be used for
flushing the system  of sludge accumulation  if required.
Trench  design   is  shown in  Figure  10.   Average  flow  if
effluent  to the  two   trenches  is  about  13,680  gallons
 (51,780 d)  per day.

     Air is  injected  into  the recharge line,  as effluent
flows  from  the  treatment plant to the  trench,  using a jet
eductor or  compressed air when flow rate  is low.

    Aeration of the reinjected effluent has the effect of
creating a  biological   trickling   filter in the  trench  to
                                     4-36
-------
   Figure  10:   Configuration  of  Reinjection Trenches
p; »H  JlfW
(Biocraft Laboratories, 1983)




                  • -,•** J (•«" "**•"
                                                                      • SIDE sME«M
 Mole: Tiealml walei axils only from one (Ida ol (he Irench,
-------
 further  increase biodegradation  of organics.   The  water
 level  in  the  trench is kept at surface elevation  in  order
 to  flush  contaminants  in  the  shallow soil  layers.

     Excavated   soil   from the   trenches   was  placed   on
 plastic  sheeting in a  2  to 3 foot  (0.6-1  m)  layer  about
 100 feet  long and 16  feet  wide.   The soil  layer is exposed
 to   the   atmosphere   to    induce   natural   aeration   and
 biodegradation  of contaminants in the  soil.

     —In-situ  Aeration Wells
     A series  of nine continuous aeration  wells  were
 ins tailed  in  the  subsurface  along  the  major  path   of
 contaminant  plume movement as  shown  in  Figure 11.    The
 configuration of the wells is  shown in Figure  12.   Air  is
 injected  into each well at  a pressure  of 4  to 9 pounds  per
 square inch (PSl).    The   addition  of air  to these  wells
 creates a zone  of  subsurface  aeration where contaminated
 groundwater  passing    near   the   wells   is   aerobically
 biodegraded.  The nine  wells  are  spaced about 30  feet   (9
 m)  away from each other and are  arranged in a  rectangular
 matrix about 30 feet  (9 m)  wide  and 100 feet (30 m)  long.
 The  arrangement  of  the wells  was designed  assuming  a   15
 foot  radius of  influence.   Residence  time through  the
 intended  aerated zone  was  calculated  using  an  average
 ground water  velocity of 0.4  feet  (0.1  m) per  day.
 Residence time  ranges  from 65 to 300 days,  depending  on
 the  direction  of ground  water  flow  through the  aerated
 zone. Ground water  temperature  is 54 °F  (12°C)  which  pro-
vides adequate temperature conditions  for biodegradation.

     In addition, two of the monitoring  wells,  numbers  4a
 and 9, are presently being aerated.
COST AND FUNDING

Source of Funding

     All project costs were paid by Biocraft Laboratories,    300.68(c)
Inc.                                                          responsible
                                                              party funding
Selection of Contractors

     Generally,   contractors   were   selected  based   on
qualifications.  A high level of  expertise  was  needed  for
all project work because the process  was  new and  required
innovation.  Formal competitive bidding was  not used,  but
Biocraft found that its contractors were within a competi-
tive price  range.   Geraghty and Miller,  Inc.   (G&M)  of
Syosset, NY was  chosen as  the  hydrogeological  consultant
                                     4-38
-------
Figure  11:   Location  of In-Situ  Aeration Wells
                (Geraghty and Miller, 1979)
                          4-39
-------
 Fi.orure  12:   Air  Well Construction





	(Biocraft Laboratories, 1983)
                       4-40
-------
  based on  three  factors  G&M was  recommended  by Biocraft's
  initial consultant, Princeton Aqua  Science;  G&M was among
  those referred to Biocraft by NJDEP, and G&M had written a
  frequently used hydrogeology textbook.   The  C&R Construc-
  tion Company  of  Westwood, NJ  has done  construction work
  for Biocraft since about 1970.   Biocraft chose C&R because
  it believed that  C&R's  ability to follow plans,  its good
  business  dealings,   and  its   especially  high  level  of
  competence with concrete construction would  be  useful for
  this work.  The L&L Chemical Construction  and  Engineering
  Company, Inc.  of  East  Rutherford, NJ was  also chosen  by
  Biocraft based on past  satisfactory  work.   In  1971,  when
  the original  Biocraft  plant was built  in Waldwick,  L&L
  helped   refine  the plans,  and   thus  showed  its  trouble-
  shooting ability,  which  Biocraft  considered useful for the
  biostimulation work.

  Project  Costs

  Biostimulation Project Cost Overview
      The total cost of  research and development (R&D) and
  capital  design  and  construction  of the  biostimulation
 operation  at Biocraft was about  $926,000.  About  half of
  this cost  ($446,280) was  for in-house process development
 including  a  pilot  plant.   Virtually  all of  this  process
 development cost was a one-time only expense.   The general
 cost  categories   for   R&D,   and   capital  design  and
 construction,  which  are  discussed below  and  tallied  in
 Table 9  are as  follows:

      •  Hydrogeological  Study -  Problem Definition

      •  In-house Process  Development

      •  Ground  Water Collection/Reinjection System
      •  Biostimulation Plant

      These costs include expenditures contributing  to the
 biostimulation  project from 1975  through March  13,  1982.
 In-house  research,  planning, management  and  overhead  are
 included  as  estimates by  Biocraft  officials  to   within
 about  10% of  expected  actual cost  range.

      Cost for  legal  services  and repair of  the  leaking
 underground  waste   storage  tansk  are  not included.    All
 information  is  based on  actual  goods and  services  costs
 between  1975-1982  drawn  from invoices  and from  estimates
by   the   plant  manager,   the  plant  engineer,   and   the
 fermentation director, and not on  current market  value.
                                     4-41
-------
            TABLE 9. SUMMARY OF PROJECT COSTS-  BIOCRAFT LABORATORIES,  WALDWICK, N.J,
Task
A. HydroR<;olnp,lcal Study-problem definition
H. In-house Process Development (R&D)
C. Ground Water collection/Injection system total
1) Uustgn
2) Installation
D. BiostJmulfit ton plant Oesip.n and Construction total
1) Engineering Design
2) Mnsonnry Construct ton
3) Equipment nncl Miscellaneous Installation
CAl'ITAI. AND KM) TOTAL
E. Operation & Maintenance (O&M)
1) ULllltlCH
1) Electricity 26.4 kw(24 hours/day)
il) Steam 72 pounds (32kg) /day @ 90PSI
2) Maintenance sec text
3) WutrJent Salts see Table 15
Total Water treated - 13,680 gallons (51,779 l)/day
Actual Expenditure
$73,9/18
$446,280
$184,243
($61,490)
($122,753)
$221,207
($58,400)
($73,975)
($88,812)
$926,158

$47. 40 /day
($46,82/day)
(58(f/day)
$159.93/day
$19.20/
-------
Hydrogeological Study - Problem Definition
     The   total  cost   for  the   initial  ground  water
assessment study was about  $74,000,  as  shown  in Tables 9
and 10.
            300.66(c)(2)
            assessment
TABLE.  10.   INITIAL  GROUND WATER  ASSESSMENT  STUDY  COST
             BIOCRAFT LABORATORIES, INC., N.J.
     Monitoring wells and test borings     $ 6,874

     Laboratory testing                    $27,704
     Environmental and hydrogeological
       consulting                          $39,370

                                   Total   $73,948
     Independent   and   in-house  testing   cost  $27,704
(in-house:  400 hours @ $50/hour).  The sum of $39,370  for
environmental and hydrogeological consulting work included
200 hours  of  Biocraft employees' time  spent  working with
consultants.

In-house Process Development Cost
     The  total  cost  for  research  and development  of  the
biostimulation  process  and  construction  of  the  pilot
platitwas  about  $446,280.    This cost  includes  in-house
labor, equipment, and quality  control laboratory overhead
as shown Tables 9 and 11.

    TABLE 11.  IN-HOUSE PROCESS DEVELOPMENT - BIOCRAFT
  	LABORATORIES INC., WALDWTCK, N.J.
     Labor

     Equipment

     Quality control lab
                          Total
$296,280

$100,000

$ 50,000

$446,280
The cost  for  building construction,  installation,  piping
and  pumps  for   the  pilot  plant   was   about  $40,000.
Laboratory work occurred from December 1978 to March 1980,
followed  by operation  of  the  2.7  gallon  (10.2  l)/hour
            300.68(f)
            survey and
            monitoring
                                     4-43
-------
 pilot scale testing from March 1980 until June  1981,  when
 full  scale  plant  operation began.

 Ground Water Collection/Reinjection System
      The  total  cost for the design and construction of the
 ground water  collection/reinjection system,  including the
 air  injection system,  was  about $184,00 as  shown in Tables
 9  and 12.   The  in-house  labor  costs of $26,400 includes
 the  plant manager  and  director of fermentation  (each  200
 hours @  $50/hour)  and  the plant  engineer  (160 hours  @
 $40/hour).

      The  system  was  installed  primarily during  November
 1980  and  was substantially completed by March 1981.  Most
 of the installation work for the ground  water collection/
 injection  system was  done  by C&R  Construction  Company,
 Inc.,  and cost about  $122,753, including construction  of
 trenches  A,  B, and C;  air well  construction and  project
 supervision.   Two major cost elements of the construction
 of trenches  A,  B  and C were:   (1) -$7,490 for extra labor
 and  equipment  (including  a backhoe/frontloader)  and  162
 tons  (147 Mt)  of  3  to 4 inch (7 to  10 cm)  stone; and  (2)
 $12,278 for  the 3/4 inch (2 cm) plywood sheeting  and labor
 necessary  to shore up  the trenches  during construction.
 The digging  of  bucket  well  #30 (ZO feet  x 4  feet 16 feet
 (3 m  x 1 m x 5 m))  and  filling  it witht stone cost $2,586.
 The  construction  cost  for  the  nine  air  injection wells
 included  $5,850  for nine,   6  foot  (2  m)  deep cinderblock
 and cement manholes; and $5,400 for digging the 320 linear
 foot  (98 m)  trench  across  the  asphalt  parking lot for the
 air line.   The  added expense  for  the  access  manholes was
 later  determined  to be unnecessary by the  plant manager,
 because surface  injection  would have  been  adequate.   The
 $4,500 for clearing of  trees and land  for construction was
 one   of   several  secondary   costs   involved    in   the
 installation work.

 Biostimulation Plant Design and Construction
     The total cost for the design and construction of the
 biostimulation  process  plant  was  about  $221,000  (see
 Tables 9 and 13).

     The  sum of  $58,400 for engineering design  of  the
 final system included in-house  costs of 160 hours for the
 plant manager and 200 hours  for the  director  of  fermenta-
 tion, both  at  $50/hour.  About 960 hours of engineering
 time  was  used, at  $40/hour.   Most  of  the  design work
occurred  during  1980   and  construction  occurred  during
early 1981.  The  system went  on-line  in  June 1981.   Most
of the contracted  engineering and construction work on the
 300.70(b)(iii)
 (c)
 ground water
 pumping
300.70(b)(2)(ii)
biological
reactors
                                     4-44
-------
	TABLE  12.   GROUND  WATER COLLECTION/REIWJECTIOM  SYSTEM

A.   Design

     1.   Laboratory  testing                          $10,418

     2.   Labor

         a.  Hydrogeology
             consultants                            $24,673

         b.  Biocraft  (in-house)                     $26,400

                                  Subtotal           $61,490

B.   Installation

     Air  and monitoring well points                  $12,740

     Trench, air well  construction
      and miscellaneous site work                  $80,500

     Hydrogeologist supervisor                       $21,513

     Engineering                                     80,000


                                  Subtotal         $122,753


                      Total                       $184,243
                                 4-45
-------
TABLE 13.  BIOSTIMULATION PLANT DESIGN AND CONSTRUCTION
           BIOCRAFT LABORATORIES, INC. WALDWICK, R.J.
A. Engineering Design
Biocraf t , in-house
Engineer
Draftsman/ Blueprints
Subtotal
B. Masonry and Construction
Masons
Piping
Electricians
In-house maintenance and
engineering
Subtotal
C. Equipment & Miscellaneous Installations
Tank trailers with modifications
Duct (includes installation)
Rotameters , rollers , pipe , tanks
Ceramic diffusers (air spargers)
Threading diffuser
Pipe, valves, etc.
Temperature Recorders
Compressor
Pumps
PCV liner
Gauges (0-5 PSl)
Metering Pumps
Charcoal
Miscellaneous
Subtotal
Total Process Plant Design and Construction

$ 18,000
$ 38,400
$ 2,000
$ 58,400

$ 14,500
$ 27,800
$ 16,675

$ 12,000
$ 73,975
$ 28,560
$ 8,000
$ 9,000
$ 6,000
$ 3,000
$ 15,000
$ 1,500
$ 4,954
$ 2,500
$ 1,500
$ 1,000
$ 3,000
$ 1,318
$ 2,000
$ 88,832
$221,207

                         4-46
-------
      Biostimulation plant was  performed  by L&L  Chemical
Construction and  Engineering,  Inc.    S^"""1.1"/ "£
for  the process  plant  was  done  by  C&R  such  as  the
construction of the  catwalk and stairs, and railroad tie
support piles for the activation and  settling tanks, which
totalled $2,874.

     The masonry  and construction work  listed  in  Table  13
generally  includes  above-ground work  such  as pump house
construction,  tank  installation and plumbing, and trench
connections.  The construction of the new pump house shell
by  C&R cost $4850.   Biocraft  provided 200  hours  of  both
maintenance  and engineering labor at  §35  and $40 per  hour
respectively.

      The largest single cost  atnong  the  equipment  and
miscellaneous  installations listed  in Table 13 is; $28 560
 for  the  four  5,400 gallon  (20,000 1) used milk  tank
 trailers used  for the activation and  settling  tanks.  This
 cost includes  delivery, set-up, and modifications such as
 a vent on  the tnanhole,  installation  of a  rear  outlet 3
 inch (8 cm)  butterfly valve,  a 2 inch (5 cm) valve in_the
 belly, and several 2 inch  (5 cm)  nipples  for  various
 sampling,  feed, filter and effluent lines,  and 1  1/2 inch
 (4 cm) steam nipples.

      The used milk  tank  trailers have 2 inches  (5 cm) of
 insulation, which helps buffer ambient te"Pcrf?urcrfteqfrfe""
 on  the maintenance  of the 20°C  process.    The  cost  per
 modified  tank  trailer  was   about  $6,250.    The  plan
 engineer  and  manager  have  subsequently determined  that
 lined  standard  carbon  steel  tankers^ would  have  been much
 less  expensive,  even with  the  additional estimated $4,000
 cost  for  lining,  which would have been  necessary to make
 them suitable  for this use.

       The  cost  for  secondary  elements,  such as the ceramic
  air spargers   and  vent  carbon  adsorbers was affected  by
  innovative  specifications.    The  cost  of  threading  the
  ceramic  diffusers  was  necessary  because  the   difrusers
  could only be  purchased in 2  foot  (0.6  m)  lengths,  and
  needed to be connected  to form tank-long  air spargers in
  the activation tanks,  A specially designed roller-support
  apparatus was constructed to allow the air-spargers  to be
  rolled out for maintenance  to eliminate clogs.   Ihis
  system was intended to  obviate  the cost  and  risk of
  sending a maintenance technician into the  tanks  to remove
  the biomass buildup on the air-spargers.   This maintenance
  cleaning has  not yet  been  needed.   The  four  carbon
  adsorbers  mounted  on  the  tanks  to  prevent  volatilized
  solvent emissions, were constructed  from used,  retrofitted
  drums and  $750 worth of  charcoal.    The  $1,318  charcoal

                                       4-47
-------
  cost  in Table  13  also provided  enough charcoal  for one
  annual replacement.  Wooden pallets were used to construct
  an  inexpensive saddle for  mounting  the  drums.   This
  innovation obviated the need  for purchasing  for commercial
  vent carbon adsorbers  for $1,960.

  Operation and Maintenance Costs
      The operation and maintenance  (O&M)  costs  are listed
  in  Table  14, and  are separated  into  utility,  and main-
  tenance labor and  overhead.   The largest  utility  cost of
  the system is $46.82/day  for 26.4 kwh  of  electricity (55
 Amps @ 480 Volts)  at   7.39f?/kwh, based  on  the  latest  1983
 "Large  Power   and   Lighting  Service"   industrial  rate
 schedule.   The 58<
-------
                    TABLE 14.   OPERATION & MAINTENANCE COST
                     BIOCRAFT  LABORATORIES, WALDWICK,  N.J.
I.  Utilities

     A.  Electricity 26.4 kw x 7.39 £/kwh x 24 hrs/day     $46.82/day

     B.  Process steam 72 Ibs/day @ 90 PSI x 0.8 ^/lb       58 i/day


II.  A   Nutrient Salts                                    $19.20/day


III. Maintenance Labor and Overhead

     A.  Quality control lab & technician A                $24.40/day

     B.  Fermentation lab and technicians                  $97.10/day

     C.  Maintenance                                       $20.26/day

     D.  Supervision                                       $17.14/day

                                       Total O&M           $226.53

$226.53-13,680 gallons (51,779 I/day treated = $0.0165/gallon ($0.0044)
                                 4-49
-------
TABLE 15.  NUTRIENT SALT COST - BIOCRAFT LABORATORIES, WALDWICK, NJ
Nutrient*
Ammonium chloride
Potassium phosphate
(monobasic)
Potassium phosphate
(dibasic)
Magnesium sulfate
Sodium carbonate
(soda ash)
Calcium chloride
Manganese sulfate
Ferrous sulfate
*USP or food grade
Amount Used (Pounds/day)
34.6 (15.7 kg)
19.0 (8.6 kg)
28.4 (12.9 kg)
2.0 (0.9 kg)
0.6 (0.29 kg)
0.06 (0.029 kg)
0.13 (0.06 kg)
0.03 (0.014 kg)
Total daily cost
Daily Cost
$5.63
$5.25
$7.50
$0.36
$0.05
$0.40
$0.01
$0.0005
$19.20
                                4-50
-------
 PERFORMANCE EVALUATION

 Groundwater Decontamination

      The   biostimulation  process   implemented   at   the
 Biocraft site  is  generally reducing  pollutant  concentra-
 tions in the groundwater beneath  the  property.   Data from
 different  monitoring   wells   show   that   the   removal
 efficiency has  been  somewhat variable.   Figure  13  shows
 the  location   of  presently  existing  on-site  monitoring
 wells.  Tables  16  through  20  give chemical  analysis  of
 groundwater for selected pumping and monitoring  wells from
 July, 1981  to December 1982.   Pumping  well #13 in the main
 collection  trench has shown a dramatic decrease  in pollu-
 tants  during  the 18  month  period  of  operation,  with
 concentrations   of methylene  chloride in the  parts  per
 billion (ppb)  range.   Pumping  well #30  which  intercepts
 the southern component of  contaminant  flow,  is  showing  a
 significant  decrease   in   COD,   dimethyl  aniline,   and
 isopropyl   alcohol and  reduced  but   varying  levels  of
 methylene  chloride,  acetone,  and butanol.  It is  believed
 that   pockets   of   gross  contamination  are   still  being
 collected  by this well.  Contaminant  levels are  expected
 to  stabilize and  reduce  as pumping continues.   Wells  4A
 and 31  in  the  southwestern  corner  of the  property  show
 dramatically reduced  levels of contamination presently  in
 the ppb  range.   Wells 1 and 2 along the  northern  property
 boundary, and wells  11  and  12 in the extreme eastern  side
 of  the  property show  relatively  low  concentrations  of  COD.

      Some of this  amount may be  attributable to humic  sub-
 stances.     However,   residual   contaminants   are   also
 suspected to be present  and contributing  to the COD level.
 Because  of  the  hydrogeology of the area,  low level  contam-
 inated  ground water in  property  line wells is not believed
 to  be in the area of  influence  of  the collection  trench
 and pumping wells and  is  expected  to  migrate  offsite.
 These  levels are relatively low  and  residual contamination
 will be  gradually  diluted with time.  Contamination of the
 municipal  deep   well  by  these  contaminants  is   a  remote
 possibility, since any downward migrating substances would
 probably be  adsorbed  by clay and  silt  particles  at these
 levels.

 Groundwater Collection System

     The design of the groundwater  collection  trench and
 pumping  wells   is  generally adequate.    The advantage to
 using collection wells  is  that if a pocket  of contamina-
 tion  was discovered  a pumping well  can be installed
 quickly  and  economically.   Monitoring  wells  can  also be
pumped if required, but  the collection  of ground  water is

                                     4-51
-------
                                            Figure  13:   Well  Location Map
                                                (Source:  Btocraft  Laboratories, 1983)
 I
Ui
                        . tM  IflEHCH MOWTOfllMO WElt


                        • n>  PUMP1MO WELL
-------
           TABLE  16.   LEVEL OF ORGANIC CONTAMINANTS  PUMPING WELL #13
                      (Biocraft Laboratories,  1983)
                             July 1981 - Dec.  1982

Date
1981
July 1-15
July_ 16-31
Aug. 1-15
Aug. 16-31
Sept. 1-15
Sept. 16-30
Oct. 1-15
Oct. 16-31
Nov. 1-15
Nov. 16-30
Dec. 1-15
Dec. 16-31
1982
Jan. 1-15
Jan. 16-31
Feb. 1-14
Feb. 15-28
Mar. 1-15
Mar. 16-30
Apr. 1-15
Apr. 16-30
May 1-15
May 16-31
June 1-15
June 16-30
July 1-15
July 16-31
Aug. 1-15
Aug. 16-30
Sept. 1-15
Sept. 16-30
Oct. 1-15
Oct. 16-31
Nov. 1-15
Nov. 16-30
Dec. 1-15
MeCl2
175
88
-
38
-
-
64
-
5
3
1
1
23
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
7*
11*
53*
8*
33*
115*
32*
9*
8*
Acetone
64
62
—
34
-
-
57
-
3
2
1
1
14
11
17
8
4
3
3
2
2
3
ND
ND
ND
1
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND:  Not detected.  Detection limit 1 rag. per liter
*mcg. per liter.  Detection limit 8 meg. per liter
All other values mg/1
NA:  Not analyzed
                               4-53
-------
        TABLE 17.  LEVEL OF ORGANIC CONTAMINANTS AND COD PUMPING WELL #30
                   (Biocraft Laboratories, 1983)
                             July 1981 - Dec. 1982*
Date
1981
July 24-31
Aug. 1-15
Aug. 16-31
Sept. 1-15
Sept. 16-30
Oct. 1-15
Oct. 16-31
Nov. 1-15
Nov. 16-30
Dec. 1-15
Dec. 16-31
1982
Jan. 1-15
Jan. 16-31
Feb. 1-15
Feb. 16-28
Mar. 1-15
Mar. 16-31
Apr. 1-15
Apr. 16-30
May 1-15
May 16-31
June 1-15
June 16-30
July 1-15
July 16-31
Aug. 1-15
Aug. 16-30
Sept. 1-15
Sept. 16-30
Oct. 1-15
Oct. 16-30
Nov. 1-15
Nov. 16-30
Dec. 1-15
MeCl2
98
77
86
68
67
123
106
64
72
37
62
115
162
68
144
107
85
49
46
62
26
38
37
27
41
76
99
120
104
132
105
118
34
41
Acetone
86
67
77
67
51
108
96
55
42
21
23
39
'44
18
58
34
36
24
19
26
7
16
18
12
17
23
29
35
32
44
55
54
19
24
BuOH
27
28
50
43
33
82
73
52
36 j
17
16
24
33
14
46
28
31
19
15
21
4
10
8
4
8
16
20
25
25
43
42
46
12
13
DMA
145
137
87
73
36
48
38
21
21
10
10
11
16
8
14
11
10
4
2
6
4
5
4
2
2
4 ,
6
10
2
8
6
7
1
ND
IPA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
15
21
7
13
10
12
11
10
18
5
10
18
8
9
20
ND
ND
ND
ND
ND
ND
ND
ND
COD
1418
1300
1250
1009
1109
1505
1432
870
958
640
582
650
815
436
838
602
596
543
461
580
518
330
433
361
461
569
648
713
729
572
743
761
290
420
TSS
330
626
481
615
526
558
487
427
415
586
278
266
342
170
173
217
210
129
206
241
161
159
176
139
177
243
257
293
219
246
262
228
152
166
NA:

ND:
*
Data not available.  Starting Jan. 1982 IPA was determined
Previous levels were recorded with methylene chloride.
Not detected.  Detection limit 1 mg/liter.
All values mg/1.
                                   4-54
-------
                 TABLE  18.   LEVEL  OF  ORGANIC  CONTAMINANTS,  WELL  4A
                            (Biocraft Laboratories,  1983)

                              JULY 1981  - OCT.  1982
Date
1981
July 1-15
July 16-31
Aug. 1-15
Aug. 16-31
Sept. 1-15
Sept. 16-30
Oct. 1-15
Oct. 16-31
Nov. 1-15
Nov. 16-30
Dec. 1-15
Dec. 16-31
1982
Jan. 1-15
Jan. 16-31
Feb. 1-14
Feb. 15-28
Mar. 1-15
Mar. 16-30
Apr. 1-15
Apr. 16-30
May 1-15
May 16-31
June 1-15
June 16-30
July 1-15
July 16-31
Aug. 1-15
Aug. 16-31
Sept. 1-15
Sept. 16-30
Oct. 1-15
Oct. 16-31
Nov. 1-15
MeCl2
67

45
35
8
ND
ND
ND
ND
ND
ND
ND
ND
ND
1
10
ND
ND
ND
ND
ND
ND
0
ND

ND
20*
11*
8*
8*
8*
ND*
20*
Acetone
67

80
78
26
ND
ND
ND
ND
ND
1
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1
ND

ND
ND
NA
NA
NA
132*
NA
NA
BuOH
ND

ND
ND
ND
ND
ND
ND
ND
ND
1
ND
ND
ND
1
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
NA
NA
NA
110*
NA
NA
DMA
23

74
65
26
2
ND
ND
ND
ND
ND
ND
ND
ND
1
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
NA
NA
NA
NA
NA
NA
     Not analyzed
ND:  Not detected.  Detection limit 1 mg per liter
*mcg/liter, all other values mg/1
ND*  Not detected.  Detection limit 8 meg per liter
                                  4-55
-------
              TABLE  19.  LEVEL OF ORGANIC CONTAMINANTS, WELL  31
                         (Biocraft Laboratories,  1983)
                            JULY 1981  - DEC.  1982
Date
1981
July 1-15
July 16-31
Aug. 1-15
Aug. 16-31
Sept. 1-15
Sept. 16-30
Oct. 1-15
Oct. 16-31
Nov. 1-15
Nov. 16-30
Dec. 1-15
Dec. 16-31
1982
Jan. 1-15
Jan. 16-31
Feb. 1-14
Feb. 15-28
Mar. 1-15
Mar. 16-31
Apr. 1-15
Apr. 16-30
May 1-15
May 16-31
June 1-15
June 16-30
July 1-15
July 16-31
Aug. 1-15
Aug. 16-31
Sept. 1-15
Sept. 16-30
Oct. 1-15
Oct. 16-31
Nov. 1-15
Nov. 16-30
Dec. 1-15
MeCl2
2
ND
ND
ND
4
34
74
78
53
45
28
23
ND
ND
50
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
Acetone
6
6
ND
1
14
25
57
81
68
59
34
24
44
26
63
44
39
63
57
28
21
23
4
12
12
ND
ND


NA
NA
NA
NA
NA
NA
BuOH
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
19
ND
ND
ND
ND
ND
ND
10
ND
ND
ND
ND
ND


NA
NA
NA
NA
NA
NA
DMA
ND
ND
ND
1
1
3
16
10
4
1
1
1
1
13
2
1
2
1
1
ND
ND
ND
ND
ND
ND
ND
ND


NA
NA
NA
NA
NA
NA
ND:  Not detected.  Detection limit 1 mg per liter
ND*: Not detected.  Detection limit 8 meg per liter
*A11 values mg/1 unless noted
                                  4-56
-------
    TABLE 20.  CHEMICAL OXYGEN DEMAND OF MONITORING WELLS  JULY  1981-DEC.  1982
                           (Biocraft Laboratories,  1983)
Date
1981
July_ 	 1-15
July 16-31
Aug. 1-15
Aug. 16-31
Sept. 1-15
Sept. 16-30
Oct. 1-15
Oct. 16-31
Nov. 1-15
Nov. 16-30
Dec. 1-15
Dec. 16-31
1982
Jan. 1-15
Jan. 15-31
Feb. 1-15
Feb. 16-28
Mar. 1-15
Mar. 16-30
Apr. 1-15
Apr. 16-30
May 1-15
May 16-31
June 1-15
June 16-30
July 1-15
July 16-31
Aug. 1-15
Aug. 16-30
Sept. 1-15
Sept. 16-30
Oct. 1-15
Oct. 16-31
Nov. 1-15
Nov. 16-30
Dec. 1-15
WELL #1
NA
NA
NA
NA
35
6
NA
NA
NA
NA
NA
NA
8
8
21
0
NA
50
12
NA
10
40
35
NA
125
ND
NA
NA
NA
NA
NA
NA
10
45
NA
WELL #2
NA
NA
NA
NA
NA
302
88
NA
NA
NA
NA
NA
50
18
22
2
NA
25
9
NA
30
30
40
NA
9
ND
NA
NA
NA
NA
NA
NA
NA
10
0
WELL #11
62
NA
81
35
47
17
70
69
37
NA
NA
57
NA
NA
65
34
25
NA
17
NA
20
70
40
NA
NA
9
20
7
13
13
17
5
13
22
NA
WELL #12
73
NA
77
NA
107
57
NA
76
33
NA
NA
NA
NA
NA
34
20
NA
NA
21
NA
NA
33
40
NA
NA
29
48
6
12
16
24
44
32
24
NA
NA - Not analyzed
*    All values in mg/1
                                   4-57
-------
primarily a matter of well location.  Since the biological
treatment system is capable of economically handling up to
20,000  gallons  (76,000  1)  per day,  any  additional  flow
would not be a treatment capacity problem.

     The  design  of  the  collection  trench  envelope  is
unconventional for dual media designs.  Usually there is a
much greater  thickness of fine aggregate  and  just  a thin
layer  of  coarse  aggregate  around the  collection  pipe.
Biocraft's design is opposite.  This design may eventually
result  in  sediment buildup  in the collection  line which
could require flushing.

Biological Treatment Plant

     The  biological  treatment  plant had  extremely  high
removal efficiencies  (greater than  98 percent) for all but
one  substance.   The  sludge  generation  rate  is extremely
low  for a biological  process.   Volatization of organics
does  not  seem to  be  a significant factor in contaminant
removal,  however,  Biocraft  has  recently implemented  a
testing program to  investigate this.

Injection  Trenches

     There is some  degree  of hydraulic backflow behind the
injection  trenches, even with the plastic  liner. _Pumping
wells  30 and 32  are  probably pumping  some of this back-
flow.   In lieu of  the liner,  a partial cutoff wall could
have been installed which may have offered improved  con-
tainment   of  the  backflow.    The  additional  expense of
installing such a wall, which would  probably be over 300
feet (90 m)  long,  would be substantial.   Grouting or sheet
piling would probably be unfeasible because of the  glacial
till  geology.    A  slurry  wall  or  other  excavated  and
installed  barrier  would be more  appropriate.   If a  steeper
hydraulic  gradient were  present  at the site, very little
backflow would be  expected  from the  liner system.   It  is
also recommended  that geotextile fabric  be used to  protect
 the liner  from puncturing  during  gravel  fill  operations
 and rock projections  in the  trench wall.

      In terms  of  construction,  Biocraft  has  experienced
minor difficulties with the present  design of the  system.
The aeration well  manholes  were allowing  ground water  to
 seep  into  the  installation  and  had  to  be  grouted.
 Biocraft  now  recommends  that   an  access  manhole  is
 unnecessary  and   troublesome,  and will  eliminate it  in
 future designs.
                                      4-58
-------
In-Situ Aeration Wells

     The aeration wells  are  an interesting innovation but
because  of  lack  of  testing,  their  actual effectiveness
remains unclear.  The  placement  of wells on 30 foot (9 m)
centers  was based  on  an assumed  aeration radius  of 15
feet.   No testing has  been  performed  to  investigate the
radius  of aerations,  and so  it  is  as yet  difficult to
determine  if the  zone of aeration  is  continuous.   If the
zone of  aeration  is  not continuous, the residence time of
65 to 300 days through the well bank does not apply.   In a
non-continuous aeration  zone situation, it is more useful
to assess  biodegradability  in terms  of dissolved oxygen.
If it is assumed that groundwater coming into contact with
an  aeration well  will  become  saturated  with  dissolved
oxygen,  the  average  removal  of organics by biodegradation
will range  from  3 to 4 mg/1.   This suggests  that if the
well matrix  produces  a  non-continuous  aeration  zone, it
will be relatively ineffective with high groundwater con-
taminant levels,  but may be very  effective with  residual
organic concentrations of less than 5 mg/1.
                                    4-59
-------
                                 BIBLIOGRAPHY
Biocraft Laboratories,  Inc.   1975  to  1982.   Memoranda,  correspondence, and
     invoices.  Biocraft Laboratories,  Inc.,  Elmwood Park, N.J.

Bureau of National Affairs, 1982.  Environmental Reporter:  State Water Laws.
     Bureau of National Affairs,  Washington,  B.C.

Chojnowski,  Kathleen,  January,   1983.   Personal   Communication.    U.S.
     Environmental Protection Agency, Region II.  New York, N.Y.

Division of Water Resources.   1975  to  1982.  Administrative Orders, letters,
     memoranda,  and  phone  logs.   New  Jersey  Department  of Environmental
     Protection, Trenton, N.J.

Environmental  Data  and  Information  Service,  1981.    Local  Climatological
     Data-Newark, New Jersey.  National Climatic Center, National Oceanic and
     Atmospheric Administration,  Asheville,  N.C.

General Drafting  Company.   1977.  Road Map  of New Jersey.  General Drafting
     Company, Inc.  Covent Station,  N.J.

Geraghty  and Miller,  Inc.   1978-1982.   Memoranda,  correspondence,  letter
     reports  to Biocraft Laboratories, Inc.   Geraghty and Miller, Inc., Port
     Washington, N.Y.

Geraghty  and  Miller, Inc.   March 16, 1979.   Investigation of  Ground  Water
     Conditions at Biocraft  Laboratory,  Waldwick,  N.J.  Geraghty and Miller,
     Inc., Port Washington, N.Y.

Goldberg,  Alexander.   March  9,  1979.    Letter report to  N.J.  Department  of
     Environmental  Protection, Newark,  N.J.   Passaic  Valley  Sewer ag"e
     Commissioners, Newark, N.J.

ladavaia,  Vincent  A.  February  5,  1979.   Letter  Report  to Northwest Bergen
     County Sewer Authority, Waldwick, N.J.  Havens and Emerson,  Inc., Saddle
     Brook, N.J.

Jhaveri,  Vidyut,  Ph.D.,  November,  1982.    Personal Communications.   Biocraft
     Laboratories, Waldwick, N.J.

Jhaveri, Vidyut, Ph.D.,  and  Alfred  Mazzacca.   February, 1983.   Draft  Report:
     Bioreclamation  of  Contaminated   Groundwater  and  Soils  using  the  CDS
     Process.  Groundwater Decontamination Systems, Inc.,  Waldwick,  N.J.

Lanza,  Vince.    January,  1983.    Personal Communication.    Public  Service
     Electric and Gas Company, Newark,  N.J.

Lee, L.L., J.E. Time, and R.L.  Gillett.   1925.   Soil Survey  of  Bergen  Area,
     New Jersey.  U.S. Soil Conservation Service, Washington, D.C.


                                     4-60
-------
L&L Engineering.   April  1978.   Storage Tank  Pressure  Testing Report.   East
     Rutherford, N.J.

Lynch, Peter, Manager, Passaic-Hackensack  Basin,  Division of Water Resources.
     November,  1982.    Personal  Communication.    New  Jersey Department  of
     Environmental Protection,  Newark, N.J.

Maddox,  Paul.   January,  1983.   Personal  Communication.    Arcal  Chemical
     Company, Silver Spring,  MD.

Mahon,  Joseph.    November,  1982.   Personal  Communication.   Ground  Water
     Decontamination Systems, Inc., Waldwick,  N.J.

Mazzacca, Alfred.    November, 1982.   Personal  Communication.    Biocraft
     Laboratories, Inc.,  Waldwick, N.J.

Murphy,  Ellis,  and McBride,  Esq.   1978  to  1982.   Correspondence.   Murphy
     Ellis, and McBride,  Counsellors  at  Law, Hackensack,  N.J.

Page,  Leo  M.   1981 to 1982.   Correspondence.   Consulting Geologist (Town of
     Waldwick) Basking Ridge, N.J.

Princeton  Aqua  Science.    1976 to  1979.    Letters  and  Reports  to Biocraft
     Laboratories.  Princeton Aqua Science,  Inc.  New Brunswick, N.J.

Public  Service  Electric  and  Gas.   February 14,  1982.   Rate Schedule:   Large
     Power  and  Lighting.  Public Service Electric  and  Gas Company, Newark,
     N.J.

Schnell  Publications.    January  31,   1983.    Chemical  Marketing   Reporter.
     Schnell Publishing Company, New York, N.Y.

Snyder, Harold, President.   November,  1982.   Personal Communications.
     Biocraft  Laboratories,   Inc./Groundwater  Decontamination  Systems,  Inc.
     Waldwick, N.J.

Svokos,  George.    January,  1983.    Personal Communication.    Biocraft
     Laboratories, Inc.,  Waldwick, N.J.

United States Environmental Protection Agency.    1975.   Correspondence  and
     Situation  Reports.    Emergency  Response   and  Inspection Branch, Edison,
     N.J.;  Surveillance  and  Analysis Division,  Edison,  N.J.;  and Region  II,
     New York, NY.

Vecchioli,  John,  and E.G. Miller, 1973.   Water Resources  of  the New Jersey
     Part  of  the Ramapo River Basin.   Geological Survey Paper 1974,  Geological
     Survey, United States Department of the Interior,  Washington, D.C.

William Niesen  Associates,  October,  1981.    Voting  District  and  Community
     Facility Map:    Waldwick,  N.J.   Wiliam  Nieson Associates,  Planning  and
     Design, Ocean, N.J.


                                     4-61
-------
-------
                           CHEMICAL METALS  INDUSTRIES

                              BALTIMORE, MARYLAND
 INTRODUCTION                                                  NCP
                                                              References
     Hazardous  substances  were  stored  in  drums,  con-
 tainers  and  tanks  at this  now bankrupt precious  metal
 reclamation   and   chemical  manufacturing   facility  in
 Baltimore,  Maryland.     Off-site  migration   of  these
 substances  threatened to  contaminate  the nearby Gwynns
 Falls,  a  tributary  of  the  Patapsco  River,  and  the
 presence of strong  acids,  basics and  cyanide presented a
 risk of explosion and release of toxic vapors that could
 threaten  the  health  and   safety of  residents  in  the
 surrounding residential area.

 Background

     Chemical  Metals  Industries  (CMI),  owned  by L &  M
 Associates, Inc., filed for  bankruptcy in August  1981.
 It was  dissolved  by  court  order on August 28,  1981 and
 the  property  placed  in  the hands  of a  court-appointed
 receiver.   For 7 years, CMI  had operated as  a precious
metal reclamation facility  and a manufacturer  of copper
 sulfate.  The site  had been in  commercial use  since the
 1950's, with  one  previous  owner operating a  gas station
 on part of the premises.

     The site was investigated in September  1981 by the
Maryland Office  of Environmental Programs  (OEP) and  by
 the Technical  Assistance  Team  (TAT)  for  the Region III
 office  of  the   U.S.  Environmental   Protection Agency
 (EPA) .   The CMI   f ac i 1 i ty  had  cons is ted  of  two  s ites
 separated   by    a    block   containing   20    occupied
residences.    Site 1,  as it was called in  the  On  Scene
Coordinator's  report*  was  the  location  of  the  old  gas
 station.   It  was enclosed  by an 8 foot  (2.4 m)  cinder
block wall, within  which approximately 1,500 drums  were
found.   The drums were filled in different degrees with
                                      5-1
-------
a  variety  of  chemicals,   including   caustics,   organic
solvents  and  cyanide.     They  were  deteriorated  and
damaged   and   piled   haphazardly   about    the   site.
Apparently this site was used primarily for storage.

     Site  2 was  enclosed  by a  dilapidated  fence  and
contained the metal  reclamation plant  with  its adjoining
yard.  About 50 drums  and containers marked as acids and
oxidizers  were  found  in   the  plant building.    The
laboratory  and  laboratory  storage  area  of the building
contained   small  quantities  of   reagents  along  with
various  labelled  and  unlabelled  rare and  heavy metal
formulators.   In  the yard  were  15 above ground  storage
tanks   containing   varying   amounts   of   liquids  and
crystallized  materials.     The   yard  also  contained
approximately  one  hundred   55-gallon drums   that  were
believed  to contain wastes from  the  metal  reclamation
operation.    Many   of  these  deteriorated  drums  were
leaking  their  contents  onto  the  ground.    Some  were
located near an open storm drain that led  to  the public
sewer system.   A  storage  vault containing  various solid
materials,  including zirconium powder, was  also found  on
Site 2.

     Materials  stored  on  CMI  property  primarily were
wastes  that  had   accumulated  from   two   manufacturing
processes.   One process  involved  production of copper
sulfate   and   copper  hydroxide.     The  other   process
involved  dissolution of trace  amounts  of precious metals
from  waste  chemical   solutions   and  printed   circuit
boards.    For  example,  gold  from  circuit  boards  was
dissolved   in  aqua regia,   a mixture  of  nitric  and
hydrochloric acids  that is  highly  corrosive.   The aqua
regia  was   then  neutralized,  causing  the   metals   to
crystalize  out of the  solution.   It appeared  that Site 2
had been used mainly for these manufacturing processes.

     In October 1981,  EPA concluded that the  site posed
an  emergency  and   authorized  immediate  removal  of  the
waste using CERCLA  funds.

Synopsis  of Site Response

     The  emergency   response at  CMI  took  about  7 weeks
from October  to December,  1981.   Workers  first removed a
large  amount  of trash and  debris  from the  two sites.   A
35  ton (31.7 Mt)  crane was  used  to move  the  haphazardly
piled   drums  about   so   they  could  be   sampled   and
analyzed.   The 2,000  drums found at  the  two sites  were
classified  as  empty,   partially   full or  full.    Empty
drums     were    subclassified    as    salvageable    or
unsalvageable.    Salvageable  drums  were   removed  by  a
chemical  company  and  unsalvageable  drums were  crushed

                                       5-2
-------
  and removed by a scrap metal dealer if uncontaminated or
  disposed  of  at  a  licensed  facility  if  contaminated.
  Partially   full  and  full  drums   were   overpacked  if
  necessary and  subclassified according to their contents:
  acidic, basic,  solvent,  and cyanide.  Cyanide drums were
  taken  to  a  licensed disposal facility.   Solvents went to
  a  cement  kiln  for  use as a low grade fuel.   Acids and
  basics  were taken to  a nearby  chemical treatment  and
  disposal facility.

      At  Site 1,  three underground  tanks,  one  of  which
  contained waste oil with 0.42  ppb PCB's,  were pumped out
  and  their contents  disposed  of.   The tanks were then cut
  open,  filled with  cement  grout,  covered and  the  area
  capped  with clay.   A garage  located  on the  site  was
  removed.  Four monitor wells  were installed.   Then the
  site  was  graded,  capped  with  clay,  and  covered  with
  topsoil and seed.

      Site 2 had  15  above ground  liquid  storage  tanks.
 Their contents  were sampled and  analyzed.   Bulk  liquid
 acids and basics  were  removed  by a vacuum truck.   Seven
 of the  tanks were stainless steel and were removed by a
 company in  exchange for  the tanks.  The remaining  tanks
 were dismantled and removed.    A building  and  several
 walls were  left  standing  at  Site  2.    Their  exteriors
 were sandblasted  and   the  interior of the building was
 cleaned with  detergents  and  disinfectants.     Zirconium
 powder  found in a  vault  in the building was  removed and
 burned  under controlled  conditions.   Four monitor wells
 were installed,  then the  site  was graded and paved with
 asphalt.

 SITE DESCRIPTION

 Surface  Characteristics

      CMI consists of two parcels  of  land  separated by a
 block of  about  20 residences  in  southern  Baltimore,
 Maryland,  near  the Baltimore   - Washington  Expressway
 (see  Figure  1).   Site  1 is  at 2001 Annapolis  Road and
 Site  2  at 2103  Annapolis  Road.   Railroad tracks run next
 to  the  northern  and southern  boundary  lines of  Site 2
 (see  Figure  2).   Soil  at the two  sites is  in the Lenoir
 - Bettsville association and is  sandy loam to clay loam
 over  clay.   The soil is moderately well drained, with a
 subsoil  of predominantly  silty clay  loam  and silt loam,
 underlain by thick stratified sediment.

     The  area  has  a  changeable  but  equable  climate      300.68(e)(2)
because  it   is  located  between  the  colder northern  and      (i)(E)
milder southern  climates, and between the Appalachian         climate
                                      5-3
-------
    Figure 1.  Location Map of  Chemical Metals  Industries
              Site, Baltimore, MD
                                 f MIDDLE
                                /  BRANCH
Source:   The Sun,  Baltimore, MD,  10/23/81

                       5-4
-------
             Figure  2.  Locations of CMI  Sites #1 and #2
                  o
                  o
                  o
                  OJ
                      CLARE  STREET
CMI SITE
#1

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M
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                                        BALTIMORE GAS AND


                                        ELECTRIC PROPERTY
1111111111  n  111111111111111  n  1111
                              5-5
-------
Atlantic Ocean  to the east.   This area is located  near
the average  path of the  low pressure systems that  move
across the country, which  cause  frequent changes  in  wind
direction.     Precipitation   occurs   fairly  uniformly
throughout the year, averaging about 40.46  inches (102.8
cm)  annually.    Temperatures   range   from  an   average
minimum daily temperature  of  33.4  degrees F.  (0.8 C.)  in
January to an average maximum of  76.6 degrees F. (24.8
C.) in July.

Hydrogeology

     Although monitor  wells  were  installed  at   the  two
CMI  sites,   apparently  no  study  of   the  area's  hydro-
geology  was   made.    Ground  water was  found  at least
within 8  feet (2.4  m)  of  the surface  at  Site 1,  and  at
an unknown depth at Site 2.

WASTE DISPOSAL HISTORY
     Wastes  disposed  of  at  the  two  CMI  sites  resulted
from  two on-site manufacturing  processes.   The first
process  involved the manufacture  of  copper  sulfate  or
copper  hydroxide by  reacting   a  waste  liquid,  copper
ammonium  sulfate, with  either  sulfuric acid or  sodium
hydroxide.   The  second  process  involved placing  printed
electronic  circuit  boards in  aqua  regia,  which is  a
mixture of nitric and  hydrochloric acids that is highly
corrosive.   The  aqua  regia  dissolved gold  out  of  the
circuit  boards,   leaving  the plastic  intact.   Then  the
aqua  regia was  neutralized  to make the gold crystalize
out of the solution.

     These  manufacturing  processes  resulted  in  large
amounts  of  incompatible wastes  such as acidics,  basics
and cyanide,  which  were  stored  close together  in above
ground tanks  and haphazard piles of drums,  some  of which
were  badly  deteriorated.    Numerous  other  substances,
such  as  zirconium powder,   reagents   and  heavy  metals
formulators,  were also  found in a vault in the  building
located on Site 2.   The three underground  tanks at  Site
1  contained  relatively  small   amounts   of   water  and
gasoline mixtures in  two tanks and a waste oil with 0.42
ppb  PCS'a in the  third.   These  had  been used  by the
previous  owner  of  Site 1,  a service  station  operator.
It  was not  clear whether or how the  CMI  operators had
used  these tanks.

DESCRIPTION  OF  CONTAMINATION

      Preliminary investigation  of CMI was performed by
the  OEP  and  a more detailed investigation was conducted
by the TAT.  Environmental contamination at the CMI sites
was   rather  slight;   the   principal  reason   for    the
 300.68(e)(2)(D)
hydrogeological
factors
 300.65(a)(3)
risk of fire
or explosion
                                      5-6
-------
  emergency  response action  was  the  threat of  explosion
  and   fire   presented  by   the   improper  storage   of
  incompatible   materials  in   areas   next  to   occupied
  residences.   Most of  the  contamination was confined  to
  drums,  tanks, debris  and  surface soils.   An  estimated
  100  tons (90.7  Mt)  of contaminated  debris and  surface
  soil was removed from Sites  1  and 2,  but no breakdown  of
  this figure was  available.   It appeared from the initial
  investigations  that  the  surface contamination  resulted
 mainly from the  contents of  deteriorated drums  and tanks
  spilling onto the ground.    Acid fumes were detected  in
  the soil at Site 1 and EP toxicity tests of soil  at Site
  1 also indicated cadmium levels in excess of standards.

      The  extent  of   ground   water   and  surface  water
 contamination  that  resulted from the  two  CMI  sites  is
 not  clear.     Investigators  observed  some bluish-green
 run-off  from  the  site,   and   early   in  the   emergency
 response  they placed   a  sorbent  sausage  boom  at two
 locations  to   contain  run-off.   Leaking  drums  stacked
 near an  open   storm drain  at  Site 2  posed a  threat  of
 contaminated  run-off   into  the  drain  system.     Surface
 run-off from  the CMI  sites eventually  goes into  Glynns
 Falls,  a tributary of  the  Middle Branch of the Patapsco
 River.

      Eight   monitor wells  were  installed,  4  at  each
 site.   On  Site  2  a  bluish-green water was observed  in
 some  wells;  it was subsequently found to contain a high
 concentration   of  copper  sulfate,   with  the  highest
 concentration  being in  the center of  the site.   On Site
 1,  gasoline was  found  in one well at a depth  of 8 feet
 (2.4 m).

     Contamination of  the  air was a major concern at CMI
 because  cyanide  was  found  close  to  strong acids,  the
 mixture  of which could produce  extemely toxic  hydrogen
 cyanide  gas.   This concern  was underscored by reports
 from  neighbors of noxious  odors at the sites.   Several
 fuming drums  were observed during early site  investiga-
 tions.   The initial analysis  of air  samples by the TAT
 using  a  MSA cyanide  detector  showed  cyanide  concentra-
 tions in  excess of 30  ppm.   This led to  a cessation of
 all  site  activity while TAT  investigators  attempted  to
 confirm these  results  with  a  Draeger  detector.   When the
 Draeger detector  failed to  confirm the  initial  results,
 the investigators consulted with the manufacturer of the
MSA detector and  learned that the high concentrations  of
nitrogen dioxide  gas,  resulting from  the  degradation  of
nitric acid  at the  site,  may  have  caused  an erroneous
cyanide  reading.    On  another  occasion,  the   Draeger
instrument had a  cyanide  reading  of  over  30  ppm,  but
when the area  was sampled with  the MSA detector  this was
 300.68(e)(l)(i±)
 absence of
 effective
 drainage control
 system
 300.65(b)(5)
 sampling
 300.65(b)(5)
sampling
                                      5-7
-------
not  confirmed.     Discussions   with   Draeger  Company
representatives  determined that  ammonia vapors  at the
site could have  caused a  false positive  reading.  Nitric
acid  or  hydrochloric   acid   vapors  also  could  have
discolored the Draeger tubes  and given a false positive
reading.  Investigators eventually determined  that  fumes
emanating from some  of  the drums probably resulted from
the mixture of moisture with acids in leaky drums.

PLANNING THE SITE RESPONSE

Initiation of Site Response

     CMI  was  discovered  when  an  inspector   from the
Maryland Office  of Environmental Programs (OEP) noticed
it while driving to a licensed chemical treatment  plant
in  South  Baltimore.  A  review  of  state files revealed
that, while  CMI  had operated for  7 years, OEP  had  no
record  of  its existence.   Nor did the  state  Department
of Health have records about it.

     The OEP  entered the  site on September 2, 1981  to
conduct an  initial investigation.  Officials  determined
that  the  situation  posed a  significant  threat of con-
tamination   and   explosion,   requiring   an   immediate
response.   Since neither  the  OEP nor L & M Associates,
the owner of  CMI,  had sufficient funds  for  this clean-up
action,  the  state  requested federal  assistance  under
section  104   of  CERCLA.     EPA  Region  III   sent  its
Technical Assistance Team  (TAT),  which was Ecology  and
Environment,  Inc.,  to inspect  the site on September 15.

     The  TAT  inspected  conditions  at  CMI,   conducted
ambient air monitoring,  and took drum samples  to  the  EPA
Region  III  Central  Laboratory for  analysis.   A  visual
inspection  of CMI  found  that several attempts had been
made  to start fires.  Local residents interviewed by  TAT
personnel  reported  that  noxious  vapors  had  emanated
occasionally  from CMI over the  past  few years, and that
a   green  liquid  and  noxious  odors  had  entered  the
basement of an adjoining  residence.

     Markings on drums  at the site revealed the presence
of inorganic  acid  and  acid solutions,  alkali salts  and
alkali  solutions,  cyanide-bearing  compounds,   mixes  and
solutions,  and   ammonia  compounds   and  ammonia  solu-
tions.    This  combination  of  chemicals  presented  a
serious threat   to  public  health;   as the  TAT  report
stated, "acids,  when brought  into contact  with cyanides
evolve  actively toxic hydrogen  cyanide vapors which  are
 fatal in concentrations  of 300  ppm."  The TAT conducted
ambient air  monitoring,  which showed low concentrations
 of hydrogen  cyanide vapors   and  organic  vapors  at   the
300.63(a)(4)
random observa-
tion by government
300.64(a)
preliminary
assessment
300.67(b)
state request
for federal
assistance
300. 64 (a)
preliminary
assessment
300.65(a) (1)
toxic exposure
                                       5-8
-------
site.
     The  TAT  report agreed  with the  conclusion of  the
state   that   conditions  at   CMI   justified  emergency
response   action.      The   TAT  outlined   three  major
threats:   (1)  formation and release of hydrogen cyanide
vapors  from  leaking drums;    (2)  off-site  migration of
contaminated surface water from  leaking drums, affecting
walkways,  streets  and  the  Patapsco River;  and  (3)  the
danger  of fire, which treatened  nearby  residences  and
the  environment with  the release  of toxic  vapors  and
water run-off  from fire fighting efforts.   To stabilize
the site  and reduce these threats,  TAT proposed  that  EPA
secure  the drums,  assess  the  integrity  of  the above
ground  storage tanks,  and  inventory,  sample,  analyze,
categorize and dispose of all wastes.

     On October 19, EPA authorized  an  emergency  response
action at  CMI,  to  be funded  under  CERCLA, making CMI  the
first Superfund site in Maryland.   Response  action began
that day.  Before  authorizing  the  response, however,  EPA
had  to  resolve a  conflict  it had with the U.S. Coast
Guard.     Between   the  time  of  the  DEP   request   for
assistance  on  September 2  and EPA1 s  authorization on
October 19, the state  performed some  containment action
at CMI.   Upon  Maryland's request,  the  Coast  Guard agreed
to reimburse  certain   state  costs  under  the section  311
fund of  the  Federal Water Pollution Control Act, which
the  Coast Guard  administered.   The  state  fenced both
sites to  prevent unauthorized  entry and removed  trash to
prevent   fires.     The  Coast  Guard  supplied   sorbent
barriers  to be placed  at  two  locations to prevent run-
off of contaminated material into the  storm drain.

     Due  to   the  Coast  Guard's prior involvement with
CMI,  some debate  arose  between  it  and  EPA regarding
allocation of  supervisory  authority and funding for  the
clean-up.   This  debate may have  contributed  to delay
between   the    state's  request   and   EPA's  Superfund
authorization.  In early October,   the agencies  signed  a
Memorandum of  Understanding  allocating jurisdiction over
the  site.   EPA's  On   Scene  Coordinator  (OSC) was given
final authority over  all actions taken at CMI.  The  OSC
requested  $58,000  from  EPA  headquarters  to  pay   for
staging    and  intitial response   action  costs.   This
amount  was authorized by  headquarters  on  October  19.
Then the  OSC  made an  oral  demand  upon the receiver  for
CMI  for  clean-up  funding,  which  was   followed by  a
written  demand.   The  receiver responded  that  no such
funds were available.   On  the  same day as  the  receiver's
response,  EPA  hired J  & L  Haulers of Baltimore, Md. to
serve as primary contractor  for  the clean-up.
300-65(a)
immediate
removal risk to
human health or
environment
300.65(b)(3)
security
fencing

300.65(b)(7)
physical
barriers
300.64(a)(93)
determination
of party's
willingness to
clean up
                                      5-9
-------
Selection of Response Technologies

     The  technologies  employed  at  CMI were  drum,  tank
and bulk  liquid removal, and grading and  capping.  Drum,
tank  and  bulk  liquid  removal were  chosen in order  to
eliminate the  threat of explosion  or  fire.   Drums and
liquids  were  divided   into  classes  and  subclasses  to
facilitate   safe   handling  and  expedite  disposal   or
treatment.   Both CMI sites were  graded  and capped.   Site
1 was  capped with  clay and sod  for use as a small  park
and Site  2  was capped  with asphalt  for use as a parking
lot surrounding the  building  that had been prepared for
use as administrative offices.   The underground tanks  at
Site 1 were  filled with cement grout, covered  and  capped
because they were not contaminated enough to warrant the
high  cost of  excavation and  removal.   Four monitoring
wells  were  installed at each site  to  determine whether
the  removal   action  prevented  further  ground  water
contamination.      Ground   water  extraction   was  not
performed because  there were  no drinking  water  supply
wells  located  nearby.   Officials took  a "wait and  see"
approach  to this  issue,  preferring to observe monitor
well  results  to  determine whether   further  work  was
needed.

Extent of Response

     Response action at CMI ceased when all materials  of
concern were removed from  the  two sites  and the surface
areas  capped,   thereby  ending  the  immediate  threat  of
explosion  or  fire.    Little  information  is  available
concerning  how deep  the  contractors  excavated surface
soil  at  the sites  to  remove contamination;  it appears
that  they simply  scraped  the  sites  to  where the  soil
appeared  clean and then graded  the  area in preparation
for capping.   Nor  is it clear how it was  determined  that
the building at Site 2 was safe for  re-use.   Given the
nature and  extent of  contamination  there,  the cleaning
and sandblasting measures apparently were sufficient.

DESIGN AND EXECUTION OF SITE RESPONSE

     On  the night of  October 19,  1981,  when Superfund
money  was authorized for CMI, EPA, the  TAT, the Maryland
OEP and J & L, the primary contractor, met to outline a
plan  for  set-up at  the site and to allocate responsi-
bilities.    A  primary  concern   of  all parties  was the
safety of the  nearby population. The  TAT was  to perform
continuous   site  boundary  air  monitoring  and was  to
develop an  evacuation  plan in the event  of explosion  or
fire.    The Baltimore  City  Police  and  Department  of
Traffic and  Transit  were to close off  the area where CMI
was  located to prevent unauthorized  entry  during  the
300.65(c)
completion of
immediate
removal

300.68 (j)
extent of
response
                                     5-10
-------
emergency  response  period.    This meeting  also  estab-
lished a  community relations plan, whereby a  small  team
from EPA  would  explain to local residents what  remedial
actions would be taken at the site.

     Participants  at the preliminary  meeting  were  also
concerned  for  worker safety  at the site.   The TAT  was
given responsibility for  drafting  a site  safety  plan for
EPA  approval  that  outlined  operating  procedures   and
precautions.     The  plan   required   medical   physical
examinations  for  all  on-site  personnel,  daily  safety
meetings,  prior  training  for all tasks to be  performed,
continuous   site   monitoring,   and  availability  of   a
respiratory  system.    In addition,  J  &  L  was  given
responsibility  for  establishing  a  safety protocol  for
its personnel and  those  of its subcontractors.  J &  L's
plan provided  a respiratory  protection program,  decon-
tamination facilities, and trained medical personnel  on-
site.  J  & L also supplied initial site  security  during
non-working  hours,  with  Baltimore  police  providing
security later.

     Site  monitoring  featured prominently  in  the   TAT
plan with the setting of a  base  line  for  NGN,  NH3  and
explosive vapors,  as measured  by Draeger  tubes and a MSA
explosimeter,  and  with   sample results  recorded  in  a
log.    Criteria  for on-site  vapor  concentration  were
established;  if  on-site  vapors  exceeded 10  ppm,  site
periphery  monitoring would be conducted,  and  if cyanide
concentration  at  the  periphery  exceeded  2  ppm,   the
Maryland Health Department would be notified immediately
and appropriate action would  be taken.  In addition,  the
TAT  plan  identified  different   categories    for   air
sampling  during drum handling,  according to  the  degree
of hazard.

     The   TAT   plan  also  designated  three  zones   of
contamination at  GMI.    Zone  1  was  the  "clean  zone",
where no  uncontained waste or contaminated equipment and
personnel  were  permitted.    Zone  2 was  located  mainly
around Site  2 and required appropriate safety equipment
for each  task.   Zone 3 was at Site 1 and required,  at a
minimum,  that each person use  a respirator,  safety suit,
PVC  boots and  gloves.   No  one  was permitted  to  work
alone in this area.

     Work  at the  site  began October 20,  the day after
the  meeting.   It consisted  mainly  of  drum and  bulk
liquid  removal;  approximately  2,000  empty,  $>artially
full or  full drums  were removed  and  bulk liquids  were
taken  from  15  above  ground and  3  underground storage
tanks.
300.71
worker health
and safety
300.65(b)(6)
moving
hazardous
substances
off-site
                                     5-11
-------
     Drums  were classified  as  empty,  partially  full  or
full, with  the empty category being broken  down further
into salvageable  and unsalvageable.  The  partially  full
and  full  categories  were  subcategorized  by  content:
acidic,  basic, solvent and  cyanide.   Empty  salvageable
drums were  removed  by a  local chemical  company at  no
charge, while  empty  unsalvageable  drums  were crushed and
either  given  to a scrap  metal  dealer if  uncontaminated
or disposed  of at the  Browning Ferris  Industries  (BFI)
Solley Road facility if contaminated.

     Partially  full  or  full  drums  were handled according
to their  contents.   Drums  containing  cyanide went  to  a
permitted disposal site in Camden, New  Jersey.   Many  of
these were deteriorated and  had to be overpacked. Drums
holding  solvents  were  taken to the  Delaware  Container
Company  in  Coatesville,  Pennsylvania  for use  in a  low
grade fuel for a  cement kiln.   Drums of  acidic and basic
waste  were   sent to  Chem-Clear  Inc.   in   Baltimore,
Maryland  for  chemical treatment   and   disposal.    Bulk
liquids  pumped  from  storage   tanks  at  CMI  also   were
handled according to this classification system.

     Removal  action  at CMI's Site 1 took place in  the
following manner.  Workers  first removed debris from the
site (approximately  100 tons (90 Mt) of debris  and  con-
taminated soil were  removed from  Site  1).   Then  they
began  sampling,  analysis   and  categorization  of   the
drums.    Deteriorated drums were overpacked and  disposed
of at  the appropriate  places.   A vacuum  truck withdrew
compatible bulk liquids  from  drums,  such as acids  and
neutrals  or  basics  and  neutrals, and  transported  the
liquids  to  a  chemical  treatment  and disposal  facility.
Since many  drums had  deteriorated, a  35-ton  (31.7 Mt)
crane supplied by the Baltimore  Health Department was
used to  manuever drums  for sampling and removal.   The
crane began  at the top of  the  pile of  drums  and worked
down.

     Three underground  storage  tanks  were found  at  Site
1, two  containing gas  and water  mixtures and  one  con-
taining  waste oil with 0.42 ppb  PCBs.   These  liquids
were pumped out and  disposed of.   Then a backhoe removed
surface  soil  down to  the  tops  of  the tanks, which  were
about 4  feet  (1.2 m) below surface.  Part of  the top  of
each tank was  removed and  cement grout  was pumped  in
until it flowed out  of the tank  vents.   The  tops  were
then replaced and the  area  backfilled.   A 6  inch  (15.2
cm) clay  cap  was  placed over the area, which in turn was
covered by top  soil.

     A  garage located on Site  1 was  removed.   It had  a
common   wall   with   the   residence  on  the   adjoining
300.65(b)(ll)
salvage
operations
300.70(c)
off-site
transport for
treatment,
storage or secure
disposition
                                     5-12
-------
property, so extra care was  taken to avoid damage to the
latter  structure.   After  removing the  garage, workers
sandblasted  the  common  wall  to  remove  possible  con-
tamination and prepared it for painting.

     After the  drums  were  removed  and underground tanks
filled,  4  monitoring  wells were  installed at  Site 1.
Finally,  the site  was  graded,  capped  with  clay,  and
covered with a  layer  of  sod.   It is now being used as a
playground by neighborhood children.

     Site 2 was similar  to  Site  1 in terms of  procedures
for removing  drums  and bulk liquids.   However, several
distinguishing  removal actions took place here.  First,
Site  2  had  15  above  ground storage  tanks  (see Figure
3).  Their contents were sampled.   Bulk  liquid acids and
basics were  removed  by a vacuum truck.   Then the tanks
were  flushed  with water and the water  was removed for
treatment.

     One   tank   contained   copper  sulfate,   a   hard
crystalline material  that  required  that the tank be cut
apart with  a welding  torch  and  removed  by hand.  Seven
other  tanks  were made  of  stainless  steel;  a company
removed  than at  no  charge  in exchange  for  the tanks.
The  remaining  tanks,  5  of  steel   and 2 of  fiberglass,
were dismantled and removed.

     A second difference between the CMI  sites  was  that
Site 2 contained  a building and  several  walls  which were
decontaminated  and left  standing (with the  exception of
one  unstable wall  that was removed).   Exteriors were
sandblasted  while  the  interior  of  the  building  was
cleaned  with detergents  and  disinfectants so  that it
could be used later.   A  third  difference between the two
sites  was  that highly  explosive   zirconium powder was
found  in a vault in  the building   at  Site 2.    This was
carefully  removed  and  burned  by  the  Baltimore  Bomb
Squad.

     Finally, while Site 1  was capped  and sodded for use
as  a  playground,  Site 2 was paved  for use  as  a parking
lot  around  the  building,   which   was   to  be  used for
offices  and  storage.   Dye studies   that had  been made to
investigate   possible  run-off  of  contaminated   water
during  the  removal   operation  were  used  to  plan the
grading  of the  site   to  insure  proper  drainage.    Four
monitoring  wells  were installed at Site  2.   After the
area  was graded,  it was paved with a 2.5 inch  (6.3 cm)
layer of asphalt.
300.70(b)
surface sealing;
grading;
revegetation
300.70(c)(l)
off-site
transport
for destruction
300.7000(l)(ii)
(A); (C)
surface sealj
grading
                                     5-13
-------
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-------
 COST AND FUNDING
 Source  of Funding

     Before  EPA authorized  the  use  of  Superfund  money
 for the  CMI  clean-up,   the  Coast  Guard  promised  a
 relatively  small  reimbursement  of  the  state's  costs
 under  section 311  of the FWPCA.  This  money was for the
 costs  of fencing both CMI sites  and  removal of trash to
 prevent fires.   In addition,  the  Coast Guard supplied
 sorbent  barriers  as  a  temporary  measure  to  prevent
 possible run-off of  contaminated material into the storm
 drain.   As of July 1982,  this reimbursement had not been
 made.

     EPA paid for most  of  the  response action  at CMI,
 using  the CERCLA immediate  removal funds.   The intitial
 authorization was  for $58,000,  but  unforseen  difficul-
 ties in  the removal  process  as  well  as  unexpected
 contamination  problems   necessitated   several  funding
 increases, bringing  total EPA funding  to $205,000.  For
 example,  the first funding  increase  occurred  on October
 24,  five days into  the clean-up.   A sum of $30,000 was
 authorized    mainly   because   zirconium   powder   was
 discovered in a  locked vault in  the building at Site 2.

 Selection  of  Contractors

     Ecology   and  Environment   served   as   the  on-site
 Technical  Assistance   Team (TAT)   under  its   3-year
 contract  with EPA Region III.    It  was  responsible for
 coordinating  special projects,   sampling,  documentation,
 and  planning.   J  & L Industries  of Baltimore,  Md.  was
 hired   as  the   clean-up  general  contractor.    It  was
 selected  by  EPA because  of  its  experience  and  proximity
 to  CMI,  and  a  direct procurement   time and  materials
 contract  was  used.    J  &  L  oversaw   the  removal  and
 disposal  of   all drums,   tanks,  bulk  liquids,  and  con-
 taminated  soil and debris.   J & L subcontracted with the
Delaware  Container Company  for  disposal  of  solvents.   J
& L hired the firm  due to  past work experience  and the
 company's  proximity  to  CMI.  J & L hired  Clean America
of   Baltimore  to  pump  out  bulk  liquids   at  CMI  and
 transport  them   to   appropriate  disposal   facilities.
Clean America was  hired  primarily because  it had vacuum
 trucks  that were capable of  doing the job.

     EPA  hired several  companies  directly  to  treat  and
dispose  of various substances.    It  hired Chem-Clear,  a
chemical  waste  treatment   and  disposal   facility  in
Baltimore,  to  dispose  of   the  acids  and  basics  from
CMI.  A time and materials  contract was  used with  Chem-
Clear,   which was  selected  because of  its  expertise  in
the  field,  the  technical capabilities  of its  facility,
300.61(c)
CERCLA -
financed
response
action
                                     5-15
-------
and its  proximity to CMI.   EPA hired CAMAX Corporation
to  remove  and  dispose  of all  non-zirconium materials
from the  vault  and laboratory area at Site 2.  EPA  also
hired  Martel  Laboratory  Services,   Inc.   of  Baltimore
(through  TAT Special Projects)  for  analysis of  samples
from CMI  for RCRA disposal capability and precious metal
content,  as  well as monitoring  well  samples for ground
water contamination.  Martel  was selected because it was
located  nearby  and  had  the  capacity  to perform prompt
analyses, while  state and  federal labs in the region had
too much backlog.

     T  &  A  Excavating,  Inc.  was hired  to  do the final
site clean-up,  including removing the building from  Site
1,  grading and  sodding  that area,  grouting the under-
ground  tanks at Site 1,  clay capping  the tank area, and
grading  and paving  Site   2.    T &  A  originally   sub-
contracted  with J & L but  later  worked  directly  for EPA
under a sole source  fixed  price contract.

     Two  Browning  Ferris  Industries  (BFI) facilities
were used by J & L, Chem-Clear and  Delaware Container
for disposal.   All non-liquid hazardous substances  from
CMI,  including   sludges  from  Chem-Clear  and   Delaware
Container,   were  disposed  of  at  BFl's   Solley   Road
facility.   Non-hazardous solid  wastes such  as debris and
some  empty  decontaminated  drums were  disposed  of  at
BFI's  sanitary  disposal  facility.    BFI  had  an  open
disposal  contract with Chem-Clear and Delaware Container
for  their sludges.   J &  L had  a contract with BFI  to
dispose  of contaminated soil and debris,  and EPA had a
separate  contract  with  BFI  for  disposal   of  the  non-
hazardous  materials.  BFI!s proximity and  capability  to
receive   these    wastes  were  major  reasons   for   its
selection.

     EPA  had   several  local  firms  perform  designated
removal  work  under  formal  or  informal  agreements  in
exchange  for the materials removed.   Abbey Drum Company
in  Baltimore   removed  about  600  empty  uncontaminated
drums  from sites 1 and 2 at no charge and was allowed to
keep them.   Included in this number were 51 drums loaned
to   CMI  by  Robinson  Chemical   Company,   which  Abbey
returned   to  Rob inson  as  a    favor   to   its   c 1 ient.
Spectron,  Inc.  removed  stainless sfeel tanks from Site 2
in  exchange for  the tanks.    Finally,  Klaff Metals  of
Baltimore,  a scrap  metal  dealer, agreed to remove  over
400  empty  uncontaminated  unsalvageable drums   and un-
contaminated debris, which totalled  over  31,000 pounds
 (14,061.4 kg).   These firms appear to have been selected
because  they   were  willing  and  able  to   remove   these
materials quickly and at no charge to EPA or the state.
                                      5-16
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 Project  Costs

      The  emergency   response   action   at   CMI   cost
 $340,343.42  (see Table 1).  Most  of  the CMI  project was
 funded  directly under authority of CERCLA, although the
 State of  Maryland  and  City   of  Baltimore  contributed
 substantial  funds and services  also.   According  to the
 On   Scene   Coordinator's   (OSC's)   report,  a  total  of
 $199,143.42  in  direct costs  was  funded under  CERCLA,
 with most  of that amount going  to J &  L Industries, the
 general  contractor  ($152,289.17),  followed by Chem-Clear
 ($25,435.25),  T &  A  Excavating ($15,000)  Clean  America
 ($4,989) and Williams  Mobile offices ($1,430).

      The  State   of Maryland   had  spent  an  estimated    300.62(a)
 $103,500   as  of  February  1,  1982  for  personnel  and    state role
 equipment.   Personnel who  spend  time  on the  projcet    in response
 included a representative to  the Regional Response Team,
 chemical and civil  engineers,  a biologist, a geologist,
 well   drillers,   investigative   staff  and   Assistant
 Attorneys  General.   Maryland also provided such  support
 equipment  as  a  well  drilling rig, a  van and  a  4-wheel
 drive  vehicle,   respirators,   an  MSA   self-contained
 breathing  apparatus,  and  monitoring  equipment.    The
 state also paid  for   some  costs  incurred  by T  &  A  in
 capping  the sites, but  these weren't  specified  in the
 OSC  report.

      Baltimore  provided  24-hour  site  security for  part
 of the  project's duration,  a 35-ton (31.7 Mt)  crane for
moving   drums,   a   Civil  Defense  van,  fire  equipment
 (ladder  truck  and  pumper),  a recharging  self-contained
breathing  apparatus, plus the  time of  personnel from the
Fire  Department,   Bomb   Squad,   Health  Department  and
Mayor's  representative to  the  Regional Response  Team.
These goods and services  were estimated  to total  $7,700
as of February 1, 1982.

      The OSC  estimated that  the  cost  of the  Technical
Assistance Team's special projects relating to CMI  came
 to  $30,000,  although  this figure was  not broken  down
 into  costs for specific tasks.

      The U.S.  Coast Guard  agreed to  expend  some  money
under section  311 of  the FWPCA to reimburse some  state
costs  incurred  during the  initial response  to the  CMI
 site  before  response  authority was  switched  to EPA and
funding  to CERCLA.   The Coast Guard agreed to  reimburse
the  state  for  the cost of fencing the  sites  and  placing
sorbent  barriers  to prevent run-off.   No  reimbursement
had  been made  as  of  July  1982.    The  costs  of  these
actions were not included in the OSC's  report.
                                     5-17
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             TABLE 1.  SUMMARY OF COST  INFORMATION-CHEMICAL METALS INDUSTRIES, BALTIMORE,  MD.
Task
General contractor (oversight
of all removal and disposal
work — 1400 drums, 15 tanks,
100 tons (90.7 Mt) contaminated
soil and debris
Disposal of contaminated
soil and debris
Treatment and disposal of
bulk liquids acids and
basics
Pumpout and transport of
bulk liquids
Grading, sodding and
capping Sites 1 & 2
Mobile office rental
Workplan, safety protocol,
chemical analysis
State of Maryland equipment
and personnel
City of Baltimore equipment
and personnel
TOTAL
Quantity

100 tons (a)
(90.7 Mt)
19,500 gal.
(73,815 1)
19,500 gal.
(73,815 1)
NA
1
NA
NA
NA
' A
NA
Expenditure
$147,789.17
$4,500
$25,835.25
$4,989
$15,000
$1,430
$30,000
$103,500
$7,700
$340,343.42
Unit Cost
NA
$45/ton(a)
($40.82/Mt)
$1.30/gal
($0.34/1)
$0.25/gal
($0.07/1)
NA
NA
NA
NA
NA

Funding Source
CERCLA
CERCLA
CERCLA
CERCLA
CERCLA
CERCLA
CERCLA
Maryland
Baltimore

Period of
Performance
10/19/81-
12/18/81
10/19/81-
12/18/81
10/24/81-
12/18/81
10/24/81-
12/18/81
11/27/81-
12/18/81
10/20/81-
12/18/81
10/19/81-
12/18/81
9/2/81-
12/18/81
10/19/81-
12/18/81
9/2/81-
12/18/81
I
»—
00
                   NA - Not available
(a) From OSC report
-------
PERFORMANCE EVALUATION

     The  emergency  response   at  the  CMI  sites  was
completed *in  approximately 7 weeks  and  appears to have
accomplished  its  objective,  namely,  to  eliminate the
threat  to public  health  and  the environment  posed by
possible  fire or explosion.   Several causes of delay in
the  response action  can  be  identified.   First,  the
dispute between  the  U.S.  Coast Guard and EPA concerning
authority  over  the   clean-up   action   apparently  con-
tributed  to   the  delay  of over  one month  between the
Maryland  Office   of  Environmental  Programs'   (OEP's)
request   for  funds  under  section   104  of  CERCLA  on
September 2,  1981  (EPA's TAT agreed  on September  15  that
an   emergency   response  was   warranted)   and    EPA's
authorization, on October 19.   Since this was  the  first
Superfund action in Maryland,   this  type of delay  might
not occur again.

     A  second delay  in the response  action resulted from
the circumstances  at CMI.  The unstable  piles  of  leaking
drums  found  at  the  sites  necessitated  the use of  a 35-
ton (31.7Mt)  overhead  crane  to remove the drums one at  a
time,  working from  the top  down.    This procedure was
very  slow but  necessary for  safety reasons,   since the
contents  of  many drums were unknown but some  drums  were
identified as containing incompatible chemicals.  Adding
to  the delay  in  removing drums was  the fact that  the
sites  had little  room  for  a  staging  area where  drums
could be  sampled,  overpacked  and categorized for  removal
and  disposal.   The   lack  of   staging  area led  to  the
temporary storage  of  some   drums   at   the  Chem-Clear
facility,   pending  analysis   of   their   contents   for
precious  metals,  giving  rise  to   a concern  that  the
response  action  might  be   abating  a  hazard  at  one
location  by  creating  a  new  hazard   elewhere.     This
concern was  alleviated fairly  promptly,  however,  because
once    initial    analytical    results    indicated   no
commercially   recoverable  precious  metals,   the   drum
contents  were treated  and  disposed of.

     One   important   issue   in  this   response   action
concerns  the asphalt  cap  placed over Site 2.   This site
was  cleared and graded in December  1981  in preparation
for  paving.    T &  A Excavating, the paving contractor,
advised the  OSC that the cold weather at that  time could
cause   the asphalt to  crack  later  because  it  might not
set  properly.  T  & A  also stated that the 2.5 inch (6.3
cm)  asphalt  would not  support heavy vehicles.   T &  A
advised  that  the  paving  be  postponed  until  warmer
weather,   but   the  OSC   and   the   Maryland   Office  of
Environmental  Programs   (OEP)   wanted   to  finish  the
response  action   because   the   delay   would    impose

                                      5-19
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 addit ional  cost s  and require  re-grading the  area when
 paving  was  to be  done.   The OSC chose  to pave the site
 in December.  According  to reports  from T  &  A  and the
 OEP,  the asphalt  had begun to crack by  August 1982 and
 may  require  patching by  the  state.   The  OSC had  to
 choose  between finishing the  response  action with the
 risk  that the pavement would not  set properly, in which
 case more money would be required from some  source, most
 likely  the  state,  or delaying completion of  the project,
 in which case  the  total paving  cost  to the  Superfund
 might  be lower  but  the site  would be  exposed to  the
 element s  in the meant ime.   Al though the OSC' s dec is ion
 may result  in additional paving  costs to the  state,  it
 did have  the beneficial  effect of capping Site 2 in the
 short term,  even  if  this may not be  entirely  effective
 in the long  term.

     The  role of ground water  monitoring   in  the  CMI
 response  action is somewhat unclear.   Most of the clean-
 up work  at  these  two  sites  was in the nature of  an
 emergency  removal  action:   first,  hazardous substances
 and  contaminated   soil   and  debris   were   removed  and
 disposed  of,  then   monitoring   wells   were installed.
 Hence,  the  results  from  these wells  did not  guide  the
 response  action  that  was performed  but could  indicate
 the need  for future  remedial action.   It was  apparent
 from the  first  series of samples that there was ground
water contamination at both  locations: copper sulfate  at
 Site 2  and  gasoline at Site  1.   The OSC decided not  to
perform  ground  water extraction  and treatment  because
 there were  not drinking  water wells nearby.   If  this  is
 so,  there  would   be  no  need for future ground  water
 treatment and,  thus, no practical   need  for  continued
operation of the  wells.    However,   Maryland  state  law
apparently  requires  continued  monitoring for  a period
after site closure.

     One  of  the  highlights   of  this  response action was
 the OSC's adroit  use of  ways to have materials  removed
 from the  sites  at  no charge.   Local companies  removed
 salvageable drums  and tanks  as well  as crushed  drums and
scrap metal  in exchange  for these materials.   Hazardous
substances  such  as  solvents,   acids and   basics   were
recycled whenever  commercially  possible.   This work was
 time  consuming  and  would  have  greatly  increased  the
response costs if EPA had hired contractors to  do it.

     Another  important  feature of the  CMI response was
the  close   cooperation  between  EPA,   the   State   of
Maryland,  the  City   of  Baltimore,  and  the  various
contractors.   The work  was generally well  planned  and
carried out,  with agencies  and departments  contributing
much  of  needed   personnel,  equipment  and   services.

                                     5-20
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Government  respresentatives,  together  with   the  TAT,
developed  a  good  safety   protocol  and  workplan   for
conducting the  site  response.  These  parties also took
steps  to inform  local  residents  of the  situation  and
developed  an  evacuation contingency  plan.    The  only
notable  instances  of  noncooperation were the Department
of Defense, which would  not  to permit the burning of  the
zirconium  at  a  defense  installation,  and state   and
federal labs in the area, which because of backlogs were
simply unable to do the chemical analysis quickly.
                                     5-21
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                  BIBLIOGRAPHY
Chambers, Barry.  June 1, 1982.  J & L Industries.
     Personal communication with Environmental Law Institute.

Henderson, Frank.  May 27 - June 2, 1982.  Maryland Office of
     Environmental   Programs.       Personal    communication   with
     Environmental Law Institute.

Massey, Thomas I.  May 27 - July 1, 1982.  On-Scene Coordinator,
     U.S. EPA - Region III.  Personal communications with
     Environmental Law Institute.

Massey, Thomas I.  1982.  Federal On-Scene Coordinators Report,
     Major Pollution Incident, Chemical Metals Industries, Inc.,
     Baltimore, Maryland, Emergency Removal Project.  U.S. EPA
     Region III.  Philadelphia, Pennsylvania.

Patel, Dinesh.  June 1, 1982.  Chem-Clear.  Personal communication
     with Environmental Law Institute
                                  5-22
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                        CHEMICAL RECOVERY SYSTEMS, INC.

                               ROMULUS, MICHIGAN


INTRODUCTION                                                  NCP Reference

     Chemical Recovery Systems, Inc. (CRSl) has operated a
solvent recycling facility on a 15.75 acre (6.38 ha) tract
in  Romulus,  Michigan since 1972.   Previous  owners  of the
site, Cam Chemical Company  and  Product  Sol,  also used the
property for  solvent  recovery,  but their disposal methods
resulted in severe contamination of ground water below the
property with organic  and  inorganic  chemicals,  solvents
and heavy metals.  This  in  turn contaminated an adjoining
drainage ditch that leads to the Ecourse River.

Background

     The Cam Chemical Company purchased this site from the
Sinclair Oil  Company  in  1960  and used  it to recover waste
solvents  for  resale  as  lacquer thinners,  resins,  driers
and  paint  additives.   "Still bottoms"  from the recovery
process  were stored  in  55-gallon drums  onsite.   After
about 45,000  drums  had  accumulated, the company excavated
4  unlined  trenches  to  store  still bottoms;  these over-
flowed  in  the later  I960' s  to  form one  large pond.   Cam
Chemical purchased  an  incinerator  to dispose  of  its
chemical wastes and thereby expand  its recycling capacity,
and  soon accumulated 60-70  thousand  more drums.    The
incinerator  proved   inadequate  and  the  company  ran  into
financial difficulty.  It sold the  property to Product Sol
Corporation  in  early 1971.   Product  Sol  constructed  4
large  clay-lined  lagoons during  the  summer  of 1971  to
store chemical wastes.  It sold the property at the end of
1971 to CRSI, the present owner.

Synopsis of Response

     Since  1972,  CRSI  has  removed  approximately 100,000
drums containing  still  bottoms  from the site and disposed
of  them.  The 4 clay-lined  ponds were  removed, with three
being  excavated  between May and  October  1974 and  the
fourth  in 1980.   CRSI  installed an underdrain  system in
1976  to collect  contaminated ground  water.   Subsequent
tests showed  that it  was  ineffective,  and  in 1980 another

                                     6-1
-------
one was  installed.   The Trouton Drain, which  adjoins  the
site and was contaminated, was dredged twice, once in 1977
and again  in  1980.   In 1980, CRSI  installed an asphaltic
slurry wall  to complement  the underdrain  system  and
prevent movement of ground water from the  site to Trouton
Drain.  In early 1983,  wastes were  removed from the large
pond (vinyl pond shown in  Figure 1).
SITE DESCRIPTION

     The Chemical Recovery Systems, Inc.,  site  is located
in  Wayne  County, Michigan,  about 25  miles (40  km)  from
downtown Detroit (Figure 1A).   The surface characteristics
and  hydrogelogy of  this  site  are  discussed  separately
below.

Surface Characteristics

     The site is approximately 1,300  feet (396 m) long and
900  feet  (274 m) wide  enclosing a  total of  15.75  acres
(6.38 ha) (Figure IB).   The northern boundary of the site
parallels Van  Born  Road  and  includes  its  only entrance.
The  western portion  of  the   site  is  bounded  by  a  C&O
railroad track  and  the eastern  portion  by Trouton  Drain.
Classified by USGS as  an intermittent  stream,  this  drain
forms  part   of   the  headwaters  to  the  Ecourse  River—a
medium-sized tributary  of the Detroit  River.    Less  than
1/4-mile  (0.4  km)  south  of  the  site  is  residential
community of  about  100  single-family  homes with Trouton
Drain  running  through   the  center.     The areas in  the
immediate vicinity of the site  along  Van Born  Road  are
occupied  primarily  by  small  businesses  with  a  few
single-family residences, a large industrial  plant,  and a
school.

     Vegetation on the site consists  of tall weeds,  trees,
and  shrubs   along  the   southern boundary  and  southwest
corner thinning to a  few shrubs, grass, and bare ground in
the  remaining portions  of the site.   At  least  1/3  of the
property is devoid of  vegetation because  of  the presence
of  dirt  roads,  the parking  lot, buildings,  drum storage
areas, and a large pit of wastes known as the vinyl  pond.

Hydrogeology

     Topography  of  the site  is very level with less than    300.68(e)(2)
an 0.5 percent  decline in slope from the northwest  to the    (i)(D)
southeast  boundaries.  Several  test   borings taken  over    hydrogeological
the past 10 years show an upper layer of topsoil, 8  inches    factors
(20  cm) thick,  overlying a sand  aquifer  with thicknesses
ranging between  7  and  10 feet  (2 to  3 m).   Beneath the

                                     6-2
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  /   CHEMICAL      o
  /   RECOVERY      5
 /   SYSTEMS

                    1 INCH ^2000 FT
Figure 1A.  Chemical Recovery Systems., Inc. Site
                            i-3
-------















C & 0 RAILROAD
1 I

VAN BORN ROAD
1
Parking
Lot
<•" Office 	 • . Tool
a- 1\ uirice _, ••.
•f**7
tfv- v
V < - ^
_ ".— r ^ 	 v sued
^••X drum storage areas _, . Sb
.t ^X ^ Ziebart \.
*t> Formula- ")
(5*.' ^-^ lime Thio- Plant (se- '
film parate
— ^_ ownership] '
Unload- •
IMR tors Dnderdrain /*N
Area /3f$^ Sump 	 * I
' 	 / O O o
V ^QcvSy/ ^Lo o° <; 	 Tank storase
^^ ^*^0 /« Qo O of solvent
X. and still
f •"• -NV,,^ >v bottoms
" / ^s. \, (diked)
/ JL ^\. ^\
I vi 1 \ Tank storage of
I myl \ recovered solvent
1 Pond \ J~~\ (diked)
W
k 2
o
S
H
t §
H
•^
M
1
Figure IB. Site Plan of Chemical |
Recovery Systems, Inc. »
"^This pond was removed early in 1983, subsequent to
preparation of this project. ,
















6-4
-------
 sand  is  a  layer  of very  stiff  clay.   The  thickness  of this
 clay  layer was not determined:   however,  the  existing data
 show  that   it extends  to at least  10 feet (3 m) in  depth
 beneath  the deepest portion of  the  sand  layer.  Data was
 not available on the geology below  the  clay layer.

      The  sand  layer  was  determined  to  have  an  average
 hydraulic^ conductivity  of  30  gallons  per day per  square
 foot  (1,222 1/day/nr3)  and an average downward  gradient  of
 0.006 running  east to  southeast.   Using  these  estimates,
 the  average velocity  of  groundwater  moving  through  the
 site  toward Trouton Drain was  calculated  at 0.12  feet (3.6
 cm) per  day.
 WASTE  DISPOSAL  HISTORY

     Prior  to I960,  the  site was  owned  by the  Sinclair  Oil
 Company.    It  was  then  purchased  by   the  Cam  Chemical
 Company  who used  the  site to recover  waste  solvents  for
 resale as  lacquer  thinners,  resins,  driers,  and  paint
 additives.   At  first,  the  still  bottoms  from  this
 operation  were   pumped  into 55-gallon  (208  1)  drums  and
 stored on  site.   A few years later,  after about 45,000
 drums  had  accumulated  on site,  Cam  Chemical   excavated
 three  unlined  trenches, each  with a  capacity of  450,000
 gallons  (1.7 x  10  1)  ,   and  began using  them to  store
 still  bottoms  and  other   unrecoverable  wastes.    These
 trenches  overflowed in  the late 1960s  to form  one  large
 pond which  is shown in  Figure 1 as  the  vinyl  pond.   In
 1969,  Cam  Chemical purchased  a Franklin  incinerator  in  an
 attempt to  reduce  the  volume  of still bottoms on  site  and
 to bring in more business  from the surrounding industries.
 The  incinerator  proved incapable  of  burning  the  still
 bottoms at  a fast  enough rate and, as a  result, between  60
 and 70 thousand more drums of waste  were brought on site
 for which Cam chemical did  not have an  economical means  of
 disposal.   Now  in  financial difficulty, Cam Chemical sold
 the  site  in early 1971  to Product  Sol Corporation  which
 provided the capital to  construct four lagoons lined with
 2 feet (0.6 m) of  "blue clay" and ranging  in capacity from
 500,000 to 2,000,000 gallons (1,89 x 106  to 7.57  x 106 1).
 These  lagoons,  completed in the  summer  of 1971, were all
 constructed  along  the  eastern boundary of  the property
 less than 50  feet  (15  m)  from Trouton  Drain.   One of the
 lagoons  was  filled  with  an off-specificat ion  grease
 compound from  a local  chemical  company,  two  others  were
 filled with still  bottoms,  and  the  fourth contained waste
 oils.   At  the   end  of  1971,  the  site  was  sold  to its
 present owners,  Chemical  Recovery Systems,  Inc.   Since
 that time,  CRSI  has removed over 100,000 of the drums left
by the previous owners, drained  and  filled  in  the  four

                                     6-5
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clay-lined lagoons,  installed  and  replaced an underdrain-
age system, and constructed a slurry wall around the down-
gradient  side  of  the  site.   There  are  currently  about
6,000 drums on the site.   Wastes were  removed from from a
large  vinyl  pond which  contained  approximately  15,300
cubic  yards (11,670  m )  of  hazardous  wastes,  early  in
1983.   However,  this  remedial  action was undertaken after
the  research  for this  case  study  was completed  and will
therefore not be discussed further.
DESCRIPTION OF CONTAMINATION

     The  earliest documentation  of contamination  at the
CRSI  site  occurred  in  August  of  1970.  The  Michigan
Department of Natural Resources took numerous ground water
and surface  water samples around   the site in response to
odor complaints  lodged  by nearby residents.   The  results
of  the  sampling  showed high  levels of phenol, chlorides,
and chloroform   in  both  the ground  water and water  and
sediment  samples  taken  from Trouton Drain.  In some areas,
levels of chloroform, phenol,  and chlorides in the ground
water exceeded 200, 18, and 1500 mg/1, respectively.

     By  the  summer of  1978, a  special  task force made up
of  various  State officials  identified  the  presence of
eight  chemical  contaminants  in  Trouton  Drain and in an
interceptor  trench which was  installed  during the summer
of  1976.    These  chemicals   included  benzene,   toluene,
xylene,  dichloroethane, dichloromethane,  trichloroethane,
trichloroethylene,  and  phenol.   The vinyl  pond  was  also
sampled  and  was  found  to contain dichloromethane,  dichlo-
roethane, trichloroethane, toluene,  and  perchloroethane.
Table  1  provides characterizations of the  chemicals  found
in  and around  the Chemical Recovery Systems,  Inc.,  site.

     Additional  chemical  pollutants were  not  discovered  at
the site until  a June,  1982,  lab report  revealed  pockets
of  high  PCB concentrations within the  vinyl  pond.   The
pond  sampling was done by setting  up  a grid system  of  24
sampling points  across  the pond and taking core  samples  at
from 0 to 4  feet (0  to  1.2 m)  and from 4  to 8 feet (1.2  to
2.4 m)  at  each  point.   Although  most  of the 48  samples
taken  within the pond  showed  PCB  levels  below  regulated
concentrations,   11  of  the samples had  concentrations  of
PCB's  between 51 and 175  mg/kg.
300.64U)
preliminary
assessment
300.68(e)(3)(i)
water pollution
                                      6-6
-------
             TABLE 1:  CHARACTERIZATIONS OF THE CHEMICALS FOUND IN
                           AND AROUND THE CRSI SITE
                          (from data compiled by Che
                 Michigan Office of Toxic Materials Control).
Chemical Name
1,2 Dichloroethane
1,1 Dichloroethane
Dichloromethane
Vinyl Chloride*
Trichloroethylene**
Perchloroethylene**
1,1,1 Trichloroethane
Benzene***
Toluene
Xylene
Pheno 1
Solubility in
Water (mg/1 @ 20°C)
8,700
5,000
20,000
1.1 (25'C)
1,070
150 (25°C)
4,400
800
515
175
82,000 (IS'C)
Relative Acute Oral
Toxicity to Mammals
moderate
slight
slight
slight to
moderate
slight
slight
slight
s 1 ight
slight
slight
moderate
*   Proven human carcinogen
**  Proven carcinogen to laboratory mice
***  Suspected human carcinogen
                                   6-7
-------
PLANNING THE SITE RESPONSE
Initiation of Response

     Early response efforts by CRSI were  prompted by com-
plaints  from  nearby  residents.  As  early  as 1970, the
Michigan . Department of Natural  Resources (DNR) responded
to resident's complaints about odors from Trouton Drain by
taking  samples  of ground water  and surface  water  around
the site.  Ground  water samples  from below  the site and
sediment samples from Trouton Drain  showed high levels of
phenol, chlorides and chloroform.  The rupture of 2 waste-
filled  lagoons  in the winter  of  1972 further contaminated
Trouton Drain, triggering more complaints by residents and
more  sampling  by  the  state.  Pursuant  to an agreement
between the  state  and  CRSI  in  1973, the company began
removing  the  4  clay-lined  lagoons.   The  parties also
agreed  that CRSI would begin removing drums.  To  control
seepage  of contaminated  ground water into Trouton Drain,
CRSI  hived Keck  Consultants  to design an  underdrainage
system.  This was  installed  in 1976.  In  1977, the state
dredged  part of Trouton Drain  to remove contaminated and
odorous sediments.

     Public pressure to clean up the site increased during
1977-1979,  leading  to  a   public  meeting  between  local
residents,  CRSI personnel  and DNR officials and  the
appointment of  a  special  task force of state officials to
investigate  the  site  and  make  recommendations.   During
1978 and 1979,  the state continued to  install ground water
monitoring  wells  and  take  soil samples  from  the site,
adjacent  property,  and  Trouton Drain.   CRSI continued to
remove  drums.

     In August   1979, the  state   filed  a   civil  action
against CRSI,  alleging  violation  of  the  state  Water
Resources Commission Act.   CRSI  filed  a countersuit alleg-
ing  that it had  already  taken  extensive and  responsible
clean-up  efforts  on property that  was contaminated  when
purchased.  While  these   suits  were pending, CRSI  and the
state  studied alternative  remedial  actions  and  continued
their   sampling  to  determine   the  nature   and extent of
contamination.   In   February   1980,   the   state  and   CRSI
settled  their  lawsuits by a  Consent Agreement  that stated
the  specific remedial actions  that CRSI would  undertake,
at its  own  cost.

     Primary remedial  technology  specified  in   the agree-
ment  included  construction of a  slurry wall  to  contain all
wastes  migrating off the  site and  installation  of a second
underdrain  system  to  collect  contaminated  ground  water
on-site.    Secondary  or  complementary  remedial  actions
300.63(a)(4)
observation by
public
300.64(a)
preliminary
assessment
300.68(e)(l)(iv)
hazardous sub-
stances above
surface and in
drums

300.68(e)(2)
(i)(D) hydrogeo-
logical factors
 300.68(c)
 judicial process

 300.68(g)
 development  of
 alternatives

 300.68(c)
 private funding
 300.68(e)(2)
 source control
                                      6-8
-------
 required  under the Consent  Agreement  included removal  of
 6,000  remaining drums of  on-site waste;  removal and  proper
 disposal  of approximately   33,000 cubic yards (25,230 m )
 of  contaminated   soils  and   sludges  from the  remaining two
 waste  ponds;  removal of  hot  spots  of top  soil located  on
 the property;  backfilling of   excavated areas  with clean
 fill;  and  restoration  of the  proper grade  and  reseeding
 of   the   surface  to  control run-off.  When CRSI  completed
 construction of  the  slurry wall and underdrain,  the state
 agreed to  dredge  Trouton  Drain  again  and CRSI   would
 reimburse $10,000  of the  state's costs.

 Selection of Response Technologies

     Numerous  remedial  actions  have  been selected and used
 to  control  pollution  at  the   Chemical  Recovery  Systems,
 Inc. site.  These  actions have  included:

     • Removal of four clay-lined  lagoons  in 1974 and

     • Dredging  of Trouton  Drain  in  1977  and  again  in
        1980

     • Installation of two  underdrains to interrupt con-
        taminated  ground  water—one  in 1976  and  the other
        in  1980 after the first one  failed

     • Removal of over 100,000 drums since 1972  hazardous

     • Installation of a vibrating  beam type slurry wall
        in  1980.

 The selections of these methods have occurred without the
 benefit of  any thorough feasibility  analyses  and  have been
 initiated by both  the State  and CRSI.   The removal  of the
 four lagoons was the result of  an agreement in May of 1973
 between  CRSI  and the  State.    This   decision   was made
 because the ponds  had previously ruptured and continued  to
 pose a threat  to Trouton  drain.  The exact  manner in which
 they  were  removed was  negotiated  between CRSI  and the
 state.

     The dredging  of Trouton Drain in 1977  and in 1980 was
 recommended  by State  Officials.    These   recommendations
were  made  in  response  to  accumulations   of odoriferous
materials in the slow-moving drain.

     The first underdrain was  installed  under a  recommen-
dation by an engineering  consulting  firm.   This underdrain
system was  removed and  replaced  after  a series  of   tests
 showed that  it had failed and  was  no  longer intercepting
the contaminated ground water from the site.

                                     6-9
300.68(e)(l)(iv)
hazardous sub-
stances in drums
300.68(e)(l)(v)
highly contam-
inated soils at
or near surface
-------
     The  decision  to  remove  drums   from  the  site  was
reached mutually by the State  and  CRSI.   The  deteriorated
condition of the drums and the resulting leakage and fumes
were undesirable to both parties.

     The slurry wall  resulted  from independent efforts by
CRSI to  find the most  effective  method of preventing con-
taminated ground water from  entering  Trouton  Drain.  CRSI
management had  already made  some of  the  initial contacts
with the  contractors  that  installed the slurry wall prior
to  suggesting  this  method  to the  State.   After reviewing
the  specifications  for the  slurry  wall,  the  State incor-
porated  them  into  the Consent Agreement  which was signed
between  the two parties in May of 1980.

Extent of Response

     Since  the  Consent  Agreement  between CRSI and   the
state  established  specific   remedial actions  for  CRSI to
perform,  some   of   the company's   response  efforts  have
ceased  with  the completion of the required actions, e.g.,
construction of the slurry wall  and new underdrain  system.
Not  all  of  the required actions had been completed by  the
time research  for this  case  study  was  concluded;   for
example,  the vinyl  pond has  not  been  removed as of  October
1982,  and about 6,000  drums  remain on-site.    However, ^it
can be expected that  response actions at this  site, with
the exception  of  ongoing monitoring and maintenance of  the
underdrain  system, will cease when the  actions  specified
in the  Consent Agreement  are completed.
300.68(j)
extent of
remedy
 DESIGN AND EXECUTION OF SITE RESPONSE

      Each  of  the   actions  performed  at  the  CRSI  site
 required different  equipment  and techniques.   Therefore,
 each  different  type  of  action  is  discussed  under  a
 separate subheading below.

 Removal of Four Clay-Lined Lagoons

      This action was  begun in May of 1974 and all but one
 lagoon were removed within 5 months.  The remaining lagoon
 was not  removed until 1980.  The reason for the long time
 period needed  to complete this  action was mainly related
 to  CRSIfs inability to pay the associated disposal costs.

      In carrying out this action, all  liquids were pumped
 out of the  ponds into  tank trucks  and sent off-site for
 incineration.  The  solids in the bottoms of the ponds were
 300.68(e)(l)(v)
 highly contami-
 nated soils at
 or near the
 surface

 300.70(c)(2)(l)
 excavation
                                      6-10
-------
 excavated  and  mixed on the ground with lime using  a back-
 hoe;   then  transported   in   dump  trucks  for disposal  at  a
 nearby  landfill.   The   purpose of the  lime mixture was to
 solidify the   semi-solid portions  of  the  dredged  materials
 and  to create  heat  for   volatilizing  some of  the organics
 in  the wastes.  Although the pond dredgings were  slightly
 acidic,  they  were  not  considered to be  a RCRA  corrosive
 waste, thus  neutralization was  not a primary objective of
 the  lime additions.  The lime mixing  process was  continued
 until  the  pond dredgings were of  adequate consistency to
 be  loaded  into a dump truck.

 Trouton Drain  Dredging

     Trouton Drain  was   dredged first in  1977  and again in
 the  fall  of   1980.  The first dredging was done  by a  pri-
 vate   contractor  under   contract  with   the   Wayne County
 Department  of Public  Works.  Records were  not  available
 from either  party  on  the equipment  and methods used to
 accomplish this first dredging.

     The  second  dredging  was  done  by Inland  Waters
 Pollution  Control,   Inc. under  contract  to  the  Michigan
 Department of Natural Resources.   Using a  "Gradall-600"
 and  a  dump truck,  1 foot  (0.3 m)  of sediment was  scraped
 from the bottom and from  the sides of the  drain  along  a
 1700-foot  (518 m),  continuous  segment  between  Van  Born
 Road  and  Joan Street.    The drain  sediments  that   were
 removed  were  replaced with  a mixture  of fresh  sand and
 gravel.   A  total  of 400  cubic  yards  (306  m )  of drain
 sediments were replaced  and the dredgings were piled along
 the  drain  to decant the  excess moisture.   They were  then
 loaded  on  the dump  truck  and   landfilled.   The entire
 operation  took about one month to  complete.

 Underdrain Installation

     The   first  underdrain system consisted  of  a 4-inch
 (10 cm) diameter, corrugated  plastic tube running  approxi-
mately 1,000 feet (305 m) in  a north/south direction.  The
 trench for this drain was excavated with a backhoe  approx-
 imately  60 feet  (18 m)  away  from the  Trouton Drain,  and
was backfilled—first with 6  inches  (15 cm)  of pea gravel
 surrounding the drain pipe and then with native materials.
The underdrain was  placed  just above  the  clay layer, how-
ever,  it did not  penetrate the  underlying clay  over  its
entire  length.  Thus,  a  portion of the ground water con-
tinued  to  flow in  the sand  layer beneath the underdrain
and  into Trouton  Drain.    Another problem with  the first
underdrain  was the  specified minimum thickness of 6 inches
(15  cm)  for  the pea  gravel.    This  thickness   was  not
300.70(c)(l)
off-site
transport for
destruction
300.70(c)(2)
removal of con-
taminated soils
and sediments
300.70(b)(l)
(iii)(D)(l) sub-
surface drains
                                     6-11
-------
sufficient in preventing  siltation and rapid  blockage  of
the drain slots  in the pipe.

     The  installation  of  the new  underdrain  system  took
approximately two months to complete (February to March  of
1981).  Although it has almost identical specifications  to
the first underdrain (Figure 2), a 6-inch (15 cm) diameter
pipe was  used instead of  the  previous  4-inch (10 cm)  pipe
and more  care was  used  in the  placement  of  the new drain
such that  it  would  be set into  the  clay layer  at  0.5  to
0.3 percent downward slope toward the new 96-inch (244 cm)
diameter  concrete   sump.    The   thickness of  pea  gravel
around the drain pipe was increased to a minimum of 3 feet
(0.9 cm) to prevent the clogging problems experienced with
the earlier drain.  The new  sump was constructed of steel
reinforced concrete  with  a 6 foot  (1.8 m)  drop from the
invert drains to the  sump floor.  The contaminated ground
water  entering this sump  is  pumped  with  a  portable
submersible pump to the Detroit sewer  system at a rate  of
between 700 and 4,000 gallons (2,650 to 15,142 1) per day
depending  on the  amount  of rainfall.    The  city takes
monthly grab and composite samples of these discharges and
analyzes  them  for  phenolics  and  for   several  standard
wastewater parameters including pH,  BOD,  COD,  metals, oil
and  grease,  and suspended  solids.   The  results of these
analyses  are  similar to  the  results  of  previous ground-
water samples taken at the site.

Drum Removal

     The  types of wastes  contained in  the  drums  are still
bottoms   from  past   solvent  recovery  operations.  These
still  bottoms  are   composed   of  particulate   matter and
mixed  with varying proportions  of halogenated  and non-
halogenated solvents.   Because  these wastes are  generally
consistent  between different  drums   only  occasional
analyses  are  performed  on them  and  significant  deviations
have  not  been observed.

      Prior to 1978  drum disposal was accomplished by load-
ing  the drums on a  trailer and  hauling  them  to  the  nearest
acceptable landfill.  By  1978   this  method  became  prohib-
itively   expensive   and   was  replaced  by   the   following
procedures:

      •   Remove  the  head of  the  drum

      •   Pump  any   liquids  from  drums  into  tankers   for
         transport  to nearby cement  kilns and steel mills
         for use  as  secondary  fue1s
300.68(e)(l)(iv)
hazardous sub-
stances in soil
300.70(c)
off-site
transport for
disposition
                                      6-12
-------
   Figure 2.  Cross-Section and Site-view of the  New Underdrain


              System at Chemical Recovery Systems,  Inc.
ifi®i§t
£gvyi>~:'"t
                                 ^:'f^'-" Backfill with Native

                                ili^rr*^ Material
                                i'.V'Vsi^rr" Native "Haterial
                                       Pea Gravel C3-fooc radius

                                       surrounding drain)
LAYER
                     t
                                        Sump.
                          ,740*
                                                         •250'
                  North
                            6-13
-------
     •  Punch four equally  spaced holes down  the  side of
        the drum to allow any free liquids to drain out

     •  Remove  solids  for treatment  with lime  and  land-
        filling at Belleville

     •  Crush the empty drum and  treat  with  lime prior to
        landfilling at Belleville.

     The free  liquids  draining  from the holes  punched in
the drums  are  mixed with  lime in  a 8  by 50  by 3 foot
(2.4 by  15 by 0.9 m)  ramped concrete  pit using  a  bull-
dozer.   The mixed wastes  are  disposed at  the Belleville
landfill.  The  reasons  foe. lime  treating  the contaminated
liquids  and  solids  are  to solidify   the  wastes and  to
volatilize the  organics with the heat  generated  from the
reaction between  the  slightly acidic  wastes  and the lime.
Lime addition  and mixing  are terminated when  a dirt-like
consistency is attained.

Slurry Wall

     The initial  contact with the Slurry  Systems Division
of Thatcher Engineering  Corporation, was made by the CRSI
officials.  Slurry  Systems then  requested  CRSI  to send
them  samples   from  the  two   remaining  on-site  ponds.
Slurry Systems tested the samples against different slurry
mixtures including bentonite-cement, bentonite-flyash, and
kaolin  in various  proportions.    The  tests  consisted of
falling head permeabilities using a 12  by 16-inch (30.5 by
40.6 cm)  lucite cylinder  in which  1.5  inches  (3.8 cm) of
slurry mixture  were  placed beneath 1  foot  (0.3 m) of the
polluted pond  liquor.   None of  the  slurry mixtures main-
tained  structural integrity for  more  than a  few days of
exposure to  the CRSI sample.  Finally, a relatively new,
asphaltic  slurry called  "ASPEMIX"  was  tested.   This
formulation  consists  of an  asphalt  emulation, fine sand,
cement,  and  water.    After  seven days  of  testing,  the
average permeability of the  slurry was  3.22 x  10-  cm/sec.
This  average  permeability was  determined  in accordance
with  U.S.  Corps  of  Engineers engineering  manual 1110-2-
1906;  page VII-3.   The results  of  this  testing prompted
Slurry  Systems  to  recommend  "ASPEMIX11  for  use  in  the
construction of the slurry wall  at  CRSI.

     The State  DNR accepted the proposal  for  an "ASPEMIX"
slurry wall  to be used in conjunction  with the underdrain
system  to  contain ground  water  seepage  into  the Trouton
Drain.   The  bottom  of the  wall was  keyed  into the  clay
layer  underlying  the sand at an  average  depth of 10  feet
(3  m).    The top  of  the  wall,  which can be  seen at the
ground  surface, extends 65  feet  (20  m) from east to  west

                                      6-14
300.70(b)(l)
impermeable
barrier
-------
 at  the  northern end of the property, then turns  south  for
 approximately 1,000 feet (305 m)  before turning west  for
 400 feet  (122 m)  (Figure  3).   The  installation was  done by
 the vibrating  beam method  in  which  a large  I-beam is
 literally vibrated  with  sufficient  intensity  that it  works
 its way  into  the   soil.    After   the   required  depth is
 reached,  the  beam is withdrawn at  a rate of about 3 meters
 per minute  as slurry is  pumped at  75  to 125  psi into  the
 hole through  nozzles at  the base  of the beam (Figure  4).
 At  the  Romulus site,  a  40-ton (36 MT)  crane was  used to
 suspend  a 7  ton  (6.3  MT)  beam and vibrator  unit over  the
 work area.    The vibrator  was  a   single,  275  horsepower
 motor of  French design.   Each  injection is overlapped with
 the previous  one by a margin  equal to  10  percent  of  the
 total beam  depth.   The length  of each  injection  is  a  total
 of  47  inches   (119  cm) including the 14-inch  (36 cm) beam
 fin (Figure  5).   The vertical  straightness  of  each beam
 injection is  controlled  by  guide   leads which maintain  a
 vertical  plane  within  a tolerance  of  1  percent.    The
 thickness of  the  wall  varies between 4  and 6  inches (10 to
 15  cm)  depending on the size of  the  interstices  between
 the soil  surrounding the  hole.

     The  total time needed to construct the  wall  at CRSI
 was about  1  month   and  the  construction was complete in
 June of  1980.  The  wall  would have been completed  earlier
 but a pump  used to  blend the asphalt slurry  broke, taking
 two weeks for replacement.
COST AND FUNDING

Source of Funding

     Most of  the remedial work was  funded by  CRSI  pursuant     300.68(c)
to an agreement  negotiated  between  the  company and  the     private  funding
state  in  1973, as  well  as  a Consent  Agreement signed by
the parties  in 1980 that settled  their lawsuits over  the
clean-up.   In addition,  the City of  Romulus  paid for  the
first  dredging of Trouton  Drain  in  1977.    The second
dredging was  paid  for solely by the Michigan  DNR.

Selection of  Contractors

Keck Consultants
     Keck   Consultants,  of   Lansing,   Michigan,   was
originally hired  by CRSI to  design  the  first underdrain
system.   This firm was  hired based  on reputation  and a
lump  sum  contract  was  used.    CRSI did  the  construction
work.    When  the system  failed,  CRSI hired Keck again to
design  a  more extensive  system  because  that  firm  was
                                     6-15
-------
                                    task storage
                                    of
                                    fMdstoek
                                    end still
                              Tank srorax* of
                                      soiranr
                              (dllwd)
Figure 3.  Location of  the Slurry Wall    z
            at Chemical  Recovery            3
            Systems, Inc.                     « I
           pond was removed early in 1983, subsequent to
      preparation of this project.
                    6-16
-------
Figure 4.  Placement  of a Slurry Wall Using the Vibrating Beam Method.
 SLURRY
  MIXER
Vibrator
Slurry Injecting Nozzles
      at Beam Bottom
                        SANDY SOIL

                    CLAY" (Impervious Zone) $
                                  6-17
-------
      Figure 5.  Schematic Diagram of the  Ground Surface After  Four Overlapping Injections Using the

                 Vibrating Beam (Cross-Hatched Area Denotes  Outline Made by Injection  #4)
I
t-1
QO
                                                                Fin
Beam

_ 33"
                                            Direction of movement
-------
familiar with the site.   CRSI did the construction work on
this systems also.

Slurry Systems
     Slurry Systems, of Gary, Indiana, was hired on a lump
sum  contract  to  design  and   install  the  slurry  wall.
Slurry Systems was hired primarily because of  its asphal-
tic slurry.   In  addition,  this  company  offered a two-year
guarantee on the wall.

Project Costs

     The  total  cost  of remedial  action  related  to  the
Chemical  Recovery  site  has  been  approximately  $1.4
million,  funded  by state,  municipal  and  private sources.
Of  this  amount  Chemical  Recovery has incurred  most of the
cost.   The Michigan  DNR has spent  approximately $14,000
plus  an  unaccounted for dollar  amount  of man  hours.  The
City of  Romulus  has spent  approximately $50,000.  The cost
data  are summarized in Table 2.   The costs  of particular
remedial  actions are discussed below.

Removal  of  Four  Clay-Lined Lagoons
     The  cost of  removing four of  the  five  waste ponds
 located  on the site was approximately $450,000.  Chemical
Recovery financed the entire  amount, including  disposing
of  over  100,000  gallons   (378,500   1)  of  liquid  waste.
Disposal costs  ranged  from 3  to 4  times the  costs of labor
 and equipment.

Trouton  Drain Dredging
      The Michigan DNR dredged the  Troutoa Drain in  1980  at
 a total  cost of $23,870.   The originally  estimated  cost  of
 dredging the drain was  $10,000;  however, this  figure  was
based  on  what   proved  to  be an underestimated  amount  of
 contaminated  sediment.    DNR  assumed  the   cost  of  the
 $13,870  overrun and Chemical Recovery funded the remaining
 $10,000.  The City of  Romulus  had previously  dredged  the
 drain in  1977  along and  south of the site at  a  cost  of
 approximately $50,000.   CRSI paid  for approximately $6,000
 of the  first dredging but refused further payment  because
 they  felt that  the  job  was  not being  performed  properly.
 The total  cost  of dredging  the Trouton  Drain,  then,  was
 $73,870.

 Underdrain Installation
      The original  underdrainage  system  has  designed  and
 installed in 1976 for a total cost of $6,000.   This system
 failed and, in 1980, a new intercepter drain was installed
 for  a  total cost  of  $65,540.    The  Consent  Agreement
300.62(a)
state role
                                      6-19
-------
                         TABLE 2.  SUMMARY OF COST INFORMATION CHEMICAL RECOVERY SYSTEMS, INC
-»—.l2"k .
1. Lagoon removal
2. Trouton Drain
dredging
a. 1977
b. 1980
3. Underdrain
a. 1976
b. I960 desing
c. 1980
installation
4. Drum removal
5, Sl-irry Wall
TOTAL
^Quantit^





10,000
drums


Estimated
Expenditure

$10,000
$6,000
$30,000
$35,540

$83,000
$164, 540
Act un 1
Expenditure
$450,000
$50,000
$23,870
$6,000
$30,000
$35,540
$750,000
$83,000
$1,428,410
Variance

$13,870
0
0
0


$1,263,870
<«« ^S*








Estimated
Future Cost
$1,000.000







$1,000,000
Funding
Source
CRSI
Romulus
CRSI
($10,000)
and DNR
($13,870)
CRSI
CRSI
CRSI
CRSI
CRSI

Period of
Performance
6 yrs and
ongoing
3 mos.
1 mo.
6 wks.
2 mos.
1 mo.
8 yrs. and
ongoing
2 mos.

I
rsj
O
-------
 required that the drainage system be designed  by an engi-
 neering  firm.   The  actual construction  of the  drainage
 system was undertaken by Chemical Recovery personnel.

      Chemical Recovery  hired  Keck  Consultants  to  design
 the  system  through   direct  procurement  on  a  lump  sum
 contract  in  1980.    The cost  of designing the  drainage
 system was set at  $30,000.  Keck Consultants completed the
 design and  it  was  approved by  DNR  without incurring  any
 cost overruns.   The   construction of  the drainage  system
 was undertaken by Chemical Recovery during July of  1980,
 immediately subsequent  to  the  construction of  the  slurry
 wall.  The cost  of construction was  approximately $35,540,
 bringing the total  cost  of  the  drainage  system  to $65,540.
 It is not  possible to break  down the  cost  estimates  into
 labor and materials.

 Drum Removal
      Removal  and  disposal  of  approximately  95,000   55-
 gallon drums  of  hazardous  waste  from  1972-1980 has  cost
 approximately $750,000.   Chemical Recovery financed  all of
 the drum removal and  disposal  activities.  In  1972,  when
 the company first began  to remove the  drums, the cost  of
 diposal  per drum was  approximately $4 at  an  incinerator in
 Ohio.  By 1978 the cost  per drum had increased  to approxi-
 mately $25-30.  At that time,  Chemical  Recovery began  to
 dispose  of the drums  by collecting  the  wastes in  tanker
 trucks.    The cost  for  bulk  disposal  was approximately
 30-40 cents per .gallon ($0.08 -  $0.10/1)  or  $16  to $22  per
 drum,  at a landfill  in  Belleville,  Michigan.   The empty
 drums were crushed on-site and  also disposed  of in  that
 landfill.

 Slurry Wall
      The  slurry wall  was installed  in  1980 for  a total
 cost  of  $83,000.   The cost per  square  foot was approxi-
 mately  $2.50 ($26.91/m2).    Slurry  Systems  of  Gary,
 Indiana,  a subsidiary  firm of  Thatcher  Industries Inc.,
 signed^a  lump  sum  contract  with Chemical Recovery in 1980
 and finished two  weeks after the  estimated date of
 completion.  The two  week overrun resulted from a failure
 in  the pump used to mix  the asphalt slurry mix.   There was
 not cost overrun.
PERFORMANCE EVALUATION

     The previous  sections  of this report  have described
five types of remedial actions used at  the  CRSI site.   Of
these five, the two underdrain systems and the slurry wall
are the only remedial actions for which performance evalu-
ation data  have been  collected.   Therefore,  evaluations

                                     6-21
-------
are not  provided  for  the  pond removals, drum  processing
activities, and drain dredgings.  It  is  assumed,  however,
that  these activities  were  properly performed  and  the
disposal  of the  wastes  from  these  operations  did  not
seriously contaminate any off-site areas.  The evaluations
of the  two  underdrains and the slurry wall  are discussed
separately below.

Underdrains

     The  failure  of  the  first  underdrain  system  was
documented  in a 1980  survey of ground water elevations at
the CRSI  site.   This survey resulted  in the construction
of the  ground  water contour map  shown  in  Figure 6.   The
reasons  for failure  of the  first underdrain  have  been
given as (1) clogging because of an insufficient amount of
pea gravel  surrounding the drain pipe and (2) bypassing of
ground  water  beneath  the drain  because of inconsistent
contact  between  the  drain pipe  and  the underlying  clay
layer.

     Figure 7 shows  dramatic  changes  in  ground  water flow
patterns  at the site after installation  of  the new under-
drain and  the slurry wall.  However,  the validity of this
map  may be questioned  because two  of  the  ground  water
levels  on  which the  map is based  are  assumed, rather than
measured, values.  Of  these two values (i.e., 653.81 at MH
and 645.66  at  the underdrain  sump) the  sump elevation is
the most questionable.   This sump is not  perforated and
thus would  not drain all of the surrounding  soil.

     Regardless of the potential errors in Figure 7, the
new underdrain was designed  such  that is no longer under-
cut by  the bottom portion of  the  sand aquifer.  Further,
five times  more pea  gravel has been added around the drain
pipe  to  prevent  clogging  of  the  drain slots  with  fine
silt.   The entra  pea gravel has not been entirely sucess-
ful  as  evidenced  by an incident  of  clogging  in  the new
underdrain. This  problem apparently  was solved, however,
by backwashing the  underdrain  with the same jetting equip-
ment  as is used  to clear obstructed  sewer lines.    Since
this  incident has occurred,   periodic backwashing  of the
drain  has  become  a  routine  procedure.     Perhaps  a more
thorough evaluation of  alternative drain design (e.g.,  a
geo  texile envelop or  a different  size of gravel) may have
prevented the need for periodic backwashing of  the present
drain.

Slurry  Wall

     The  effectiveness of  the  slurry wall cannot be
assessed accurately due to an  insufficient  amount of data

                                      6-22
-------
Figure 6.  Groundwater  Flow Patterns at  Chemical Recovery  Systems,
            Inc.  Before  Installation of the Slurry Wall and the Second
            Underdrain.   (Elevation data  and diagram were provided
  	by  Keck Consulting Services.  Inc.^	
         Legend
       O Observation w*ll Locations
     ^	Direction of Grounewatw Plow
     .100— Grounawater Elevation Contour (retotfve)
      x  Surface-watw elevation
                                 6-23
-------
Figure 7:  Groundwater Flow Patterns at Chemical Recovery Systems,
           Inc. After Installation of the Slurry Wall and the Second
           Underdrain.  (Elevation Data and Diagram were Provided
           by Keck Consulting Services, Inc.)
                             6-24
-------
 (since the wall  and underdrain were  implaced,  only  four
 ground water  elevation surveys have been conducted at  the
 site,  one  of  which was  used  to draw  the  contour map  in
 Figure 7).  However, in looking  at  the  ground  water eleva-
 tions  shown in Figure  7,  there seems to be  an  unexpectedly
 high water level  at well  number  OW-8;  i.e.,  the ground
 water  levels   east  of  the underdrain  would  be expected  to
 be somewhat lower  than those at  a comparable distance  west
 of the drain.   Because there are  not  enough readings  on
 the present well and because there  are  not  enough  wells  to
 draw a reliable ground water  contour  map,  an explanation
 cannot be given for the high reading in well number OW-8.

     Although  it  is not possible  to  accurately  test  the
 effectiveness  of  the  slurry wall,  it   is likely  that  the
 wall is an effective barrier  to contaminated  ground water
 at  the CRSI   site.   This  assessment  is made after  con-
 sidering  the  permeability  tests performed  on the slurry
 mixture (using the actual ground water  from the  CRSI site)
 and the  carefully  controlled methods of  installing  the
 slurry wall.

 Conclusions
     The  preceding case history  illustrates the same  lack
 of  organized  planning  that has  been noted  in  other
 remedial  actions  across the country.   Without a  thorough
 feasibility   analysis,  it  is  impossible to  determine
 whether the most efficient and cost-effective methods  were
 used to control contamination  at the  CRSI  site.   Further,
 without a carefully planned testing method,  it  is impos-
 sible   to  determine  the  effectiveness  of  the  chosen
 remedial  action alternative after  it  was  installed.    It
 should  be noted that  the need  for such  planning  is  even
 more critical  when a new technology or a new application
 of an  old technology is being  considered.   For example,  in
 the  foregoing  case  study,  a  relatively new  method,  the
 vibrating  beam, was used to   install  an  asphaltic slurry
 wall.   The  beam method has  been  used  in the United States
 for  only 8  years and,  at  only  a  handful of  remedial action
 sites.  The asphaltic  slurry used at  GRSI has had an even
 shorter history of  application  at  remedial action sites.
 For  these  reasons,  more  water-level wells  should be
 installed and  monitored to  determine  the effectiveness of
 these  new  technologies.   Further,  the time  periods  for
 falling-head permeability tests,  which were  used to select
 the  asphalt  slurry,  should  be   lengthened to  determine
whether the slurry would continue to work  after years of
contract  with  contaminated  ground water  from  the  CRSI
 site.   In any  event, the  Michigan DNR  should be  contacted
by  US  EPA  to  obtain periodic  updates  on  any testing to
determine   the   effectiveness  of  the  slurry  wall  at  the
site.

                                     6-25
-------
                                 BIBLIOGRAPHY
Heimbuch, Joseph A.  February, Marcb, 1982.  Personal communications with
     G. Edmunds, ELI.  Chemical Recovery Systems, Inc., Romulus, Michigan.

Heimbuch, Joseph A.  July, August, September, 1982.  Personal communications
     with M. Evans, JRB Associates.  Chemical Recovery Systems, Inc., Romulus,
     Michigan.

Michigan Department of Natural Resources.  August, 1970 to July 1982.  File
     materials, Chemical Recovery Systems, Inc., Romulus, Michigan.
                                      6-26
-------
                              COLLEGE POINT SITE

                               QUEENS, NEW YORK
INTRODUCTION

     The  College  Point  Site  was  a lagoon  contaminated
with  polychlorinated biphenyl  (PCS)  located on  a   /2
acre (0.2 ha) of  land owned by  the City  of New York.   As
shown in Figures  1  and 2,  the site lies  in an industrial
environment  adjacent to Flushing  Bay within  a vacant
city-owned  lot  near 31st  Avenue  and  123rd  Street  in
College  Point,  Queens.    At  the  time  of  the   response
action  in 1980,  the lagoon contained a  4  inch (10  cm)
layer  of PCB  contaminated oil overlying approximately
318,000 gallons (1.2 x  10  1)  of waste water.   Prior  to
removal  in  1980,  the level of  PCB contamination in  the
oil  layer  was  measured  at  240  milligrams per   liter
(mg/D.

Background

     The  history  of  the  site was  not  a  subject  of
investigation by  those  involved   in  the 1980 clean-up,
and  therefore  little is  known  about  when,  how, and  by
whom  the  PCB  contaminated  oil  was  dumped  into  the
lagoon.   Official discovery of  the PCB  contaminated  oil
at the  site occurred in  May of  1978 when a United States
Coast   Guard  helicopter   pilot  flying   over  the   area
noticed a discoloration  on the  water  surface of  Flushing
Bay.  A Coast  Guard investigation  followed  to determine
the  source  of  the contamination and traced  the  spillage
to  oil  in  the  lagoon.    In order to  prevent further
discharge into Flushing  Bay, the  U.S  Coast Guard had the
City of New York  flush out the  storm  drain through  which
the  lagoon  oil  had travelled  to the bay.  The drain was
then  plugged  to  prevent future  run-off,  and the  Coast
Guard   terminated   its   involvement   based   on    its
determination that  the  lagoon  posed no  further  imminent
or substantial threat to navigable waters.
NCP
References
300.63(a)(4)
observation
by government
agency


300.65(b)(4)
defensive action;
source control

300.65(a)(3)
threat of
fire
                                      7-1
-------
Figure  1.  Site Locator Map- College Point, Queens, New York
                                         k 55S^j?^5Mfe4^&?fl ft
                         7-2
-------
     Figure 2.  Location Map of College Point Site, Queens, New York
                     14th Ave
                                20th Avenue
                                    FLUSHING
                                     AIRPORT
                28th Ave
CONCRETE
COMPANY
                                                 800
                                           0   400   1200
                    CONSTRUCTION
                    COMPANY
                                          SCALE IN FEET
FORMER
PCB-OIL
 POND
 SITE
                       COLLEGE POINT
                      INDUSTRIAL PARK
                               7-3
-------
                          "?*, "  "*  '"' —  '"-It" "•!
        s           ,c,
     .' 5=
   the  clean-up  feU  within  the     ;iew p
   Department  of Environmental Protection  (NYC  DEP)   which
   initiated response action  in April  1980.
   Synopsis of Site Response
  rh^,',      J 5>   198°   tne   mC   DEP   "ntracted  with
  Chemical    and    Environmental   Conservation    Systems
  International   Inc.  (CECOS)   of  Niagara  FaHs,  OT  to
  remove  and  dispose of  the PCS contaminated oil  waste
          T   PCB - Contaainated  -oil  and  sludge  at   the
        CECOS   V^;- , B6treen JUUe  "   and  N^e"b«  1.
               solld^d  and disposed of  the  PCB oil  and
       8,  1980 to November  3,  1980.  The  fly  ash/PCB oil
       *  f??riSed  2'124  tons  d.926 Mt)  or 77%  of the
  total  solid waste  taken  from the site.   The
      A total of 318,000  gallons  (1.2  x 106  1)  was  pumoed
 and treated by  filtration and settling on-site  to^wer
 its oil/grease concentration before disposal at  a  nearby
 New York Cxty sewage  treatment plant.  The lagoon, when
 emptied,   required  approximately 1   foot  (30.5 cm)  of
 scraping   to  reveal clean soil  beneath.    It  was then
 backfilled and graded.

 SITE DESCRIPTION

 Surface Characteristics

     The  College  Point  dump  site  is located  in  the
       ^Orou*h  °f  Nev York  C^y near 31st Avenue  and
       Street adjacent  to  the Flushing  Bay.    The  oil
 lagoon  is  situated  within a vacant,  V2  acre  (0.2  ha)
 lot  and  is bordered by  a concrete recycling company  on
 the  west   side   and Queens  Structures,  a  construction
 company, on  the  east side.  Just north of the  lagoon  is
a  dead  end  street that  is   used  as  a parking  lot
S inS^aVnVh! EaSt  Rlver  are both classified  ^
 SO  in the New  York State usage designation.   Class  SD
waters are  defined as;   "All  waters  not primarily  for
300.64(a)
preliminary
assessment

300.65(a)
risk to human
health or the
environment
                                     7-4
-------
recreational   purposes,   shellfish   culture   or   the
development  of fish life and because  of natural or man-
made  conditions  cannot  meet the  requirements  of  these
uses."

     The  average annual temperature is  54.3°F (12.4°C),    300.68(e)C2)
and  the average  daily  minimum and maximum temperatures    (1) (E)
are  47.4°F  (8.5°C)  and 61.1°F  (16.2°C)  respectively.    climate
Average  January  and July  temperatures,  which are  the
extremes  of the  monthly averages,  are  32.1°F (0.05°C)
and  76.7°F (24.8°C), respectively.   The  average  annual
precipitation  is 41.61  inches  (105.7  cm).    Winds  are
usually  out  of the  west northwest,  at  an average  speed
of 12.2 miles  (19.6  km)  per hour.

Hydrogeology

     No extensive hydrogeological  investigation has been
performed  a  the  College Point  dump  site.   The informa-
tion in  this section was drawn from a general 1968 U.S.
Geological Survey paper  and  maps  for Queens County, from
which a section is shown in Figures 3  and  4.

     The  site  is  located on recent artificial fill (AF)
probably  deposited   from  Flushing  Bay  in  the  early
1900's.     It   is   underlain   directly  by   primarily
undifferentiated  Pleistocene ground  moraine  (Qu)  to  a
depth of  about 50 feet  (13 m),  which holds a fluctuating
Upper Glacial  Aquifer with  a  salinity  of over 40  mg/1.
The fresh  ground  water  underlying the  site  is separated
from this Upper  Glacial Aquifer  by  a  150  foot (40  m)
thick clay member of the Raritan  formation  (Krc).   This
aquiclude  from the  Upper  Cretaceous  extends  from 50  -
200 feet  (13 - 53 m) deep and  slopes eastward toward the
Atlantic  Ocean   as   a   result   of Pleistocene  glacial
erosion.   Underlying  this   member at  the  site is  the
Lloyd sand member (Krl), which extends  from about  200 -
300  feet  (53  -   79  m)  deep overtop  of  the  Precambrian
bedrock.   This member  is  the  only  fresh water bearing
formation below  the  site.   The 40 mg/1  line  of the salt
wedge was  found  in this aquifer about one mile (0.6  km)
north of the site in 1968.

Upper Glacial Aquifer

     Below a thin skin  of  artificial  fill,  a  layer  of
ground moraine  deposits  extending to  about 50  feet  (13
m)  deep  contains the  uppermost  ground  water.    These
Pliestocene  deposits were laid  down  during the retreat
of  the  Wisconsinian  glaication about  9,000 years  ago.
It  consists  of   some  glacial  outwash  sand and gravel
deposits, but  mainly of ground moraine deposits at  the
site, which is north of  the terminal moraine.   This

                                     7-5
-------
  Figure 3.  Queens Surficial Deposit and  Section Locator-College Point Site
COLLEGE  POINT SITE
                                                                  __        Outcrop
                                                                Q) QJI Ctiiy member of Knritn* formation
                                      Public Supply Well in use  (1961)
                                      Public Supply or other high capacity
                                        Well in use after 1961
                                      Industrial,  institutional  or
                                        Observation Well
-------
                          Figure 4.   Geohydrologic Sections,  Queens  County, New York

           APPROXIMATE LOCATION
              COLLEGE  POINT
                   SITE
1200
                 Vertical Exaggeration X20
                                          P    I
5 miles
                                                   SCALE
              i u
              M «
              •I U
              O.V
                                                                                      ss
                                                                                      u u
Wisconsin         Qu
GlactatLon        Qc
(undifferentiated)

Gardlnera Clay     Qg

Janeco
Gravel           QJ

Magothy Formation  Kirnn
Hatawan Group

Clay Member       Krc

Lloyd Sand        Krl
member
                                                                                          Bedrock          p€
                                                                                Approximate position of the
                                                                                40 mg/1 chloride line

                                                                                      Water Table
-------
aquifer has  a porosity of  about  40%,  and a  coefficient
of permeability (rate of  flow water, in gallons per  day,
through one  square  foot  under a gradient  of 100%)  of
about 1,000 gallons/day/square foot (40,743 1 day/m ).

Raritan Clay

     This  clay  ember  of   the   Raritan   Formation   was
deposited during  the Upper Crataceous.   This member  is
composed of  clayl,  silty  clay and clayey  fine sand.   It
contains beds and  lenses of lignite, payrite and  sand
with local  occurrences  of  thin gravel  beds.  This  clay
forms a partial  aquielude which is poorly permeable  but
does not completely prevent downward vertical migration
of water.   It does confine  the Lloyd aquifer below.

Lloyd Sand

     This  member   of  the  Upper  Cretaceous   Raritan
Formation  is the  lowest  water bearing  formation below
the site and  the  lowest aquifer in Queens  County.  It is
confined   between   the   underlying  bedrock  and   the
overlying  poorly  permeable Raritan  Clay member.    The
Lloyd  aquifer  consists  of  beds  of  sand   and   gravel
intercollated with  beds  of clay and silt.   The sand  and
gravel  beds  commonly   contain  varying  amounts   of
interstitial  clay  and silt.   The  average  permeability of
the  aquifer  is   about   500  gallons/day/square   foot
(20,371/ 1  day/m ).   It  is composed  of   fine to  coarse
quartzose  sand,   and  small   to   medium   pebble   gravel
commonly containing much grayish white,   light gray  and
yellowish  interstitial   clay  and  silt.     Lignite   and
pyrete  occur widely throughout.   Development  of  this
aquifer  is  regulated  and  limited because  large with-
drawals  tend  to   induce  salt-water intrusions.   Below
this  aquifer  is  an unconformity with  the  Precambrian
bedrock of schists  and gneiss.

WASTE DISPOSAL HISTORY
     The NYC DEP officials  involved  in the  clean-up at
College Point reported  that they  knew nothing about the
history of the PCS  disposal at the lagoon.

DESCRIPTION  OF CONTAMINATION

     Although soil borings were  taken around the lagoon
immediately  before  and   after  the  removal   action,  lab
reports were not  available for this report.   The first
indication  of  the  PCB  contamination comes from a New    3Q0.64(a)
York State  Department  of Environmental Conservation (NYS    preliminary
DEC)   sample  taken  on  June  13,  1978  following  the    assessment
investigation into spillage  into Flushing Bay.   This
data  indicated a  PCB concentration  of  160  mg/1 in the

                                      7-8
-------
oil  layer  on top of  the  lagoon.   The next  sampling  was
performed  by U.S. EPA  Region II  on  April 10,  1980  and
revealed a PCB level  in the oil layer of 240 mg/1.

     The oil layer was  reported  to  be  an average of  4
inches  (10  cm)  thick across  the  surface  of the lagoon,
covering a surface area  of approximately 18,000  square
feet  (1672  m ).   Using  the  formula for volume,  this
yields  approximately  44,886  gallons   (169,894  1)   of
contaminated  oil  in  the  lagoon.   The contractor  found
that the level  of PCB contamination  dropped as  the pool
was  emptied,  which  was   attributed to   the  chemical
attraction between oil and PCB.

     Information  about  concentration levels  of PCB  in
the lagoon water  and  surrounding soils immediately prior
to removal could not be obtained.

PLANNING THE SITE RESPONSE

Initiation of Response

     The lagoon cought  fire in April 1980.  The NYC  DEP
initiated  the  removal  action because it  believed  that
the  lagoon  posed  a threat  of  future  fires as well as  a
threat  of  contaminated  air  emissions   caused  by  the
combustion of PCB contaminated oil.

     In  addition,  the  EPA  sampling  of April  10,  1980
revealed a  PCB  contamination level  of 240 mg/1  which
exceeded the limit of  50 ppm established by the  Toxic
Substances Control Act of 1976 (TSCA).

Selection of Response Technologies

     The range  of technological  responses for remedying
the threat  posed  by  the contaminated lagoon was limited
to the  necessary  pumping of  the oil  and water  from  the
lagoon,  treatment  of  each,   and  disposal.    Only  the
treatment  processes  chosen for  the  oil  and water  might
have allowed a variety of  options.   According to  the
CECOS contract,  the  detailed  plans  for  the removal  and
treatment of the  oil  and waste water were not specified
in  advance  but  were  to  be  determined  by  CECOS  and
submitted  for  approval  to U.S.   EPA, NYS  DEC,   and  NYC
DEP.    The  PCB  contaminated oil was  mixed with  fly  ash
before   disposal   to  comply   with   the   "non-flowing
consistency11  requirements   of  TSCA  for  landfilling.
While  the  oil  could  have  been  solidified  off-site,
generally,  it is  cheaper  to arrange for  a  solidification
process on-site.   The EPA specified  that  a  mixture of 5
parts  fly   ash  to   1  part  oil  would   be  acceptable.
Treatment of the  lagoon water was  necessary  to lower its
300.68(e)(2)
(i) 03)
amount and
form of substance
present
300.65(a)(3)
threat of
fire
300.6.8(h) (3)
acceptable
engineering
practices
                                      7-9
-------
oil/grease concentration  level to 30  mg/1,  as required
by EPA.   The method  chosen  to satisfy this requirement
involved the installation of filters in line between the
lagoon  and  the  holding  tanks.    In  general,  on-site
treatment  for  both  the  oil and  water was  chosen over
commercial pre-treatment  because  of  its  relative cost
effectiveness.

Extent of Response

     The NYC DEP sought  a  complete removal  of the PCS
contaminated wastes  from the  College  Point  site.   The
criteria   established  by  contract  was  for  complete
removal    of   all    PCS    contaminated   wastes   with
concentration  levels  of  50  ppm  or greater.    This
criteria was apparently  chosen by NYC DEP  in order  to
comply  with  the requirements  established by  the Toxic
Substances  Control   Act   of  1976  and  was  the primary
factor  that  determined the  extent to which the site was
cleaned up.  Correspondence  between the NYC DEP and EPA
indicates  that  sludge was removed down  to a level of 2
ppm  PCS contamination.   Data from soil  borings taken
after the  removal was not available.  However, the soil
was  removed  to  a level of  visual cleanliness  according
to  the  best professional  judgement  of  the  officials
involved in the clean-up.

     The  treatment  criteria established by  EPA for the
contaminated  water   also  determined  the   extent   of
response.  Treatment  of the  lagoon water was  required  in
order to  lower  its  oil/grease concentration level to  30
mg/1  before its disposal  in a  NYC   sewage  treatment
plant.    The  30 mg/1  standard  was  set  by  U.S.  EPA
specifically for the site.

     Funding problems were not a  limiting  constraint,  as
an  adequate  amount had been set  aside  by the NYC DEP,
not  to exceed  $1,878,285.    The  NYC   DEP   officials
described  the clean-up as complete.

DESIGN  AND EXECUTION OF SITE RESPONSE

     The  response action  conducted at the College Point
site from  July 23,  1980 to November  7, 1980  consisted  of
five  activities:  removal,  treatment,   transportation,
disposal,  and backfilling.

Removal

     The   surface  oil was  removed  from  the  lagoon  by
sequestering the oil  onto one  side of  the lagoon with  an
oil  boom and pumping the oil  into the mixing  pit  with a
2  inch  (5  cm)  trans-vac unit.   Small pockets of oil  that
                                      7-10
3QQ. 68(31
appropriate
extent of
remedy
30CU65(c)
completion
of immediate
removal
30(K70(c)(2)
(i) removal of
c ont aminated
soils and
sediments
-------
collected  on the shore  of  the lagoon were  removed  with
absorbent  pads.    In  addition  to  the  oil  and  lagoon
water,  some of  the surrounding rock,  soil, and  debris
were  also  removed  in  order to gain safe access  to  the
lagoon.   There  was also  a small  island  in the  lagoon
that  required removal  prior to use of the oil boom.   The
daily  site  reports  indicate a total  of 231  truckloads
(2,772  tons/2514 Mt)  left the  site and  went  to  the
landfill.   Assuming 12  tons  (11  Mt) per truckload,  the
solid  waste  that  left   the  site  can  be  broken  down
roughly  into   54   truckloads   (648  tons/588  Mt)   of
contaminated  soil,  sludge,  debris  and  rock  and   177
truckloads  (2124 tons/1926  Mt)  of  solidified soil  and
fly ash.

     Water  was  pumped  from  the   lagoon  into  portable
treatment  tanks erected  adjacent   to  the lagoon, using
transvac pumping  system.   Daily site reports  indicate a
total of 53  truckloads of lagoon water left  the site for
Tollman Island  Sewage  Treatment Plant.   At 6,000  gallons
(22,710  1)  per truckload,  the  total   amount  of water
removed from the  lagoon  totalled to 318,000  gallons  (1.2
x 10b 1).

Solidification

     The treatment  process  for the PCS  contaminated  oil
involved pumping the  oil  onto  piles of fly  ash in  a
mixing pit dug  just  south of the lagoon.  The liquid was
mixed  using  a  backhoe.     The   mixture  was   tested
periodically at the site by  compaction  to test  for  any
free  oil that  might escape during  transportation  to  the
landfill.   The minimum  ratio established by EPA was  5
parts fly  ash  to  1  part  oil,  however batch samples taken
from  truckloads of  stabilized  waste mixed between  July
28 and August  4, 1980 were analyzed by  DEP's  Industrial
Waste Division  and  showed  an  average ratio of 99 parts
fly ash to 1 part oil.

Water Treatment

     The   treatment   process  chosen   to   lower   the
oil/grease concentration  level  in  the lagoon water to 30
mg/1  involved  the  installation of  two 55 gallon  (208 1)
drum/filters in line between the  lagoon  and  the  holding
tanks.   The waste  water was  allowed to  settle  for 24
hours to precipitate out contaminated solids.  When  the
tanks  were   full,   random  samples  were   taken   for
oil/grease concentration  levels.   If under  30  mg/1,  the
water was  then  pumped into 6,000  gallon  (22,710  1)  tank
trucks  for  disposal.    If  the oil/grease  exceeded  30
mg/1,  further  treatment  was  to be  carried  out.   It is
unclear   from   available  information   what   "further
 300.70(b)(2)
 (ill)(C)
 solidifica-
 tion
300.70(b)(2)
(11) direct
waste
treatment
methods
                                     7-11
-------
treatment"  involved.     However,   daily  site   reports
indicate  that  on at  least  one occasion,  the water was
filtered a  second  time to further reduce its oil/grease
concentration.

Transportation and Disposal

     Trucks used  to  haul the  solidified  waste  from the
site  were  lined  with  plastic, secured  with  a canvas
tarp, and  washed before  leaving  the  site.   Tail gates
were  sealed with  a thick asphaltic  based sealant.   The
solid material was transported  400 miles  (249 km) to the
CECOS secure landfill  in Niagara Falls, New York.  These
231  truckloads left   the  site from  July  28,   1980   to
November 3, 1980.

     From  August  20,  1980  to October  28,   1980,   53
truckloads  of  lagoon  water were  taken  to  the  Tollman
Island Sewage  Treatment Plant  at  127th  Street  and East
River  in  College  Point,  Queens.    The  Tollman Island
Sewage  Treatment  Plant  is  part  of  the  New York City
sewer system.

Backfilling

     The bottom of the lagoon  was  scraped using a smooth
blade  backhoe  and  clean  dirt was  discovered  after  6
inches  to  1  foot  (15  -  30.5  cm)  of   scraping.   The
excavated   area  was   then   backfilled  with   soil  and
"landscaped",  according to the  daily site reports.

COST AND FUNDING

Source of Funding

     The  New  York   City   Department  of Environmental
Protection  paid  for   the  entire  1980 clean-up  of  the
College Point  site  because  New York City, was  the  owner
of  the  site.    The Coast Guard had determined  that  the
threat  to  navigable  waters   of  Flushing  Bay  did  not
warrant  funding  for the clean-up  under  section  311  (k)
of  the Federal Water Pollution Act.

Selection  of Contractors

      The  NYC  DEP  selected Chemical  and Environmental
Conservation Systems  International,  Inc.  (CECOS) because
it  believed that  CECOS was the  only firm qualified  to
cleanup  the PCS  contamination at  the time and because of
its licensed  landfill  in Niagara  Falls,  New York.   The
contract  signed June  5, 1980  was  on a time and  materials
basis,  and CECOS was  the sole  source contractor.
300.70(c)
off-site
transport
for treatment
or secure
disposition
300.7000 (ii)
(C) grading
                                      7-12
-------
Project Cost

     The total  cost  of the clean-up at College Point of
$1,845,020  is  based  on  invoices submitted  by CECOS to
the NYC  DEP.    As  specified by  contract,  the costs for
the   clean-up   were   billed   on  a   time-and-materials
basis.   Invoices  state the daily rates for  labor,  daily
travel  costs,  materials  costs,  and  rental  charges for
equipment, but, with  the  exception  of transportation and
disposal, do not  state the tasks for which  these  inputs
were  used.   Transportation and  disposal  were  separate
categories,  and   thus  these  two  components  of the
remedial action could be  separated  out by  costs  as shown
in Table 1.   Given these  limitations,  discussion  of the
various  project costs is  limited to the three categories
shown  in the table.

     Transportation  of the  solidified PCS  oil,  sludge,
rock,  soil,  and debris  over 400 miles (644 km)  to the
CECOS  landfill  in Niagara  Falls,  New York  cost a total
of  $202,410,  which   yields  a  cost  per  truckload  of
$876.    This  results in  a  unit  cost  of  18 /ton/mile
(13 /Mt/km) .   The  total  cost of  disposal  at the CECOS
landfill was   $531,581   or  $192/ton  ($211/Mt).    The
combined  cost   of   transportation  and  disposal was
$733,991 or  40%  of  the  total cost of   the  response
action.

      Transportation   and   disposal   of  the  pre-treated
lagoon water was  not listed  as  a separate  item  in the
invoices.

PERFORMANCE EVALUATION

      The clean-up  was described by the NYC DEP officials
as  complete.   Although a payments  dispute arose between
the  NYC DEP and  CECOS,  it did not  appear to retard the
progress of the  site clean-up.    The NYC  DEP  received
EPA's  approval  of   the  completed  removal  action  in
November of  1980,    The  threat  of future  fires  at the
site   and  the  public  health  and  environmental   threat
posed  by  the  high  levels  of  PCS  contamination were
effectively mitigated by the removal  action.  However,
 in   the  absence   of   any  monitoring   data  on  soil
 contamination   levels  after  the  clean-up,  it  is not
possible  to  evaluate precisely the level  of  clean-up
 achieved.

      While the NYC  DEP  appeared to have removed most of
 the  source of  contamination at  this site,  three  follow
 up actions are warranted.   First,  since the NYC DEP knew
 nothing  of  the  site's   disposal   history,  it   should
 conduct site visits  in the future to inspect  for any

                                      7-13
-------
                    TABLE 1.  SUMMARY OP PROJECT COST INFORMATION-COLLEGE  POINT SITE,  QUEENS,  NEW YORK
t
I-"
*>
Task
Excavation,
solidification,
and waste water
treatment
Transportation
of solidified
PCS waste
(400 miles/644 km)
Disposal of
solidified PCB
waste
TOTAL
Quantity
• 2771 tons
(2514 Mt)
solid waste
• 318,000 gal
(1.2 x 106 1)
lagoon water
• 2771 tons
(2513 Mt)
• 2771 tons
(2514 Mt)

Actual
Expenditure
$1,111,029
$ 202,410
$531,581
$1,845,020
Unit Cost
N/A
18^/ton/mile
(13^/Mt/km)
$192/ ton
($212/Mt)

V^iM^M^feAd^^^^^^^^^^^^^^^^^^^,^^!
Funding Source
••^^M^MBMonsss:
NYC Department of
Environmental
Protection
NYC Department of
Environmental
Protection
NYC Department of
Environmental
Protection
NYC Department of
Environmental
Protection
Period of
Performance
July 23, 1980
to
Nov. 7, 1980
July 28, 1980
to
Nov. 3, 1980
July 28, 1980
to
Nov. 3, 1980
July 23, 1980
to
Nov. 7, 1980
                                 N/Ai Not Applicable
-------
continued dumping activities.  Second, a hydrogeological
study of the  site  area should be conducted to determine
the  extent,  if any,  of  threat  to  ground  water and
surface water.  Third, since  some PCB/oil  discharge into
the Flushing  Bay  occurred, at least  at  the time of the
Coast Guard involvement, any  future  study  or clean-up  of
Flushing Bay  contamination  should  specifically  address
this section of the Bay.
                                       7-15
-------
                           BIBLIOGRAPHY
 Dewling, Richard T., U.S. EPA Region II, New York, NY.
      November  4,   1980.     Written  Communication  to  Francis  X
      McArdle, NYC DEP.

 Farquhar, Bob, NYC DEP, December 1982 - February 1983.  Verbal
      Communication with Environmental Law Institute staff.

 Frisco, John S.,  U.S. EPA Region II, New York, NY.  May 27, 1980.
      Written Communication to Phil Weinberg, NYC DEP.

 Frisco, John S.,  U.S. EPA Region II, New York, NY.  October 9, 1980.
      Written Communication to Jeffrey Sonmer,  NYC DEP.

 Kline,  Larry, NYC DEP,  February 16,  1983.   Verbal Communication
      with Environmental Law Institute staff.

 Langlais, Louis V.,  CECOS  International,  Inc.  October  14,  1980.
      Written Communication to Jeffrey Sonmer,  NYC DEP.

 Langlais, Louis V.,  CECOS  International,  Inc.,  Niagara Falls,  N.Y.
      September  3, 1980.   Written Communication to Jeffrey Sonmer,
      NYC DEP.

 Lavache,  Mark, U.S.  Coast  Guard, New York, N.Y.   December  1982 -
      February 1983.   Verbal communication with Environmental Law
      Institute staff.

 Leonforte, John, NYC  DEP,  December 1982 - February  1983.   Personal
      Communication with Environmental Law Institute staff.

 Marcklinger, Robert., CECOS International, Inc.,  Niagara Falls, N.Y.
     August  25, 1980.   Written Communication to Jeffrey Sommer.  NYC
     DEP.

Marcklinger, Robert, CECOS International, Inc., August  11,  1980.
     Written Communication to Jeffrey Sommer, NYC DEP.

Marcklinger, Robert.  CECOS International, Inc.  August 26, 1980.
     Written Communication to Jeffrey Sommer, NYC DEP.

McGouh,  Joseph T., NYC DEP, July 21,  1980.  Written Communication to
     CECOS International, Inc., Niagara Falls, N.Y.

Pierre,  Wayne, U.S. EPA Region II,  New York, N.Y. December 1982 -
     February 1983.  Verbal Communication with Environmental Law
     Institute staff.

"Site Procedures  Manual Safety Plan" for College Point, Queens, NYC.
     CECOS, International,  Inc., Niagara Falls, NY.

                                 7-16
-------
Sommer, Jeffrey, NYC DEP, August 25, 1980.  Written Communication to
     Louis V.  Langlais, CECOS  International,  Inc.,  Niagara  Falls,
     N.Y.

Taylor, Kathy.  February 1982.  Personal communication with
     Environmental Law Institute.  U.S. EPA.  Washington, D.C.

Zawadzki, Stanley C., CECOS International, Inc.,  September 18, 1981.
     Written Communication to Jeffrey Sommer, NYC DEP.
                                 7-17
-------
-------
                          FAIRCHILD  REPUBLIC  COMPANY

                             HAGERSTOWN, MARYLAND
INTRODUCTION

     The  Fairchild   Republic  Company  in   Hagerstown,
Maryland disposed  of  chromium sludge in a landfill  area
near its manufacturing  site.   Chromium levels  averaging
greater  than 0.05 mg/1  were  found  in the ground water
underlying  the landfill.   Several  domestic  wells  near
the  company's  property  also showed  slightly  elevated
levels of chromium.

Background

     Fairchild Republic  used  chemical  solutions to clean
sheet  aluminum  that  is  used  in  the manuf acture  of
airplanes.   Sludge and  liquids  containing heavy metals
and  a  high  concentration of  chromium and miscellaneous
organic  solvents  resulted from this operation,  and  were
deposited in an open landfill on  plant property between
1950  and 1967,    As  a  result of  rainfall  and  surface
water  percolating through the  sludge,  the  surrounding
soil and  ground water became contaminated with chromium
and organic  chemicals.

     In August  1978,  the Maryland Department  of Natural
Resources,    Water   Resources    Administration   (WRA)
conducted  ground water  monitoring prior  to  reissuing  a
permit  for  two  sludge  lagoons   operated  by  Fairchild
Republic.   The permit had expired in 1978.  WRA's ground
water  monitoring  results revealed  a  "hot  spot"  of
chromium  contamination  approximately 400 feet  (121.9  m)
away from the sludge lagoons.  The  nearby open landfill
containing  chromium sludge was  found to be  the source of
the contamination.
NCP
References
 300.63(a)(2)
 government
 investigation
                                      8-1
-------
 Synopsis of Site Response

      After  initiating  ground  water  monitoring  in  the
 fall  of  1978,  WRA issued  a 90 day  permit  to Fairchild
 Republic, which  provided that Fairchild  Republic could
 continue using  the  lagoons  for  90  days  and thereafter
 would be required to put new sludge  in a state approved
 landfill.   In  addition,  the  state   required  Fairchild
 Republic to  remove  the  existing  sludge to  prevent  the
 leaching of chromium from  the lagoons.  In  the fall of
 1979,  after  the sludge  was  removed from the  lagoons,
 Fairchild Republic hired  engineering  consultants MeteaIf
 and  Eddy,  Inc.  to  do  an  investigative study  of  the
 landfill area.

      Upon completing  the  study,  Metcalf and  Eddy drew up
 a  work  plan  that  proposed  alternatives  for  remedial
 action   at  the  landfill  area and   suggested  the  best
 alternative.   Fairchild  submitted  the entire work  plan
 to  the  state,  which  accepted  the recommended  remedial
 action.   That  action included  removing the sludge  and
 contaminated  soils,  installing  a  clay cap,   covering  it
 with  topsoil,  and  grading  and seeding  the  site.    To
 implement  the  plan, Fairchild hired  Metcalf  and Eddy to
 do ground water and soil  sampling  and analysis  from late
 1979   through  early    1980.     Fairchild  hired   Diggs
 Sanitation  to do the  soil  excavation  in the spring  of
 1981.   When Mr.  Digg1s haulers  license was revoked  by
 the   state   in   April   1981,   Fairchild  Republic  hired
 Bohager  Waste  Systems  in  November 1981, which  completed
 the  removal work in  December.   Bohager backfilled  the
 excavated area  and installed  a clay cap over  part of  the
 site  in  December 1981,  and after  the winter capped  the
 rest  of  the site, covered it with topsoil and  seeded it
 in April  1982.

 SITE DESCRIPTION
 Surface Characteristics

     The  Fairchild  Republic  property  is located in  a
 rural area  about  2.5 miles  (3.2 km) north of  Hagerstown,
Md. near the Pennsylvania  border  (see  Figure  1).   The
 landfill  in which  the contamination was detected  was
 located  north  and northwest  of  the  "Hot Fire Pit Area"
 located behind  Plant No.  11 (see Figure 2.  The  landfill
 is  designated  the  "Hot  Fire  Pit  Dump  Area").    The
 landfill had an irregular shape with  a maximum  length of
 about 350 feet  (106.7  m) and a maximum width of  about
 160  feet  (48.8  m).    Test  pits dug  throughout   the
 landfill  area  showed  a  depth of refusal of 2 -  5.5 feet
 (0.6 - 1.7 m), as shown in Figure 3.
                                      8-2
-------
                    Figure 1.

   Location  of  Fairchild Republic Company
          Haeerstown.  Maryland
6,9 \.a  FRANKLIN CO
  MANUFACTURING
     FACILITY
                      i-3
-------
CO
I
-p-
         Figure  2.
         Disposal Site Location
                                                                FRC
                                                               .PLANT
                                         'FORMER
                                         /SLUDGE
                                         I SITE

                                         in"* ""*"•»_
JJFAIRGHIL
^REPUBLIC
     -- —-
  SCALE
0      1,000*
          Metcalf & Eddy
          Monitoring Well »M1
          (M&E Well #1)
          State Water Resources
          Monitoring Well »W2
          (WRA Well #2)
FAIRCHILD
 REPUBLI
 MAIN
 PT.ANT _
          Note:  WRA well #1
          destroyed and missing
         SOURCE: METCALF & EDDY,  Inc
-------
Figure  3.  Contour Map of Depth of Refusal, Hot
          Fire Pit Bisposal Area

Source:  Metcalf  &  Eddy,  July 1982
                    8-5
-------
     The soil  at this site is  a  silty clay loam in  the
Hagerstown-Duffield-Frankstown    association   and    is
generally characterized  as  reddish, well drained,  deep,
and  medium  textured.   Below  the  silty  clay  at  the
landfill  area  lies  a  limestone  bedrock  with numerous
fractures and cavities.  The  stratigraphy of the  bedrock
is  a series  of parallel  folds  with  the  axial  traces
trending N 15 degrees E, somewhat resembling the  fingers
of  a  hand.     The   joint  measurements  trend   in  two
directions:   strike  N 80 degrees  E, dip  85 degrees  NW;
and  strike N 50 degrees E,  dip 60 degrees SE.

     Climate  in this area  is  continental  with  maximum
afternoon  temperature   averaging  88   degrees   F.   (31
degrees  C.)   in late July  and  minimum early   morning
temperature  averaging 21 degrees  F, (-6  degrees  C.)  in
late January -  early February.   Annual precipitation is
rather even  throughout  the year,  with the  mean  for  the
past 30 years at 37.08 inches (94.2 cm).

Hydrogeology

     A  carbonate   aquifer   lies   below  the  Fairchild
Republic  facility,   with the water table  ranging from
34.1 feet (10.4 m)  below surface  in dry fall months  to
11.9 feet (3.6 m) in wet winter months.

WASTE DISPOSAL HISTORY

     Between 1950 and 1967,  Fairchild Republic disposed
of  solid  and  liquid manufacturing plant  wastes in  an
open  dump  located   near the  Hot  Fire  Pit.     Liquids
consisted  of both  a metal  cleaning  solution  used  to
clean  aluminum  sheet   metal  and  waste   sludge  from
Fairchild's  waste  treatment  facility.     The cleaning
solution  contained  a number  of  spent organic solvents
and  the  sludge  contained  primarily total  chromium  and
hexavalent  chromium, as well  as  other  heavy  metals.
During the mid-19601s an improved waste treatment  plant
was  constructed, which  enhanced  the  removal  of  heavy
metals through chemical  addition.   The resulting  sludge,
which  was   more concentrated,  was   dewatered   through
filter  presses  and placed  in several  sludge lagoons.
Sludge was then  hauled  to the Browning Ferris  Industries
licensed  disposal   facility  at Glen Burnie,  Md.  for  a
number  of  years.     Recently,   trivalent  chromium  was
declassified  as a   hazardous  substance;   since  then,
Fairchild  Republic  has  disposed  of  the   trivalent
chromium sludge  at a  local sanitary landfill.
300.68(e)(2)
(i)(E)
climate
300.68(e)(2)
hydrogeo logical
factors
                                      8-6
-------
DESCRIPTION OF CONTAMINATION

     Metcalf  and  Eddy,  Inc. was hired  as  the consulting
engineering  firm for  the clean-up.   It undertook  soil
and  hydrogeological  investigations  at  the  site,  using
test  pits,  monitoring wells  and laboratory  analyses  of
soil,  ground  water  and waste samples.   The ground water
and  surface  water systems  were  assessed in  two  phases.
The  first  phase sought  to  determine local  ground water
quality.   The  contractor  installed  5  monitoring wells
near  the sludge  basins  and  analyzed  samples from  them
and  from  15  nearby  domestic  wells and   5  streams  or
springs.    Four  series   of  samples  were  analyzed  and
significant concentrations  of chromium were  detected  in
some samples.  This  led  to  the  second phase,  which tried
to determine  the  path of migration of  chromium from the
disposal areas.   Five additional  monitoring wells  were
constructed.  Three  series  of samples were  analyzed from
these  wells  and  an  additional  surface   water   point.
Figure 4 shows the  average  water table  elevations in the
area,  and Figure  5  presents  the chromium  concentrations
found.  Migration from the  disposal  areas  appeared to  be
westerly or southwesterly.

     The major  contaminants  found  at  the  site included
heavy  metals  such  as  chromium,   copper,  zinc  and
aluminum, as  well as organic materials, most notably  1,
1,     1-trichloroethane,     1,      1-dichloroethylene,
ethylbenzene,           methylchloride,          toluene,
trichloroethylene,   and   xylenes.      There  were  two
relatively  easily  distinguishable  classes  of   wastes
discovered at the site:   a  black, powdery material and a
bluish-green  sludge.   The black, charcoal-like material
consisted primarily of  the  spent  organic  solvents and
some heavy metals.   The  bluish-green material had a high
concentration of  total chromium, in the order of 10,000
tag/kg  or  greater.   Since chromium was  found to   be the
dominant  heavy  metal   contaminant   in the area  (the
highest  concentration of chromium  found  in the  ground
water  was 0.32  mg/I of  total chromium  and 0.28  mg/1  of
hexavalent  chromium),   it   was   used  as   a surrogate
indicator  for  all  other  metals.    Metcalf and  Eddy
assumed that  if chromium concentrations were found to  be
above  the  natural  background  levels,   the other  heavy
metals would  also  be  at higher than normal concentra-
tions.

     Test  pits  and  surface sampling locations  were
established around  a  base line  (B-B1 shown in Figure  6)
which  ran  through the middle of the contaminated area.
Distribution  of  chromium contamination at the surface,
as  indicated  by  soil samples,  is presented in  Figure
6.  The total chromium concentration of the samples
3Q0.68(e)(2)
amount and
form of
substances
present
                                      8-7
-------
                 Figure 4.  Water Table Elevations
                                                B/MW-7
                                                 679.6
                              B/MW-9
                               620-8
                                              B/MW-IO
                                              663.4
                                      B/MW-8
                                       632.4
       NOTE

* AVERAGE WATER TABLE ELEVATIONS

WELLS B/MW-1,2,3.4,5,6,7

 SCALE: T-iooo'
WATER TABLE
 ELEVATIONS
     Source:   Metcalf & Eddy, May 1980
                              8-8
-------
      Figure  5.   Total  Chromium Isoconcentration Contour Map
^-MONITORING WELL

  -DOMESTIC  WELL
SCALE: i"=iooo4
CONTOUR INTERVAL-AS SHOWN
	APPROXIMATE VALUES
CONCENTRATIONS IM ppm CHROMIUM
 TOTAL CHROMIUM
ISOCONCENTRATION
  CONTOUR MAP
     Source:   Metcalf & Eddy,  May  1980
                                1-9
-------
Figure  6.   Surface  Sampling Locations and  Total
            Chromium Concentrations
                                     SURFACE SAMPLING LOCATION^
                                 ,   IS CHROMIUM CONCENTRATION
                                     IN MG OF CHRQMiUMPER KG O= SOIL)


                                 B[—   -\B'  BASELINE
                                          SCALE IN FEET

                                      CONTOUR INTERVAL.
 Soiarce:   Metcalf &  Eddy,  July  1982
                         S-10
-------
ranged  from  20 mg/kg to  280,000  mg/kg with the natural
background level of  total  chromium  in  the range of 50  to
100  mg/kg.   From  these analyses,  a visual correlation
was  made  that  the material  having  a bluish-green color
contained chromium in excess of 10,000 mg/kg.

     The  estimated  volume  of  material   in  the   area
containing  the  wastes  was  approximately   5,400  cubic
yards  (4,128.84  cu.m).   About 50%  of this material was
determined to  be contaminated soils.   The  remainder  of
the  material  was  believed  to be   only  partially  con-
taminated, and lay either above  or beneath the wastes.
The  total surface  area  which required  excavation was
about  1 acre  (0.4  ha)  and  generally less  than  5  feet
(1.5  m) deep.   Figure  3  shows  the  depth to probable
bedrock.  Figure 7 presents  graphically  the distribution
of  wastes in  the abandoned open  pit site,  indicating
areas  where  contamination was  near or  directly  on the
bedrock,  areas where the  soil was  at  least 2 feet  (0.6
m)  thick  between the contamination and  the bedrock, and
areas  where  contamination appeared to be  restricted  to
within  1  foot  (0.3  cm)  of the surface.   This presenta-
tion  format  was  valuable  in  helping MeteaIf  and  Eddy
estimate  the  total  volume  of  wastes  that  should  be
exhumed.  Cross-sectional  views of  the site are shown  in
Figures 8 and  9, and the locations  of  the cross-sections
in Figure 10.

PLANNING THE SITE RESPONSE

Initiation of Response

     Fairchild  Republic  had  a state  permit to operate
two  on-site  sludge  lagoons.   When  the permit expired  in
1978,   the   state  conducted   routine   ground   water
monitoring  tests prior  to  reissuing  the  permit.   The
tests   showed  that  a  substantial   amount   of  chromium
sludge  existed in an  open  landfill 400  feet (121.9  m)
from the lagoons.  The state concluded that it presented
a threat to  the  aquifer.   In the  fall  of i978, the state
WRA  issued Fairchild a  90  day  permit for  continued use
of  the lagoons,  after  which  time  the  company  had  to    300.68(c)
remove  the  sludge.     Fairchild  and  the   state  began    private
discussions regarding the  clean-up  of the  landfill, and    clean-up
Fairchild volunteered  to clean up  the site and p&y for
all  costs  of  remedial  action  and  disposal.   The state
issued  no  clean-up order  and  imposed  no penalties  with
respect to the landfill.
                                     8-11
-------
CO
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              ft
              O
              fu
              M
              Hi
              0)
              O.
              VD
              CO
              to
                                                             O
                                h   H
O         TEST PIT LOCATION AND TOTAL THICKNESS
           OF CONTAMINATED LAYERlSI IN FEET
                             Y//////\   AREA *WenE CONTAMINATION IS NEAR OH DIRECTLY
                             \t f f f f f A   ON BEDROCK
                                              ON BEDROCK


                                              AREA WHERE SOIL IS AT LEAST 3 FEET THICK
                                              BETWEEN CONTAMINATION AND BEDROCK
                                                                                                                SCALE IN FEET
                             •^^//'>;''//'J  A«a^tEnE CONTAM'NATION APPEARS TO BE RESTRICTED
                              >  » f< < ' I <\  TO WITHIN ONE FOOT OF THE SURFACE
                                                                                                                    H-
                                                                                                                    OQ
                                                                                                                    C

                                                                                                                    ro

                                                                                                                    ^j
                                                                                                                    O
                                                                                                                    H.
                                                                                                                    CO
                                                                                                                    rt
                                                                                                                                                        O
                                                                                                                                                        Hi
-------
    Figure 8.  Geologic Cross-Section Y-Y
                                          TP-33
                            TP.10TP.11
                                "
                       TP-9

                        100


                     DISTANCE IK FEET
Source:   Metcalf  & Eddy, July  1982
                     8-13
-------
X

 fl
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•H
-M
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u

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•H
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                                                          Sdl
                                                                                                                                                    .X
CM
00
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-------
 Figure  10.  Locations of Cross-Sections Y-Y and X-X,
             Hot Fire Pit Disposal Area
                                       5   TEST PIT LOCATION
                                       •   AND NUMBER

                                   B|—  -\B'  BASELINE
                                             100
                                          SCALE IN FEET
Source:   Metcalf  & Eddy,  July  1982
                         8-15
-------
Selection of Response Technologies
     Metcalf and Eddy was  hired by Fairchild Republic to
study  the  extent  of  site  contamination  and  propose
remedial action options.   Metcalf  and Eddy proposed four
options to clean up  the landfill:   (1) chemical fixation
of the was te  and  storage on-s ite;  (2)  chemical fixation
of  the  waste  and   disposal  off-site;   (3)   off-site
disposal in  an approved hazardous waste  landfill;  and
(4)  on-3ite  disposal   in  an  approved  hazardous  waste
landfill.  It used the following  criteria in evaluating
the options:  (a)  technical  feasibility;  (b)  conformance
with  applicable  federal,  state and  local  regulations;
and (c)  estimated  cost. The  objective of  the  first  two
alternatives was to  render the  material non-hazardous so
that it could be  placed in a local landfill  rather than
to  an  approved  hazardous  waste   disposal  site.     An
advantage of these alternatives was that  rendering  these
wastes  non-hazardous  would  reduce  transportation  and
disposal costs.

     The  possible  use  of   the   chemical   fixation
alternative was contingent upon its ability to stabilize
the waste (i.e., to  prevent  leaching  of heavy metals  and
organics).    Chemical   fixation  had  to be rejected  as
technically unfeasible  because  the end-product material
did not  pass leachate  test  requirements.   Extractable
total chromium was 1.31 mg/1 and  extractable hexavalent
chromium was 0.20 mg/1.  The volatile organics extracted
were as follows: 1,1-dichloroethylene, 33ug/l;  1,  1,  1-
trichloroethane,    340   ug/1;  trichloroethylene,   2,000
ug/1; and tetrachloroethylene, 11 ug/1.

     The  third alternative,  off-site  disposal in  an
approved hazardous waste landfill, had the advantage of
removing  the   wastes   from   above   the   contaminated
aquifer.  It  also offered the  opportunity to  clear  and
rehabilitate the  disposal  area  for possible  future  use
by  the  plant.   Disadvantages  included  the  expense  of
transportation and the  costs  of hazardous  waste disposal
at an approved facility.

     The benefits  of alternative  four, on-site disposal
in  an  approved hazardous  waste   landfill,   were   that
Fairchild  could  maintain   control  of  the   waste  and
eliminate transportation and  disposal  fees.   However,
there would be  some project  delay due to  the necessity
of  designing   and  constructing   the  facility.     In
addition,  the  disposal  site  would   require  long-term
maintenance,   monitoring.
and
lengthy   permit
                               300.68(g)
                               development
                               of response
                               alternatives
                               300.68(h)
                               initial
                               screening of
                               alternatives
application procedure.   Further,  the  state was reluctant
to allow disposal of wastes above the aquifer.
                                     8-16
-------
      The proposed  on-site  facility  would be  a double-
 lined  surface  impoundment  with  a  leachate  collection
 system  between  the  liners.    The  leachate  collection
 system would remove  any leachate  migrating  through the
 upper  liner  material.    Two   specific  designs  were
 considered.   The  first used a reinforced concrete pad as
 the  lower liner and  the second  a 2 foot  (0.6  m)  thick
 clay  liner.   In both designs, a fabric material believed
 to  be imperbeable would  serve as  the upper  liner.   The
 facility required  approximately 1  acre  (0.4  ha) of land
 and would be constructed with  approximately  4 foot (1.2
 m) high walls and  a 3:1 ratio sidewall slope surrounding
 the  pit.   The landfill  and material  would  be covered
 with  a  fabric  liner  followed  by  18  inches  (45  cm)  of
 local  soil,  predominantly clay, and  8  inches  (20 cm)  of
 topsoil.   It would be seeded with a grass legume mixture
 and graded  to encourage runoff.  The total costs for the
 concrete based  and clay lined  facilities were estimated
 to be  $840,000 and $240,000,  respectively.

     Metcalf  and Eddy recommended the third alternative,
 removal  of  the wastes and  ground water  monitoring  for
 three  years,  as opposed to  alternative four,  even though
 the latter was felt  to be  the  lowest  cost alternative.
 The main  reasons  for  this  choice were  the  long  term
 maintenance  costs  and responsibility associated with on-
 site   disposal.    Fairchild  favored  this  alternative
 because  it  wanted  to  avoid prolonged   involvement  in
 waste  management.     The state,   after  reviewing  these
 alternatives,  approved  this  third  alternative in  the
 summer of 1980.

 Extent of Response

     The  state  did  not  impose  specific  environmental
 criteria  or  remedial   technology  requirements.    Its
 objective was to  lower  the  level of total chromium was
 the  soil,  domestic  water  wells  and monitoring  wells.
 (The U.S. EPA drinking  water standard for total chromium
 is 0.05  ppm  and the U.S. EPA standard under the Resource
 Conservation  and  Recovery   Act  for total  chromium  in
hazardous  wastes   was  5   ppm  at  the   time   of   the
 response.)   The WRA  did not  indicate  that meeting EPA
 standards was the  objective  of the remedial action,  only
 that  the  total  chromium  had  to  be lowered  from  the
 amount measured prior to the remedial action.   Although
 organic  contaminants  were  also  found  in  the  soil  and
 ground  water,  the state  asked  Fairchild  Republic  to
 conduct  ground water  monitoring of organics but did not
 require  that  any  pre-determined   organic  standards  be
met.   Two reasons  for this  appear to be  that EPA did not
have  standards  for organics in drinking water  at  that
 time   and   the  contamination  did  not   appear  to  be
300.68(c)
state evaluation
of clean-up
proposals
300.68 (j)
extent of
remedy
                                     8-17
-------
extensive.

     Contractors completed the remedial  action  according
to  the  Metcalf  and  Eddy  work pi an.    Excavation   of
contaminated  materials  was  stopped  when   it  reached
fissured bedrock, which  state  inspectors agreed was  the
practical limit.  Subsequent composite soil  samples from
the excavated  area indicated that  total and hexavalent
chromium  concentrations   were   not  EP  toxic.      The
contractor  then  backfilled  and  capped  the  site   and
covered  it  with  topsoil  and  grass  seed.     Work   was
stopped  when  the   specifications  of  the workplan   for
excavation,  removal,  backfilling  and capping  had been
met.   After  completion of  the clean-up,  ground water
tests  indicated that  the  chromium  contamination level
was lower, as the state required.

DESIGN AND EXECUTION OF SITE RESPONSE

Site Investigation

     The  most  important  elements  in   determining   the
technology  for  removing the material  were knowledge  of
the   contaminants,   definition   of   the   amount    of
decontamination  desired  and location of the exact area
of  contamination.   In order to obtain this  information,
soil  and  hydrogeological  investigations   were   under-
taken.    These  primarily   involved  making   exploratory
backhoe test pits,  installation  of monitoring wells,  and
laboratory  analysis  of   soil,  ground   water,  surface
water,  and  waste samples.   The results of  these tests
are  discussed  above  in  the  section  "Description   of
Contamination."   After Metcalf  and  Eddy had determined
the nature and  location  of contamination,  it developed a
workplan for the remedial action.

Removal of Contaminated Materials

     Two contractors, Diggs Sanitation  and Bohager Waste
Systems, working at different periods  of time,  performed
the  excavation,  transportation  and  disposal   of con-
taminated  materials.   Personnel  from Metcalf  and Eddy,
Fairchild Republic  and the state periodically  inspected
the  site to observe  work and  collect   soil  samples  for
chemical analysis.

Diggs Sanitation

     Diggs  worked  from October 1980 to  April 1981, when
he  was  arrested for illegally disposing of the  excavated
contaminated  materials.    Metcalf  and  Eddy  personnel
delineated  the  site  on  October  14  and  15,  and  Diggs
began  excavation on  the  15th  using a  front-end loader
300.68(f)
remedial
investigation
300.70(c)(2)
(i) removal
of contaminated
soils
                                      8-18
-------
 and two dump  trucks.   Before the end of  the  first work
 day,  Fairchild Republic  ordered  him to stop  because he
 lacked  necessary permits.   At that time,  the excavated
 material  was stockpiled on-site.  Diggs  resumed work on
 April  3  after securing  the  permits.   The contaminated
 soil   was   intended   for  disposal  at   the   Municipal
 Industrial  Service  Site Landfill in Clairton,  Pa., about
 125 miles  (201  km)  away.

     Diggs  began excavation  at  the  northern  end  of the
 landfill  area (see  Figure 11, line  P), using  the front-
 end loader  and this  time  5  instead  of  2  dump trucks.
 Contaminated  soil   and  materials  were   excavated  and
 stockpiled  at the site on a daily basis,  with  the extent
 of  excavation and the size of the pile limited to reduce
 possible    exposure   due   to   rainfall    and   run-off.
 Generally,  the  trucks  were  loaded  in the  morning from
 the  stockpile  remaining    from   the  previous   day's
 excavation.   Sometimes trucks would return in  the late
 afternoon   or  early  evening  for  a  second  load,  but
 apparently  most made  only one  trip per day.

     During the first week of work, Diggs constructed a
 shallow  diversion  ditch  along   the east   side  of  the
 landfill  area  to  prevent  surface  waters  from  running
 into  the  excavated  area.   Odor  from contaminants  was
 occassionally  strong,  especially   when   the   front-end
 loader   encountered   large  pockets  of   black   colored
 wastes.   When  this  occurred,  the operator  used  an air-
 purifying   respirator  with  combination  filter/chemical
 cartridges.

     Metcalf  and Eddy  personnel periodically inspected
 the site  to advise  Diggs about the  extent  to  which soil
 should  be   removed.    Visual  observations  backed  by
 chemical  analysis   reports   from previous inspections
 established   that  contaminated  materials  were  readily
 distinguishable from  clean clay:  the former were usually
 black or blue-green  and  the  latter was  orangish.   In
 areas of  slight or  not visually  apparent  contamination,
Metcalf and Eddy's  graphic distribution of contaminants
was  used   to  guide  removal  (see  Figure  7).     Where
 contaminated  materials  were  found  in the  folds of  the
bedrock, they were removed using hand tools.

     Officials  from  the  Maryland Department  of  Health
 and  Mental   Hygiene  (MDHMA)  also  made   regular  site
 inspections also.   During the first week of work,  Diggs
did  not   have  covers  for   his  dump  trucks   during
 transport.      State   inspectors  notified  Diggs   and
Fairchild that  these  would  be required.  The  state also
required  Diggs  to   take   further measures to   control
potential site run-off.  In response, Diggs constructed
300.70(b)Cl)
(11) (B) (2)
ditch,
diversion
300. 70 (h)
(liKBKD
benn
                                     8-19
-------
                                       LEGEND
                                     TEST PIT LOCATION
                                     AND NUMBER
                                -|e   BASELINE
                                        100
200
=1
                                    SCALE IN FEET
FIG. II EXCAVATION GRID, HOT FIRE PIT
           DISPOSAL AREA
               8-20
-------
 a berm northwest of  the  excavation across a major swale
 that  drained  the   area   (see  Figure  11-the  berm  was
 between lines D and E near Stations 0 + 50 to 0 + 75).

      Work by Diggs  ended on April  23  when his hauler's
 certificate was  revoked  by  MDHMH.   Fairchild Republic
 records  indicated  that  he  removed  2,428  cubic  yards
 (1,856.4 cu m) of  contaminated  soil and materials.  The
 excavation site was  left open and  no  soil or materials
 were removed until November  1981,  when a new contractor
 began work, a delay of about  6 months.

 Bohager Waste Systems

      After being selected by Fairchild and obtaining all
 necessary permits,  Bohager  Waste Systems  began  work on
 November 16, 1981.    Bohager  followed basically the same
 excavation  workplan  as  Diggs,   but   transported  the
 exhumed  contaminated  materials   to  the  Solley  Road
 Hazardous Waste Landfill  in Glen Burnie, Md., a distance
 of  approximately 70  miles (112  km).   Inspections were
 resumed by Fairchild Republic,  Metcalf and Eddy, and the
 state.   Bohager began work in the  previous excavation,
 using  a   front-end   loader  and  6   dump   trucks.    Con-
 taminated  soil  and  materials   were   excavated  and
 stockpiled on  a  daily  basis  and  trucks  were  loaded
 either  directly   from excavation   or  from  the  pile.
 Usually  6  trucks  were  loaded  in  the  morning  and  3
 returned  in the afternoon for a second  load.

      At first,  Bohager excavated  the area from Station 0
 - 75  to 0 + 30 between lines F and  E as  shown in Figure
 11  and removed a stockpile left  by Diggs extending from
 Station 0  + 30 to 0 - 50 between lines E and C.   During
 this  early  stage,  Bohager's  industrial hygienist  took
 on-site air samples  to determine dust levels, and from
 the  low levels detected concluded  that  respirators were
 not necessary.

      During  the next two weeks, Bohager worked  in  the
 section southwest of  line F in  Figure 11 and cleaned and
 prepared   the  northern   section  for   soil   sampling.
 Composite   samples,   consisting  of  12   evenly   spaced
 sub samples  taken  from the upper 2  inches  (5  cm)  of soil
 at  the  bottom of  the excavated  area,  were  taken  on
 November  30,  1981  in sample area  FRC - 1  (see  Figure
 12).

      Subsequently,  Bohager was directed  not to work  in
 the FRC - 1  area and worked  in the  remaining  southwest
 portion of  the  site for  the  next week and  a  half.
According   to  Metcalf   and  Eddy,   the   contaminated
materials had either  been dumped onto or had  seeped into
300.70(c)
off-site
transport
for secure
disposition
                                     8-21
-------
co
I
K3
           rt
           o
           Hi
           M
           00
           M
            LEGEND


	  AREA OF APPARENT SUBSURFACE CONTAMINATION

       FROM WORK PLAN



	AREA OF SUBSURFACE CONTAMINATION WHERE

       CONTAMINATION WAS REMOVED



FRC-1  SAMPLE AREA
                                                                                                                         100
                                                                                                                                        H-
                                                                                                                                       OQ
                                                                                                                                        e
                                                                                                           ^ O
                                                                                                           p. O
                                                                                                           p- en
                                                                                                           en H-
                                                                                                          T3 rt
                                                                                                           o ro
                                                                                                           CO
                                                                                                                                     (D  fl)
                                                                                                                                     Pi

                                                                                                                                        (r
                                                                                                                                        O
-------
the fractured bedrock in  the  southwestern  section  of  the
landfill.   State inspectors agreed  on  December 10 that
the practical  limit of  excavation had  been reached  in
this area, and Bohager stopped work.  Fairchild Republic
records  showed  that Bohager  removed 2,741  cubic yards
(2,096  cu.m)  of  contaminated material.    Total  amount
removed  by Bohager and  Diggs  was  5,169  cubic  yards
(3,952.4 cu.m).

     Composite soil samples were  taken  from  sample areas
FRC-2 and  FRC-3  (see  Figure 12).  The  composite samples
were   analyzed   by   Gascoyne  Laboratories,   Inc.    of
Baltimore,  Md.,  using   EPA's  EP   toxicity  test,   for
extractable total  and hexavalent chromium,  the  chosen
indicator  contaminant.   According to MeteaIf and Eddy,
the results indicated  that  "all  three  composite samples
did  not  exceed  (sic)   the  maximum  concentration   of
contaminants for  characteristics of  EP Toxicity  (i.e.,
5.0 mg/1) for total hexavalent chromium."  These results
were  then submitted  to   the  state  with  a  request   for
written  agreement  that   a  sufficient   amount  of con-
taminant s had been  removed and  approval  to ins tall  the
clay cap.

The results are shown in Table 1 below:

    TABLE 1. RESULTS OF EPA-EP TOXICITY  TEST ON SOIL
                 SAMPLES  FROM EXCAVATION

Constituent
Total chromium
Hexavalent chromium
(measurements in mg/1)
Sample Area
FRC-1
0.00
0.00

FRC-2
0.14
0.11

FRC-3
0.69
0.48

    Source: Metcalf and Eddy, Inc. July 1982.
Backfilling and Capping

     A clay layer approximately  2  feet  (0.6  m)  thick was
placed directly  on  the exposed bedrock and  compacted to
retard  penetration  of   rainfall   and  prevent  further
movement of contaminants  into  the  ground  water.   The pit
was then backfilled with  clean soil and crushed rock and
compacted.  A clay cap was then installed  according to
Metcalf   and   Eddy's   specifications   for  materials,
density, permeability and compaction.
                                     8-23
300.70(b)(l)
(ill)(A)
impermeable
barrier
300.7000(1)
(ii) (A)
surface seal
-------
     The clay cap was  installed  in two  stages  by Bohager
Waste   Systems.     Before   beginning  work,   Fairchild
Republic   obtained   verbal   authorization  from   state
inspectors.   The first  stage occurred  on December  10,
1981, when the northern  part of  the landfill  area  was
capped  (see  Figure  12-  the  area  capped corresponds
roughly  to  sample  area  FRC  -  1).    Equipment  used
included  a roller,  a front-end loader  and three  dump
trucks.

     The  second  stage of  capping  occurred  during  the
week of April  12,  1982.   Metcalf and Eddy  reported that
the  almost  4  month  delay  was  due  to  poor  weather
conditions  during  the winter and  early  spring  months.
Fairchild  Republic  received written approval  from state
officials  prior to  placing  the remainder  of the  cap.
The cap  covered the southern  part of the  landfill  area
(see Figure 11-the  area  corresponds roughly  to  sample
areas FRC-2 and FRC-3).    Bohager used  a roller,  two-
wheel vibrator, front-end loader and dump trucks.

Grading, Topsoil and Seeding

     The  clay  cap was graded to  encourage run-off  and
thereby  minimize  surface  ponding.    In  addition,   it
lessened   the   opportunity  for  vertical   infiltration
should percolating  rainfall reach  the  clay barrier.  A
perimeter  drain was   installed  around  the facility  to
further minimize  the movement of run-off water  onto  the
decontaminated site.   A topsoil  cap of  approximately 6-8
inches  (15.24  - 20.3  cm) was placed over the  clay  and
seeded with a  grass-legume mixture.  The purpose  of  the
soil was  to preserve  and protect  the  integrity  of  the
clay layer, while the  grass helped  eliminate  erosion of
the topsoil and reduce the amount  of water reaching  the
clay cap  by optimizing  evapotranspiration.   Monitoring
wells previously  installed by the  state  and Metcalf  and
Eddy  were  used  to  collect  ground  water  samples  and
determine  the  overall long-term impact of the  response
action.
300.70(b)(l)
(ii) (C)
grading

(300.70(b)(l)
(ii)CD)
revegetation
COST AND FUNDING

Source of funding

     Fairchild  Republic  paid  for the  entire  response
action.  The  company   also   reimbursed  the  state  for
certain costs,  such  as  the installation of monitor wells
and the analysis of  soil and water samples.

Selection of Contractors
     Fairchild  Republic hired  Metcalf and Eddy, Inc., of
Boston, Massachussetts  as consulting engineers  for  the
300.68(c)
private
clean-up
                                     8-24
-------
site  investigation  and response action.   This firm  was
hired  on a sole  source,  fixed price contact because of
its  reputation   and   its   familiarity   and  prior work
experience   with  Fairchild's   Hagerstown   facilities.
Metcalf   and   Eddy   conducted  soil  and   hydrogeologic
investigations  of  the  Hot  Fire  Pit   area,   developed
alternative  remedial  action  plans  for  the  clean-up,
conducted  routine  inspections  of  contamination  levels
during  the  remedial   action,  and  submitted  a  closure
report to  Fairchild  Republic with recommendations for  a
post-closure monitoring program.

     In  August  1980,  Fairchild  Republic  initiated  a
competitive  bid  process   to   select   a  contractor   to
perform  the  remedial  action.   Fairchild  solicited bids
from   six   contractors,    three   of   which   submitted
proposals.   One  of  these  proposals  was  considered  not
responsive because  it  failed  to  identify  a  state  and
federally  approved disposal site as required by  the  RFP
specifications.   These specifications also  required  the
contractor   to  have  a   state   license   to   transport
hazardous  waste,  and  to  comply with federal and state
hazardous waste laws.  Bids were based  on  cost  per cubic
yard  of   contaminated  soil  to  be  excavated,  plus   the
costs  of  backfill  and   capping  materials.   Fairchild
Republic  hired Diggs  Sanitation of  Cumberland,  Md,   as
lowest bidder.  Diggs  began excavating  contaminated soil
and  materials  in April   1981  under  the   direction   of
Metcalf  and  Eddy.     At  about  that  time,  the state
discovered that  Diggs Sanitation was illegally diposing
of  the  contaminated   soil  and  materials.    The state
arrested  Mr.  Diggs,  the  president of  the  company,   and
charged  him  with  violations  of  Maryland's   hazardous
waste laws.  This led  to an order by  Fairchild Republic
for Diggs  to stop work.  Diggs'  contract performance  was
suspended  from April  1981 until August 1981,  when  the
contract  was  terminated.   Diggs' hauler's license  was
revoked  through  a state administrative action.   Later,
Diggs  was convicted   in   the  Allegheny County  Circuit
Court  in December  1981 of civil and  criminal  charges
related to the incident.

     When  Diggs  was  charged  with  illegal  disposal   of
hazardous wastes, Fairchild hired Bohager Waste  Systems
in the summer of 1981  to  complete the  remedial  action.
Chosen through a competitive  bid process,  Bohager  was
not  the   lowest  bidder,  although  its   bid was  in   the
competitive  range.    It  was  selected because  it had  a
good  reputation  and  planned  on using  Browning  Ferris
Industries (BFI)  as the disposer.   Fairchild  preferred
the BFI  facility to other licensed  landfill sites.    To
transport  the  excavated  waste,  Bohager   subcontracted
with three haulers  at varying prices.   Bohager accepted

                                     8-25
-------
higher hauling costs in order  to minimize  the  total  site
clean-up  time.    It hired  reputable haulers  who would
continuously  remove the  wastes as  they  were exhumed.
Information about the  identify of  these haulers and  the
prices they charged was not available.

Project Costs

     According to an estimate by Metcalf  and Eddy,  the
total  expenditure   for  the  Hot Fire  Pit  clean-up  was
$450,000.  Of  this  figure,  $107,000 went  to Metcalf  and
Eddy for  engineering services, leaving $343,000 for  the
excavation and  removal work.   That sum  can be broken
down  further  into  charges   of $90,000 and  $253,000 by
Diggs    Sanitation     and    Bohager    Waste   Systems,
respectively.   The  major  elements  of the  total cost  are
presented  in   Table  2.      Because   the   excavation,
transportation and  disposal work  was  conducted  by  two
contractors   with   different   sets   of    costs,    the
expenditure in terms of  unit costs for this work is  not
available.   However,  it  is  possible  to  assume   that
Bohager Waste Systems  conducted the  entire operation and
that  its unit  costs  rather than Diggs'  represent  the
true  unit costs  required  for properly  conducting  the
operation.  This assumption  seems plausible  since Diggs1
costs were low because of his  illegally disposing of the
contaminated  matrials.    If  the  quantity of materials
removed by Diggs  are multiplited by Bohager's unit  cost
this portion of  the work would have cost  $180,886,  over
twice the amount charged by Diggs.

     While  these  assumptions  are  necessary  to derive
meaningful  unit costs,  it  should  be noted  that  this
approach  generalizes  over the entire project, whereas,
in  fact,  the  actual  cost  components of the  remedial
action  were  adjusted  by  the contractors.   Fairchild
Republic  officials  reported  that when one  cost component
ran  higher  than Bohager  had  proposed,   the  contractor
would  try  to  eliminate  some  of  the  expenditure  in
another  component by modifying its  implementation of the
work  plan.   For  example,  since excavation  expenditures
were greater than projected, Bohager decided to  use less
topsoil  than  was   originally  specified in  Metcalf  and
Eddy's work  plan.    These  alterations, however, did not
significantly deviate  from the workplan.

     Unit   costs  for  backfilling,   clay  capping  and
seeding  were  taken from  the  contract between  Bohager
Waste  Systems  and  Fairchild Republic.   Costs for grading
were   included  in  the  cubic  yard   unit   prices  for
backfill,  clay and  topsoil.
                                      8-26
-------
        TABLE 2.  SUMMARY OF COST  INFORMATION-FAIRCHILD  REPUBLIC CORP.,  HAGERSTOWN, MD.
Task
Excavation, transpor-
tation and disposal
Diggs Sanitation
(transportation
distance NA)
Bohager Waste Systems
(transportation
distance: 70 mi.
112 km)
Subtotal
Backfilling
Clay cap
Topsoll
Seeding
Subtotal
Engineer ing, sampling
and chemical
analysis
Total
Quantity
(a)
2,428 yd3
(1,856.4m3)
2,741 yd3
(2,096 m3)
5,169 yd^
(3,952.4m3)
NA
NA
NA
NA



Estimated f^\
Expenditure


$340,200



NA
$40,000
$35,000
$415,000(d)
Actual
Expenditure
$90,000
$204,204.50
$294,204.50
NA
NA
NA
NA
$48,796
$107,000
$450,000
Variance


$45,995.50




$8,796

$35,000
Unit Cost (c)
$37.07/yd3
(48.48 m3)
$74.5<)/ydJ
($97.43/m3
($1.06/yd3/ml)
($0.87/m3/km
$56.92/yd3
($74.44/m3)
$7.50/yd3
($5.71/m3)
$9.75/ydJ
(7.45/m3
$10.25/yd'
(7.84/m3)
$0.40/ftz
($0.12/m2)



Funding
Source
Falrrhlld
Republic
Falrchtid
Republic
Fairchlld
Republic
Fa ire 111 1.1
Republic
FnlrchlM
Republic
Fairchlld
Roptibl Ic
Fairchlld
Rcpubl Ic
Fnirchihl
Rc'puM Ic
Fairchlld
Riipuhl Ic
r.ilrclillit
lU'ptibl ic.
Period of
Performance
10/80-4/81
11/81-4/82
10/80-4/82




12/81-4/82
11/79-7/82
11/79-4/82
00
 I
        NA = Not available
        (a) from Falrchild Republic records
        (b) from Metcalf and Eddy workplnn, May 1980
            which assumed that 4,800 yd   (3,670 m3)
            would be excavated, transported 75 miles
            (120 km), and disposed of at  $50/yd3
            ($38.23 m3)
(c)  from contract between BcihaRc-r  Waste Systems
    and Fairchtld Republic  (except unit c:o.-;t for
   work !»y DlRRS Sanitation)
(d) does  not Include contingency of $35,01)0  (202
    contingency applied  to all items except  disposal
    cost)
-------
     Two    important    unquantifiable    costs    were
encountered.   The major unquantifiable  cost  was the  6-
month  delay due  to  the dismissal  of Diggs  Sanitation.
The   actual  costs   attributable   to   finding  a   new
contractor,   preparing  for   Diggs'    trial,   and   the
inflationary costs of  construction  over  a  longer  project
duration,  are  not available.   Another  unquantifiable
factor was  that the  Washington County Health  Department
warned several  residents whose  non-drinking water supply
wells  were adjacent   to  the  landfill   area  that  total
chromium  contamination  was  just   above  the  U. S.   EPA
drinking  water standard  of 0.05 ppm.   But  the  public
health  officials  could not  recall  if any  wells were
subsequently  closed.   Fairchild Republic  did, however,
install softeners  and  filter  systems  in several affected
wells.

     Future costs  associated  with  the hot fire pit dump
will   consist   of  ground  water  sampling   at  several
monitoring  wells  and  at  some nearby private   wells.
Precise costs  are  not  available.

PERFORMANCE EVALUATION

     The  response  action  at the Fairchild  Republic plant
is  a good example of  private and public  cooperation to
mitigate  the  threat  posed  by an uncontrolled  hazardous
waste  site.   When the Hot  Fire  Pit dump was  discovered,
the   company    promptly   hired  Metcalf  and  Eddy   to
investigate  the  site  and  cooperated with the state to
monitor  soil   and ground  water and  develop  a remedial
action plan.

      State   officials  did   not   intervene   in   the
remediation,  but  instead  allowed  Fairchild  Republic to
carry  it out  subject  to  state monitoring  and approval.
In   return,  Fairchild  Republic generally executed  the
remedial   steps   in   an  efficient   and  cost-effective
manner.   The  only set-back was the performance of Diggs
Sanitation, the first contractor.   Diggs later was found
to  be disposing of  waste  improperly.    After  a delay,
Fairchild  Republic  selected  Bohager  Waste  Systems to
continue the  operation.    This  time  Fairchild officials
did not  select  the  lowest  bid,   preferring  to assure
themselves of both a  reputable contractor and  a  reliable
disposal site for the waste.

      A   potentially   significant   concern   about   this
 response  action  is  that the  change  of  contractors
 resulted in  a 6 month delay  in work,  during which  time
 the excavation area remained open and exposed.
                                      8-28
-------
Effectiveness of Clay Cap

     Regarding  the  technical  aspect  of  the response,
removal of contaminated material and capping  with a clay
layer  can be  an  effective  long-term  solution  for  a
contaminated  site  such  as this  one.    Several factors
should be  considered in  assessing  the effectiveness of
this  technique  at  this   site:  the  extent  of  bedrock
contamination,  the  solubility  of   the waste materials,
and  the  existing  level  of ground  water  contamination.
Each of these issues will be discussed in turn.

     During   the   removal   of    contaminated   surface
material,  Metcalf   and  Eddy  determined  that fractured
bedrock  zones were  contaminated,  to  a certain degree,
with  precipitated  heavy  metals.    The precipitation of
the heavy  metals is enhanced by  limestone and  dolomite
bedrock  because of  the  high  pH associated  with these
formations.   If  heavy metals have precipitated they will
remain  as  an insoluble  fraction  of  the  bedrock until
dissolved  or  solubilized  by the ground water.   It would
have  been possible, although  extremely  difficult   and
expensive,  to  remove  the  bedrock material.   In this
case,  substantial  major  construction  involving  blasting
and   heavy  construction   equipment   would  have  been
required.  It is questionable whether  sufficient benefit
would have been  derived from this approach.   Further, it
also may have been possible to pump the ground water  and
treat  it  for removal of the contamination.   Although
appropriate   in   certain   circumstances,   it    seemed
unnecessary  in  this case since  the  ground  water  is
currently  not being used  locally  as  a drinking water
supply.  If the  ground water is used as a  drinking water
supply source in the future,  it may have  to  be  treated,
depending on  the relevant potable water  standards.

     The  volatile   organics   found  on  the site   are
typically  highly  soluble  and very  mobile  in water.
Because  the   limestone  formation  at  Fairchild  Republic
did not  significantly  impair  this  solubility, the total
amount of  organics dissolved  in the ground water  should
remain constant  or decrease with time.  There may exist
pockets  of concentrated  organics  in  the  ground water
which, because of  reduced  ground  water movement, would
be measured  in monitor well  samples  for  several years.
However,   most   of  these  should  volatilize,   degrade
chemically or biologically,  or be  diluted  in the  ground
water  over time,  although there  is no accurate way of
determining the amount  of  organics  in the ground water
or their expected behavior for this specific  site.
                                     8-29
-------
 Excavation of Volatile Organics

      There  are  several   important  considerations  with
 respect  to   the  effectiveness  of   the  construction
 activities  of  the  remedial  action.    In  any  remedial
 action involving  excavation,   it  is essential  that the
 nature of  the volatile  organics be  checked to  assure
 that they  are nontoxic  to  the working  environment and
 will  not  cause   atmospheric  pollution.    During  the
 removal  operations,   large   quantities   of   volatile
 organics   were  evolved  through  evaporation  into  the
 atmosphere.   For  this particular site, though,  there was
 little concern over  this evaporation since on-site air
 samples indicated  that the vapors  encountered were  at
 non-toxic  concentrations.

      During  construction  it is also necessary to  assure
 that there  is  sufficient control of  contaminated soil.
 The  movement of  heavy construction equipment can cause
 dust  to   be   carried  in  dry  periods  by  winds  to
 surrounding  areas.   This dust  should be controlled  by
 covering  the trucks that  will  haul the material  from the
 area and  by periodic  wetting  of the  construction site.
 Contaminated   soil   can   also  be   lost  during  wet
 conditions,  through  the   tracking  of  large equipment;
 some of the  muds  on the site can leave the facilities  on
 the  tires  or  treads  of the heavy equipment working  in
 the   area.     There  was   little  apparent   control  of
 contaminated soil  during  this excavation,  other  than
 management of  stockpile size and construction of a small
 berm and diversion ditch.

      The  effectiveness of this remedial  action is  also
 dependent  on  the  potential  increase  in  ground  water
 contamination  due to the   direct  exposure of the  sludge
 or contaminated material  to  rainfall.   If heavy  rainfall
 occurs  during the period  of  construction,  it is  possible
 for  contaminated  material  to  move  vertically  downward
 and  increase the  pollution of  the  ground  water.  Plastic
 sheets might have reduced  the  amount of leachate created
by   intercepting   rainfall.     Such  temporary  capping
measures would have  been especially  useful during the
six  month  delay during 1981, as well as  other potential
exposures to rainfall.

      Since  the  movement  of  ground  water is relatively
slow, there  is  some probability that this  wash out would
not  be  observed  in local monitoring  wells  for several
weeks or months subsequent to the event.   In this case,
there   was   frequent   rainfall  during  the excavation
period, yet  only  one  ground  water monitoring well  showed
an increase  in the level  of contamination.   The  others
decreased, possibly due to dilution.

                                     8-30
-------
Long-term Concerns

     The long-term  concerns  regarding the effectiveness
of  this  action are  (1)  the extent  of contamination of
the  fractured  limestone  and  dolomite beneath  the site
and   (2)   the  influence  of  vertical   ground  water
fluctuations on the teachability of  the  metals.   While
the  percolation  of rainfall  through  the contaminated
zone has been eliminated,  the variation in the  elevation
of  ground  water   is not so  easily  controlled.    The
continuous  natural  rising and  falling  of  the ground
water elevation associated with both  rainfall events and
seasonal variations will  periodically expose  the con-
taminated  fractures  to  lower  pH conditions,  thereby
dissolving  some  of  the metal  precipitates.    As  a
protective measure,  a grout  curtain could be installed,
although  it might  not  be  effective  in  preventing the
metal from precipitating  because voids could still exist
in the bedrock after installation of a curtain.

     In addition,  although it was not  a principal part
of the remedial action plan, since this study focuses on
the  landfill  clean-up,   the  removal  of contaminated
material from the sludge  lagoons should be considered in
terms of  the overall  effectiveness  of  the  site clean-
up.  No  study  or  formal plan for decontamination of the
lagoons was made.   Based  on  the available information,
the  lagoons were  unlined but  probably  underlain by the
natural clay that  predominates throughout the  area.  No
known  analytical   testing was  made  of  the  site  soil
subsequent  to  material   removal   and  prior  to  clay
backfilling.   Visual inspection was  apparently used to
assure complete material  removal.   The effectiveness of
this approach was,  in all likelihood, comparable to the
landfill  remedial  action,  although  no  analytical data
other than monitoring well samples exist  to support this
conclusion.

Level of Chromium Contamination

     Overall, the  excavation technology appears to have
been effective  in  reducing  the  chromium  contamination.
Following completion  of  the  action,  there was  continual
decrease in chromium  levels observed  in  the samples from
ground water monitor wells.   The highest  value reported
prior to this writing was less than 0.05  mg/1 hexavalent
chromium.   Although  no  precise  objective was set,  if
monitoring  data  continues  to  reveal   total   chromium
contamination  at  less  than  0.05 mg/1,  the   clean-up
probably will  have  been effective.    Given the  limited
data on  the organic chemical contamination, an accurate
assessment  of  the  organic  chemical  removal  cannot be
made at this time.

                                      8-31
-------
                          BIBLIOGRAPHY
Barohart Robert.  Fairchild Republic Company.  June 4-15, 1982.
     Personal communications with Environmental Law Institute.

Davis, William.  Bohager Waste Systems.  June 10, 1982.  Personal
     communication with Environmental Law Institute.

Metcalf & Eddy, Inc.  May 1980.  "Soil and Hydrogeologic
     Investigation  of  the  Hot  Fire  Pit  Disposal  Site  at  the
     Hagerstown Facility for Fairchild Republic Company, Hagerstown,
     Maryland."

Metcalf & Eddy, Inc.  May 1980. "Work Plan for Rehabilitation of the
     Hot  Fire  Pit  Disposal Site,  at  the  Hagerstown  Facility  for
     Fairchild Republic Company, Hagerstown, Maryland."

Metcalf & Eddy, Inc.  May 1982.  "Site Rehabilitation Monitoring
     Program  at  the  Hagerstown Facility   for  Fairchild  Republic
     Company, Hagerstown, Maryland."

Metcalf & Eddy, Inc.  July 1982.  "Closure Report for Rehabilitation
     of the  Hot  Fire Pit Disposal  Site at  the  Hagerstown  Facility
     for Fairchild Republic Company, Hagerstown, Maryland."

Ramsey, W. Lawrence.  "Identification and Reclamation of Chromium
     Sludge Disposal  Sites."   Management of Uncontrolled Hazardous
     Waste Sites (1980)i pp. 259-261.

Rich, Warren K. Niles, Barton and Wilmer, Anapolis,  Md. May 24, 1983
     Personal communication with Environmental Law Institute.

Rooney, Mr.  Health Department, Washington County, Md. June 3-14,
     1982.  Personal comunication with Environmental Law Institute.

Steimle, Rick.   Hazardous Waste Division, Office of  Environmental
     Protection,  State  of  Maryland.    June 2-21»  1982.    Personal
     communications with Environmental Law Institute.

Truitt, Win. Roger.   Niles,  Barton and Wilmer, Annapolis, Md.
     May 24, 1983.   Letter to Environmental law Institute.
                                 8-32
-------
                               GENERAL ELECTRIC

                              OAKLAND, CALIFORNIA
INTRODUCTION

     The  General Electric  site  in Oakland,  California,
occupies  about  24  acres  (9.7   ha)   in   a  mixed  use
industrial-residential-commercial  area  in   the  southwest
section  of the  city  about  1-1/2 miles  (2.4 km)  east  of
San Francisco Bay.  An estimated 20,000 gallons (75,700 1)
of  polychlorinated  biphenyls  (PCBs)  and petroleum  based
10-c oil  were spilled onto the  property  at  various  times
during the production and repair of transformers from 1927
to  the  late  1970's.   PCB-oil  was   found  on-site  in  soils
from shallow  to  intermediate depths and  within subsurface
sand  and  gravel  lenses.    Of  the  initial  12  on-site
monitoring wells  sampled, 2 were found  to contain PCBs  in
the water at  levels  of 0.63  and  15.0 parts  per billion
(ppb).    PCS  contaminated  ground  water  was  not  found
off-site  but  the large  volume of the  PCBs  on-site caused
concern within State agencies about the off-site migration
potential.  In  the  storage  and   loading  areas  nearby,
virtually  all  unpaved  soil  had  PCB  concentrations of
greater   than 5 parts per  million  (ppm) and hot  spots of
11,000 ppm PCBs were found.

Background

     Spills,   leaks  and  disposal  of  PCB  contaminated
material occurred throughout the 50 year period of Pyranol
use at the Oakland GE site.   Use of  the  insulating  fluid
called  "Pyranol," consisting  of equal  portions  of PCBs
(Aroclor  1260)  and  trichlorobenzenes,  began in  the  early
1930's  and  peaked in the  mid 1950's.   After  1968, when
transformer production at the  site  ceased, only a minimal
amount  of Pyranol was  used  on site  for  the repair  of
warrantied transformers.  The  last  year  of PCB use at the
facility  was  in  1975 when  the  last  drum of  Pyranol  was
delivered  from  Monsanto  Industrial  Chemicals  Company.
Sources of site contamination during this period included:

     •  Leaks in tanks that sometimes went undetected
NCP Reference
300.66(c)(2)-
(iii)
migration
potential
                                     9-1
-------
     •  Trench  burial  of  liquid  PCBs  and  contaminated
        solids such as dialectric paper

     •  Pyranol spills  from a mobile  filtering  unit that
        would occasionally "blow" from too much pressure

     •  Discharges from  a lab sink  that  emptied out onto
        the  ground,  following  the   collapse  of  a  septic
        tank.

The total amount of Pyranol beneath the site was estimated
at about 20,000 gallons (75,700 1).

     In response  to  a complaint from a GE  employee about
mishandling  of  PCBs  that were  spilled  on a  truck  bed,  a
California Department  of Health Services  (DHS)  inspector
toured  the  site to view  their PCB handling procedures on
July  20,  1979.   He  found  no  improper  handling of PCBs
on-site,  but was asked by the  employee to reinspect.  On
July 30, 1979, he  reinvestigated the  site and  took soil
samples of two oily areas, which were found to have 63 and
170 ug/g  PCB (analyzed  for Aroclor  1254).    Upon  inter-
viewing  the  plant  manager, who  had worked  at  the site
since  the  late  1940 * s,  he  learned   that  no  Pyranol  was
presently  stored   in  bulk.    However,   two  1000-gallon
(3785 1) tanks had been  used  to  store Pyranol on the east
side  of Building 2  (see  Figure  4)  but  they  had  been
removed in 1976.   These  discoveries  led  to the site study
by  GE and their  consultant and the immediate mitigation
measures that followed.

Synopsis_^f^Site Response

      In the  fall of 1981  the immediate mitigation plan was
implemented,  consisting of  a  French drain collection
system,  treatment of  contaminated   ground  water,  surface
sealing  and  runoff control.   A three-armed  French drain
and  sump  were  installed  to create  a cone  of depression
where  the  oil-contaminated  ground water  mound had  formed
under  the tank farm.    The  surface  sealing  involved  a
soil-bentonite  cover  on the  unpaved contaminated areas
with  a gravel cover  to  prevent  its  erosion.   Runoff was
controlled by  installing curbs and  gutters throughout the
site  to  ensure  that  precipitation would  not  become
contaminated before discharge into a  storm  sewer.

      Constructing the  French  drain  and  treatment  system
was the primary activity  in the immediate mitigation plan.
Two of the French drain's three arms  extend on either  side
of  the  tank  farm site, and the  third was placed from the
central  sump  directly  away  from  the  tank  farm.   The
trenches  are about 25  feet deep  (7.6  m)  and  are  filled

                                      9-2
300.63(a)(4)
discovery
300.70(b)(l)
(iii)(D)(O
subsurface drain
-------
 with gravel.  Slotted PVC collection pipes  are  located  at
 depths of 25  feet  (7.6 m),  22  feet (6.7 m)  and 19  feet
 (6.8 m)  and  run  into the sump, which is 29.5 feet (8.85  m)
 deep.  The oil floating on the water in the  sump is  pumped
 with a  skimmer  to a  FRAM oil/water separator  and  pumped
 into a  storage  tank.   The  remaining  oily  water is  then
 pumped  through   a  water  treatment  system  before   being
 discharged  into  the  East Bay Municipal Utility  District
 (EBMUD)  sewer system.
 SITE DESCRIPTION

      The  General  Electric  site  is  located  in  Alameda
 County,  California,  approximately  one  mile  east  of  San
 Francisco  Bay  at  5441  East  14th  Street,  Oakland  (see
 Figures  1-A  and  1-B).    The   latitude  and  longitude
 coordinates  for  the  facility are 37°45I56"  and 122°12'15",
 respectively.

 Surface  Characteristics

      The  local   climate is  characterized   as  being  mild
 marine or  Mediterranean  with little  fluctuation in  temper-
 ature.   The  average  winter   temperature  is  50°F.  The  tem-
 peratures  during  the  summer months  average  around 63°F.
 The  annual average  temperature  for the  area  is approxi-
 mately 57°F.   Temperatures   during  the  month of  January
 have been known to   reach the   low  20*s.   On the average,
 freezing temperatures occur  7  to 10  days  each  year  over
 the  county.   During the  summer  months,  temperatures  have
 risen as high as  115°F.  Maximum  temperatures of  90°  or
 higher occur about  4  days  per  year  in  the  immediate  San
 Francisco  Bay area.

      There is a  wide variation in the seasonal  precipita-
 tion in  the  site  area.   Most of  the  precipitation falls
 between  the  months  of  November  and  March;  very   little
 precipitation  occurs  during the  remainder  of the year.
 Localized  showers  are  infrequent, most of  the rain falls
 during winter  storms  that move  through the  area.   These
 storms are usually of  moderate duration  and  intensity  but
 there  are times when  precipitation  is  heavy  enough  or
 persistent enough  to cause flooding.  Mean  annual precipi-
 tation   is approximately 19  inches  (48.2   cm)  occurring
mostly  during  the  5-month   period  of  November  through
March.

     Relative humidity during the winter months averages
between  85 and  90 percent at night  and  drops to 60 or  70
percent during the afternoon.  The humidity is  less  during
the  spring and  summer  seasons but the driest time  of  the

                                     9-3
300.67(c)(6)
weather
conditions
300.68(e)(i)(E)
climate
-------
Figure 1-A.  General Electric Facility Location
                        9-4
-------
I
Ln
                           Figure  1-B.   General  Electric Facility Location
-------
year  is  autumn,  when  humidity  ranges  from 50  percent
during the daylight hours to 70 percent during the night.

     Winds  are predominantly  westerly,  from the  ocean,
across the bay and  toward  the  San Joaquin Valley.   Strong
winds are unusual.  Windspeeds are less than 6 miles (30.6
km)  per  hour  for more  than 50  percent  of the time  and
exceed  12  miles  (19 km) per  hour for  only 10 percent of
the  time.   The annual  average wind  velocity is  about  8
miles (13 km) per hour.

     The site is located in a coastal region characterized
by  subdued  topography.   Elevations across  the site range
from 20  feet  (6m)  on the northeast boundary at  East 14th
Street,  to  approximately 8 feet  (2m)  along the southwest
boundary along the  Western  Pacific Rapid Transit railroad
line.   In general,  the  drainage  across  the  site  area is
southerly with surface runoff eventually  emptying into San
Francisco  Bay.   The  entire facility is  located within a
100-year  floodplain.   Flooding  may  be  caused  by runoff
produced  by  high-intensity precipitation on the Berkeley
Hills to the east.

     The facility property  is bounded on  the  southwest and
southeast  by  industrial development.    The northwest  and
northeast sides are bounded by residential  and commercial
properties, respectively.

     The  native  soils on-site  consist  of  dense alluvial
deposits  composed of various  percentages of silt and clay
materials.  Overlying the  native  soil,  across much of the
site,  is artificial  fill  composed of  a mixture of sand,
gravel, building debris  and crushed  rock.  The  fill mate-
rial ranges in thickness from 0 to about  5  feet  (0-1.5m).

Hydrogeology

     On-site stratigraphy  is a complex  sequence  of  tightly     300.68(e)(2)(i)-
packed   silty  clay  and  discontinuous   sand  and  gravel     (D)
lenses.  These  deposits are  members   of the  San  Antonio     hydrogeological
formation and  continue to unknown  depths  beneath the site.     factors
The depth to the nearest confined  aquifer is  approximately
230 feet  (70 cm).   A typical geologic cross-section of the
site area to a depth of  60  feet (18 m)  appears as  shown  in
Figure  2.

     Due  to the discontinuous nature  of the strata  beneath
the  site, the  ground water  flow system  in  the  area  is
defined  here  as  a  single  homogeneous  unit extending to  a
depth  of 60  feet  (18 m)  for the  purpose of calculating
average  vertical  and horizontal permeabilities  and ground
water  flow rates.   The  average vertical  permeability  for

                                      9-6
-------
60
FT
18m
                                              CLAY
          Figure 2,  Typical Geologic  Cross  Section
                     of the G,E.  Site  Area
                              9-7
-------
                                                        —8
on-site material  from 0  to  60 feet (0-18 m)  is  5 x 10
cm/sec.   The  average horizontal permeability  is  3 x 10
cm/sec.   The  direction of  ground  water  flow within the
upper 60  feet (18 m) of on-site material tends to be away,
in all directions, from a ground water mound identified at
the northern most corner  of  the tank farm (see Figure 3).
Large fluctuations have been noted in levels of the ground
water mound between December (dry season) and April (rainy
season).   It  seems  likely that the mound  is  produced by
rainfall  collecting  in  the  diked  tank   farm  area  and
infiltrating slowly into the ground.

     There is slight vertical  downward  ground  water move-
ment  extending to  the  northeast  of  the  site but  with
exception of this  area, all  flow appears  to  be occurring
horizontally.    The  average flow velocity  is  in the range
of 5 x 10   and 5 x 10   cm/sec.

     Ground water  levels  in the site  area vary  between
approximately 5 and 30 feet (1.5 and 9 m) below the ground
surface.   The  shallowest  ground water  levels have  been
identified in the southwest  area  of  the  site.   The site's
northern  section  has  much  greater ground  water  level
values.  This  difference in ground water levels across the
site  is   the  result of the  extent  to  which  the site1 s
natural surface has been  covered  over by either buildings
or  asphalt  pavement.    Asphalted  surfaces  and  existing
buildings overlie  deeper ground  water  levels  because
infiltration is not  able  to  occur.   Recharge  areas, those
in which  precipitation can  directly contact  the  natural
ground surface  and  infiltrate  downward,  tend  to have more
shallow ground  water  levels.   The amount  of  infiltration
directly affects ground water levels across the site area.

     It has been  estimated  that  ground water  across  the
site moves  vertically downward at  a rate of  .002 ft/day
(.061 cm/day)  or 30 feet (9m)  over  a 40 year period.
WASTE DISPOSAL HISTORY

     The General Electric Oakland facility began operating
in  1924  and  has   since  undergone  numerous  expansions,
additions  and demolitions.    One  of  the  more  critical
expansions made at  the  facility involved the installation
of an additional oil storage system to store Pyranol.  The
introduction of Pyranol as a transformer insulator/coolant
required a greater  facility oil  storage  capacity separate
from the 10-c  oil  system installed in the  1920' s.   Ten-c
oil (also  called  transil oil)  is  a mineral oil  that  was
used as  a  dielectric  fluid for  transformers prior  to  the
introduction of Pyranol.   Thus  during the  early 1930's,

                                     9-8
-------
                         ;]  u
                    _^°_i^-^j/C ip
      Figure 3. Groundwater Flow Direction
(Source:  Final Phase II Report, G.E., Co., CA, June, 1981)
-------
two 5,000-gallon  (18,927  liter)  oil  tanks  were installed
aboveground at the northeast corner  of  the  present Build-
ing 2 (see  Figure 4).   These tanks  were  used exclusively
to store Pyranol.

     The growth  of the Pyranol-filled  transformer market
paralleled  the growth  of  industrial  and high-density con-
struction in  the  region.   However,  as  Oakland facility's
total capacity  increased  over  the  years,  the  levels  of
Pyranol usage at  the Oakland  facility actually decreased,
due to increased efficiency of the manufacturing process.

     Monsanto  Industrial  Chemicals  Company of  St.  Louis
served  as   the  facility's  sole  Pyranol supplier.   Their
shipments of  Pyranol  to the GE  facilxcy  between 1954 and
1975 varied from a high of 9,245 gallons  (35,038 1) per
year in  1959  to a low  of  55  gallons (208  1)  per year in
1975.

     The production of  Pyranol-containing transformers was
finally  terminated at   the  Oakland  facility in 1964, how-
ever the  facility continued  to  service  units under war-
ranty until the transformer manufacturing plant was closed
in 1975.

     During the  facility1s operation,  Pyranol was pumped
from  5,000-gallon (18,950  1)  tank  cars into two 5,000-
gallon  (18,927 1)  storage  tanks  to the  rear of Building 1.
From  these tanks  the  Pyranol was  transported through an
underground system to  the  rear  of  Building 1.   Since  the
plant  closed in  1975  the  Pryanol  tanks have  been cleaned
and relocated to  be used for waste oil  storage.

     The  tank farm,  located  near the  northern  corner of
Building  17,  (see Figure  4),  consisted of   eleven  tanks
when the  facility closed down  in 1975.   Three of the  tanks
were  used  for  Varsol  (petroleum-based  thinner)  and  the
remaining  eight held 10-c  bil.

     Disposal of  both   solid  and liquid  wastes took place
at  the  GE  Oakland facility over their  operational period.
During  the  years   prior to 1940  when the facility manufac-
tured a number  of products, a  significant  amount of  solid
waste   resulted  from the   production of motors.  The  solid
waste  accumulated and  was eventually  buried in  a  trench
that  was  excavated  in  the general  vicinity  of what  is
presently  Building 17  (see Figure 5, Area 1), and a second
trench  in  the southwest area  of the site  (Figure 5, Area
2).  The burial  of solid waste ceased in the mid-19601s.

     Liquid waste at  this  facility  consisted primarily of
waste   10-c  and  Pyranol  oils.    There  were  two  locations

                                      9-10
300.68(c)(2)(i)
      (B)
amount and form
of substances
present
-------
m* noM •«*   t.w •. n.
NIK WOW* IIM  I.m I*. II.
IOIM 1KCN '1W.  I.trt « II.
KM, ll
  m« Fl«g> JHU
  unintiMi, in
  IttlKKIO
  tlBKI
                                      (•imiiiMi miuMNi
                                      inimiia
                                      tUMIH Ml
                                    •H. ii atarm Htnfmai
                                      mn im u»   I.™ H.
ttn.tr.
  Wit MB* IU   M.«B H
  ItBIWtll* mil* Id*
  HC<4M(
KH.lt
  MM (ION 'It    ,.,» ,;
  IMIMIm •>!•«• Kin
                            Figure  4.   General Electric Site  Layout
                 (Source:   Final Phase  II Report,  G.E.,  Co., CA, June,  1981)
-------
VD
t
                                                  C.33 UOUI° WASTE

                                                  C, Z 380LI0
                                  Figure 5.   Liquid and Solid Waste Locations
         (Source:  Final Phase  II  Report, G.E., Co., CA, June  1981)
-------
on-site where liquid waste was disposed.  Area 3, adjacent
to  Building 7  in Figure  5,  most  likely  received  small
quantities  of  both  10-c  and Pyranol  oils, as  they were
both brought to  the quality control  laboratory  for  test-
ing.   The  laboratory  sinks,  into which  oil  samples were
emptied,  initially  drained into  a  septic  tank.   However
this  septic tank eventually  collapsed and the  sink then
drained directly  to the ground surface and any  waste  oil
from  the  laboratory either the  infiltrated to subsurface
or combined with rainfall runoff.  This practice ceased in
the early to  mid-1960's when 55-gallon (208 1) drums were
provided for test sample disposal.

     The main location where  waste oils were disposed was
a trench,  designated  as  Area 4 in Figure 5.  The trench
was excavated in  the late 1940's for the purpose of waste
burial, after  attempts to  burn 10-c and  other waste oil
in  plant  boilers  were unsuccessful.   Waste  oil  burial
practices ceased  in  the early  1950's  when it  became  plant
policy to  store  the oil  in  drums  and  tanks  and  sell  it
regularly  to  oil disposal  contractors.   Until the  mid-
19501 s, there was no attempt made to  separate  the  Pyranol
from the waste 10-c  oil.   The  two waste oils  were  accumu-
lated  together  in  tanks  and drums located  in the  tank
farm.   Around  1955, the  disposal  contractors  asked that
the two oils be  kept separate.    The  GE management agreed
to carry out the request.

     Liquid waste  spills  most  likely  occurred where  the
waste oil  was  handled, i.e.,  pumped,  filtered  or trans-
ferred, in  significant  volumes.   Three areas  where  these
types of activities  were undertaken are shown on Figure 6.
Each area is described  briefly below.

     Area 1 - comprises the  tank farm;  a  diked,  unpaved
              enclosure which  consisted  of 11 tanks  and
              associated  pumping,  mixing  and filtering
              equipment; due  to  frequency  of operation  and
              the  volume of oil handled,  it was  this area
             where  majority  of  spills occurred.

     Area  2 - includes  the ground surface  in vicinity  of
             the  two  5,000-gallon (18,950  1)  Pyranol
             tanks  and the  forward end  of the rail  pit
             where  oil  cars  were  unloaded by  pumping.

     Area  3  - consists  of  the southwest  end  of  what  is
             presently  Building  1;  the least  likely area
             to have had  significant oil  spills,  however
             there   is  the  chance  that  minor  leakage
             occurred  during   oil-warming   operations
             inside  the building.
300.66(c)(2)
inspection
300.66(c)(2)(ii)
assessing
hazardous
substances
                                    9-13
-------
t
t-'
.p-
                                                   B  s
®
                                                                    Tl
                                      \TFTT
     OC0D
                                          LIKELY SPILL AREAS
                                       Figure 6.  Spill Areas
                                                                               D
                                                                               r
        (Source:  Final Phase II Report,  G.E., Co., CA,  June 1981)
-------
  M.r«  i    I   '     '  a rePresentative from the Hazardous
  Materials  Management  Section of the Department of Health
  Services (DHS)  visited the  GE facility in response to  a
  complaint  made  by  a  GE  employee  concerning improper
  handling of  PCBs  at the  site.    At this  timl,  the DHS
  m^hH^f 1V  the DHS  directed  GE to
  remove all PCB  contaminated  soil  from the  site for
  disposal at a  Class  I landfill.
 *n.January 1980> GE hi«d Brown and Caldwell Consult-
Engineers to conduct the following four activities:

 Activity 1:  Preliminary Investigation

 Develop  operational  history of  facility;  review
 existing geotechnical  information;  identify regula-
 tory agencies  involved                          5

 Activity 2:  Field  Investigation

 Soil  and  ground water  sampling  to  establish  three
 dimensional distribution of PCBs on-site


 tn'lctivity
                              Anal?ses of  Samples Collected
      Activity  4:   Data Assessment and Recommendation

      Evaluation  of contamination problems;  evaluation of
      alternative correction programs.

      Upon  the  completion  of  these activities  and  the
review  of the  Phase  I  report  by  GE  and  the state   it
             he
         at the  site  was  more" extensive  than  had  been
initially  believed  and  would require  action other  than
soil  removal.   Subsequently, the  state issued a  Cleanup
and Abatement Order to GE on  December 5,  1980.  The order
consisted of the following requirements:

     •  Abatement  of discharge of PCB oils  and oily mate-
        rial and other  waste  constituents
                                                          300.66(c)(2)
                                                          inspection
                                    9-15
-------
    .   Submittal  of  a Phase  II  study  by  January 1981
        providing  additional  data  on  the  extent  of
        contamination

    •   A study plan  by January  1981  addressing  control
        and  removal  of oil  and  containment of runoff

     •   By May 1981  a long-term mitigation plan  for final
        site cleanup and corrective measures.

The following section discusses the data collected during
the field  investigative activities  at  the  Oakland site
and the conclusions  drawn from this information concerning
the extent of contamination across the site.

     There were two investigative phases that  took place
at  the  Oakland  site.    Phase  I  entailed  predominantly
Surface  sampling  techniques such  as  shallow .01  boring.
and seismic refraction.  During the ««".1.™e!t^~l
(December 1979-June 1980);  the site was divided  into three
areas  based  on  the  type and  extent  of   contamination
Surface sampling, however, did not  adequately define the
extent  of contamination in all three areas   Areas I  and
III  required additional  investigative  work.   In  January
1981,  Phase  II investigative activities  were  ^itiated
This  second  investigation involved  deeper  sampling and
making  use  of multi-cased  weUs  and borings.  The Phase  II
 investigation was completed in June 1981.   Figure    shows
 the  location of  each of  the  three  areas,   in addition  to
 soil  boring  and  monitoring well  locations  for both
 investigative phases.

      la Area I, surface PCB concentrations  ranged between
 0 1 and 220  ppm.    PCB  contamination  in  this  area  was
  levels  are  restricted to  near  the surface  and
  decrease  to  nondetectable  levels by  a  depth of  5
  (1.5 m).

      By comparison  to Area I, the contamination in Area II
  is  much  more  extensive.    PCB  concentrations generally
  ranged  from  0.33  to  1,900  ppm,  however,  hotspots  with
  concentration levels  up to  14,000  ppm  were  identified
  All concentrations generally  decreased  with Creasing
  depth.    in addition to surface  and  subsurface soil con
  tamination, Area II contained high concentrations °* KB.
  in the  form of free oil  located beneath  the  water  table  at
  the clay-sand interface in  a  number  of  isolated,  discon-
  tinuous  sand  lenses.   Oil contamination  existed  in  soils
  from  shallow  to  intermediate  depths  with  a  greatest
  observed depth  of  32 feet  (10  m) beneath  the tank  farm.

                                       9-16
-------
I
t—'
^»
                                                    -JT  .	rOl-
                                                            J
       LECEHD



£$ SOIL BORING LOCATION



Jt MONITOR WELL LOCATION



A SOIL GRAB SAMPLE
                          Figure 7.   Site Layout Showing Soil  Borings, Wells and

                                       Areas I,  II and  III
                           (From:  Preliminary  Phase I  Addendum,  G.E.,  Co., CA,  September  1980)
-------
The  total  quantity  of oil  in  the  contaminated  area or
plume  of contaminated  ground  water  was  estimated  to be
20,000  gallons  (75,800 1)  and  the  oil  layer  thickness
measured in monitoring wells was a maximum of 8 inches (20
cm).   The original  areal extent  of the oil plume is esti-
mated  as shown  in  Figure  8.   Exploratory  work in Area II
was not complete at the end of the Phase I investigation
due to the extent and severity of the problem.  Additional
data was then collected during a Phase II investigation.

     Following the first field investigative phase at  this
facility, the  extent  of PCB  contamination in Area III was
roughly approximated.   There were some PCBs identified but
definition of the severity and extent of the contamination
was  incomplete.   On the basis of  the data made available
following the  initial Phase I  investigation,  the surface
contamination  appeared  to  be  similar  in severity and  pat-
tern to  that observed  in Area I.  Subsurface PCB contami-
nation within  the  saturated  soil zone was,  at this time,
identified in  only one portion of Area  III,  and free oil
was  not  identified anywhere.   la  the southern portion of
Area III, where  PCBs were detected, contamination extended
to about 2 feet  (61 cm) except at well W503 (see Figure 7)
where  contamination occurred to depth of 15 feet (21m).

     The  state concurred  with  GE  and  its  consultant and
decided  that  additional data would be necessary in order
to  fully define the  problems in  both Areas  II  and  III.
The  additional  information needed on  site conditions would
be  acquired  during a  Phase  II  field, investigation which
would  be restricted to  these two areas.

     The Phase  II  field activities involved the  installa-
tion of  additional ground water monitoring wells and the
collection  of  both  additional  ground  water  and  soils
samples.

PCB  Distribution in Soils—Phase II Investigation  Results

      In  the  western  part  of  the  property,  in  Area  III,
detectable PCB concentrations  extended to a maximum depth
of  10  feet at  soil borings S701 and  S702 and  monitor  well
W731  (see Figure  7).   In  the vicinity of  Building 7,
detectable PCB  concentrations  extended  to a  depth of 20
feet  (6m).    The  highest  PCB  concentrations   found in
surface  soils  in Area  III was 2,500  ppm at S702.  These
levels at S702,  however, decreased to nondetectable  levels
«1  ppb) at a  depth of  15  feet (5 m).

     Monitor  well  W791   is  a  deep multi-cased  well,
completed in a sand zone at a depth of approximately 35 to
40  feet (11  to 12 m).   Soil  analyses from  W791  show  a

                                      9-18
-------
       Figure 8.   Oil  Contamination Zone Boundary
(Source:   Final Phase  II  Report,  G.E.,  Co.,  CA, June  1981)
                          9-19
-------
concentration of 83  ppm at the ground  surface  decreasing
to Less than 0.12  ppm below 10 feet.   PCB  concentrations
in  soils   within  the  35-40   feet  (11-12  m)  zone  were
nondetectable.

     Along  the   northern  boundary  of  the  site,  between
Buildings 6, 4,  and 2, the maximum PCB concentration level
identified was  510 ppm at ground  surface  at soil  boring
W736.   Detectable  levels extended  to  a depth of  25  feet
(8 m) at S710,  S709, and W736; to a depth of 15  feet (5 m)
at S711; and to  a  depth of  10 feet (3 m) at W758.   Again,
all concentrations levels decreased with increasing depth.

     Between Buildings 17 and 2, detectable PCB  concentra-
tions extended  to  a depth of  35  feet  (11 m),  but levels
were less than 1 ppm below 10 feet (3 m).

     The  highest PCB  concentrations  measured  during the
Phase II  investigation were  from  soils at  the  monitoring
well W792,  located between Buildings  1 and 2.    From the
ground  surface  to  a  depth of 11.5 feet (4  m) ,  values of
3,800 ppm  to 5,500 ppm were measured.   Between  15 and 25
feet (5  and 8  m) concentrations ranged  from 900 to 1,400
ppm  and  below 33  feet  (10  m)   concentration  values
decreased to nondetectable levels.

     In  addition  to  defining the  extent  of surface and
subsurface  soil contamination, results  from the Phase II
activities  confirmed  the  extent  of  the  free   oil plume
presented  in Figure 8.

Ground Water Analyses

     Fluid samples  were collected  and  analyzed  from
monitoring  wells  during  both  Phase I   and  II  field
investigations.    The  discussion  that  follows  and  the
conclusions  drawn  result  from the  combination  of  data
collected  during both investigations.

     Ground  water  samples were analyzed for PCB and oil
and  grease  using the  Freon extractable  method.   Using  this
analytical  technique,  if  a  sample  was  found  to  have
detectable PCB  levels  (>0.3 ppb),  it  was filtered to
remove  suspended sol ids and  reanalyzed.  Because PCBs in
oil  tend  to adsorb onto  fine-grained soil  particles, the
removal  of suspended solids ensures that the detected PCB
concentrations   are  within  the fluid   itself  and  not   a
result  of PCB adsorption onto suspended solids.

      In addition,  fluid samples  collected  were  analyzed
 for  all  isomers of dichlorobenzene, trichlorobenzene  and
tetrachlorobenzene.    Samples  were collected from  monitor

                                      9-20
-------
 wells  W612,  W613,  W614  and W625.   The  resulting  concentra-
 tions  from  the  chlorobenzene  analyses ranged  from  non-
 detectable  «0.001 ppm)  to 11.7  ppm.

     Final  PCB analyses conducted on ground water  samples
 collected  from Areas II and  III during the Phase I  inves-
 tigation,   revealed  nondetectable  concentrations   after
 filtering.    PCB  analyses conducted  on samples  collected
 during the  Phase  II study revealed unfiltered PCB  concen-
 trations  ranging   from  0.36  ppb  to  1.8  ppb; filtered
 concentrations were all less than the detectable limit  of
 0.3  ppb.   Oil and grease concentrations ranged  from 6 ppb
 to 10  ppm.

     The overall  conclusions drawn from the  field investi-
 gations  concerning the  extent  of ground water  contamina-
 tion are the following:

     • Detectable concentrations of  PCBs  were  not  found
        in  on-site groundwater;

     • Vertical  migration  of  PCBs  in shallow soils  to
        deeper confined  aquifers  was  insignificant.
PLANNING THE  SITE  RESPONSE

Initiation of Site Response

      In a November  29,  1979   letter,  the  State  Department
of  Health  Services  (DBS) directed GE  "to  remove  all  PCB
contaminated   soil...to   a  Class   I   disposal   site    for
immediate burial"; and to sample  the  site area to deter-
mine  the  extent  of contamination.    This  directive   to
excavate  and   remove the PCB  contaminated  soil was made
because, under State law PCBs  are defined as an extremely
hazardous waste,  and the .law requires that "any hazardous
material disposed  of to  the  land, accidentally  discharged
to  land or accidentally  spilled on to the land  be managed
as  a  hazardous waste."   After  reaching  an agreement with
DHS on  an engineering survey  plan,  GE retained Brown  and
Caldwell Consulting  Engineers  in January 1980 to prepare  a
detailed problem definition and  correction  plan.   Their
draft report  dated June 1980 found a much  larger volume of
contaminated  soil  than was initially  expected.   For this
reason the June 1980  report discussed a  variety  of site
response  options,   aside  from  excavation,  including   the
immediate correction  plan eventually  carried out:   French
drain  and  treatment  system,   and  surface  sealing  with
runoff  control.   The  consideration  of  the  other  site
response options  will be discussed in  the  "Selection  of
Response Technologies" section.

                                     9-21
300.65(b)(6)
immediate
removal
300.66(a)
assessment
-------
     Aside  from  the  legal  mandate  on  hazardous  waste
disposal that compelled  the  state to issue  the directive
to GE,  there were  three  general reasons that  caused  the
state to seek action at the site:

     1.  The  state  was  concerned  about  the  migration
         potential  of the  PCB-oil  under the  tank  farm
         where a ground water mound had formed.
     2.  Contaminated   surface  soil  posed  a  potential
         hazard with direct contact by workers or others.
     3.  Contaminated surface soils also posed a potential
         threat to  surface  waters and water  resources in
         the  San  Francisco Bay  area.   A dry  soil sample
         from an  on-site  drainage ditch with  100  ppm PCB
         caused a US Food  and Drug  Adminstration inspec-
         tor, the DHS and  the  California  Regional  Water
         Quality  Control Board   (RWQCB)  to be  concerned
         about bioaccumulation in edible shellfiish in the
         Bay.

In  a  December 5,  1980 Cleanup and Abatement  Order (CAO),
the RWQCB  found  that  there were "surface  and subsurface
soil  and  water  contamination with PCBs...which create a
serious threat  of  contamination  to  surface and  ground
waters of the State, to aquatic life and to public health.

     The  site response  plan  actually implemented  in the
fall  of  1981  resulted   primarily   from  cooperation  and
coordinated  discussion between,  GE,  DHS  and  the RWQCB.
The  December  1980  CAO   formalized   the  site  study  and
correction  plan  that had been agreed  upon.   According to
an  internal  memorandum from the  RWQCB, the  CAO was issued
to  assure  "adequate  control  of  a  complex   and  severe
pollution problem."  In the CAO the RWQCB ordered GE to:

      1.  Submit  a Phase  II  "Definition  Study Implementa-
         tion Plan"  by January 1981  to  refine the report
         submitted in June  1980.

      2.  Submit a detailed  plan  for "Immediate Mitigation
         Measures" by January 1981  and  implement them as
         soon possible after  approval.  (The RWQCB stated
         in   the  CAO  that  they were "conceptually in
         agreement  with  the  French drain   extraction
         approach" as described  in the Phase I Report.)
300.66(c)(2)
(iii)
migration
potential

300.67(c)(4)
surface soil
hazard
300.66(c)(2)
migration
potential
                                      9-22
-------
     3.  Submit a long term mitigation plan by May 1, 1981
         "to  remove  and/or  treat  contaminated  soil  and
         ground water to acceptable levels..."

     The final  Phase II, "Problem  Definition"  report  was
submitted  in June  1981  and  approved  in July  1981.    A
contract for  the  construction work  was  let in August 1981
and construction was completed in December 1981.

Selection of Response Technologies

     The  selection   of  response  technologies  for  the  GE
site has been and will  continue  to be the  result  of  the
in-depth assessment  of  a  number  of  alternatives.   There
are two  site response  program  plans through  which final
mitigation of contamination at  the  site will be achieved.
The  first  and  immediate correction  plan  involves  those
response technologies  that have  already  been implemented
at  the  site  and   are  presently  in  place.     These
technologies involve the following:

     •  Surface sealing

     *  Surface runoff controls

     •  A French drain extraction system

     •  Ground water treatment and storage

     •  Modification of existing tank farm.

These five response  technologies  are described in further
detail in the remainder of this section.

     The second  response program plan, which  has not  yet
been initiated, is the  "Long Term Mitigation Plan."  This
plan is  presently in  the  development stages.   There  are
three areas  presently  being  studied  for  future use  and
these are:

     •  In-situ  microbial  degradation  of   the   waste
        materials;  possibly  in  combination with  methods
        such   as   solvent   extraction    or   chemical
        pretreatment

     •  Soil  treatment using liquid  detergent to flush  oil
        and soil pores into French drain

     •  Chemical  destruction  using  a potassium hydroxide
        and polyethylene glycol  combination.

     GE   projects  that   implementation  of  one  of  these
techniques  will  take place in  1987.
                                     9-23
-------
     The  assessment  of the  immediate  correction plan
alternatives  involved  the  identification,  screening  and
evaluation of alternatives for each of the  three  existing
areas.   The  selected  response technology  plans  for  the
three  specific  areas  of  the  site   are  based  upon  the
recognition that  there  was significant variation in  the
type  and  range  of  problems   encountered   in  each  area.
However, it was  also realized  that  certain  elements  of  the
actions  taken were  similar   in  application  wherever  a
specific  problem  existed  on-site.    For  example  surface
soil contamination was treated similarily  for  all  areas.

     The PCB-contamination at  the  Oakland  site occurred in
three physical categories:

     •  PCS soil  contamination confined  to fill  material
        at 0  to  5  feet  (0 to  1.5 m) with no  detectable
        levels in subsurface soils

     •  PCB   soil  contamination  extending  into   the
        saturated soil zone

     •  An  oil   plume  within  the  saturated  soil  zone,
        containing appreciable amounts of  PCBs.

The  following section  discusses  the  selection  of  the
response  technologies utilized  to  immediately  mitigate
potential  problems   from  off-site releases  of   PCB
contaminants.

     There were  five  overall  objectives  in the immediate
corrective  plan   for  the  GE  facility and  these were  as
follows:

     •  Prevention  of vertical movement  of  contaminants
        into deeper soils or ground water

     •  Prevention  of  contaminant  movement  off-site  by
        surface runoff or other means

     •  Extraction or  immobilization of free  oil  and
        associated PCBs

     •  Containment and extraction of oily ground water

     •  Meeting all appropriate regulatory requirements.

     The   alternate means  by which these objectives could     300.68(g)
have  been met are  described by specific  area in Table 1.     development of
Table 1 describes the remedial alternatives considered for     alternatives
use  at  the GE site  in both general terms  and their appli-
cability  to each  of the  three  site areas.   Table 1 begins

                                     9-24
-------
                      TABLE  1.    ALTERNATIVE  IMMEDIATE  CORRECTION RESPONSE  TECHNOLOGIES
   Area
Response Technology
    Alternative
                                                        Description
                                                                  Rationale for Rejection/Acceptance
                                                NCP
                                             Reference
              (1) Excavation of Soil
                  and Off-site Disposal
                  (Rejected)
                          Localized or area wide  excavation of
                          contaminated soila and  off-site dis-
                          posal of soils
• Excavation involves  high  risk of per-
  sonal exposure to contamination
» Due to fact that  PCB contamination
  is localized, minimization of excava-
  tion and disposal quantities would
  have required additional  soil
  sampling and testing
• Only two alternative disposal
  facilities exist  and the  use of
  either would have involved long haul
  distances with consequent risks of
  spills
300.70 (b)(2)(c)
                                                                                                                      contaminated soil
                                                                                                                      removal
              (2) Containment by
                  Surface Sealing
                  (Accepted)
                          Sealing to be used  as  an effective
                          barrier to personal contact with
                          soils and to provide limitation to
                          movement of the contamination by run-
                          off or hydraulic movement down to
                          deeper soils or ground water; several
                          sealing materials were assessed;
                            
-------
                                                        TABLE  1.    (continued)
 I
ro
CTi
      Area
                    Response Technology
                        Alternative
  I         (4)  Grading
ontinued)       (Accepted)
                  (5) Surface Runoff
                      Treatment
                      (Rejected)
      II
(1) Excavation of Soil
    and Offsite Disposal
    (Rejected)
                   (2) Excavation,  On-Site
                       Treatment  and
                       Recompile t ton
                       (Rejected)
                   (3) Containment and
                       In-Place Solvent
                                          Description
                                             • Where necessary  the  area  was  graded
                                               prior to placement of  seal
                           • Necessary  If sealing or runoff
                            control  is  inadequate
• Physical removal of contaminated
  soils both saturated and unsaturate
  and transport of excavated material
  to approved disposal facility
                           • Substitutes on-site decontamination
                             of the soils for off-site disposal
                           • Hay have been less expensive than
                             alternative (1)
                             Involves injection of solvents to
                             effect extraction of contaminants
                                                                     Rationale for Rejection/Acceptance
                                                                    Area surface slope needed modifica-
                                                                    tions in order for the newly
                                                                    designed drainage systems to operate
                                                                    properly
                                          Sealing  and  runoff control was
                                          adequate
                                                                                 Necessary  to excavate below water
                                                                                 table  into  sands containing free
                                                                                 oil  resulting  in a need  for ground
                                                                                 water  control  i.e., dewatering
                                                                                 Dewatering posed additional problems
                                                                                 e.g.,  ground water treatment would be
                                                                                 necessary;  possible soil contamin-
                                                                                 ation  by vertical ground water
                                                                                 movement
                                                                                 High risk  of contamination to
                                                                                 personnel  Involved in excavation
                                                                                 and  disposal process
                                                                                * High risks of  offsite discharge of
                                                                                 hazardous  substances  through
                                                                                 erosion and runoff
                                                                                i High cost


                                                                                 If overall process  retained  all or
                                                                                 most of the technical  difficulties
                                                                                 related to alternative  (1),  would
                                                                                 have required  a substantial  amount
                                                                                 of laboratory  and  pilot scale
                                                                                 Investigation  to establish  techni-
                                                                                 cal feasibility
                                        • Full containment not technically
                                          feasible due to fact that there
                                                                                                                  HCF
                                                                                                                Reference
                                                                               300.70 (b)(l)(ii)(c)
                                                                               grading
300.70 (b)(2)(c)(2)
       (i)
contaminated soil
removal
                                                                                300.70 (b)(2)(iii)
                                                                                in-situ treatment of
                                                                                contaminated soils
                                                                                and sediments
                                                                                                                       300.70 (b)(2)(ili)
                                                                                                                       in-situ treatment of
                                                                                                                       (continued)
-------
                                                       TABLE  1.    (continued)
  Area
                Response  Technology
                    Alternative
                                       Description
                                           Rationale for Rejection/Acceptance
                                                                                                                NCP
                                                                                                             Reference
    II
(continued)
Extraction
(Rejected)
  from soil
• Requires full containment, i.e.
  physical bbarriers on all sides of
  property (slurry trench cut off wall)
  beneath area (chemical grouting) and
  on ground surface (surface sealing);
  also requires complex treatment
  system for contaminant removal and
  solvent recovery from extracted
  fluids
would have been no way to ensure
that contaminants would not move
through the horizontal barrier
which would have been constructed
by chemical grouting
A long-term, high energy-consump-
tion ground water monitoring and
sampling program would be neces-
sary following completion of
extraction process; this would be
very expensive
contaminated soils
and sediments
300.70 (b)(l)(iii)(A)
ground water controls
impermeable barriera
300.70 (b)(l)(iii)(C)
ground water controls-
ground water pumping
              (4)  Containment  with
                  Partial Extraction
                  (Rejected)
                       • Includes same containment elements
                         as alternative (3), but extraction
                         elements would be reduced
                       • Would not include solvent injection
                       • Requires treatment of extracted
                         fluids
                                        • Full containment necessary for
                                          system to operate successfully,
                                          however full containment, for
                                          the above mentioned reasons,  is
                                          not technically feasible
                                      300.70 (b)(l)(iii)(A)
                                      ground water controls-
                                      impeermeable barriers
                                      300.70(b)(l)(iii)(c)
                                      ground water controls-
                                      ground water pumping
              (5) Partial Containment
                  with Partial
                  Extraction
                  (Rejected)
                       • Would include slurry trench cutoff
                         wall and surface seal but not the
                         grouting beneath the site
                       • Vertical containment would be accom-
                         plished by continual lowering of
                         water table within contaminated zone
                         by use of extraction system
                       • Phreatophytes would be planted to
                         assist in maintaining hydraulic grad-
                         ients, through ground water removal b
                         evapotranspiration
                                        • Decided that a barrier around
                                          perimeter of property unnecessary
                                        • Unnecessary costs involved
                                      300.70 (b)(l)(iii)(A)
                                      ground water controls-
                                      impermeable barriers
                                      300.70 
-------
                                                     TABLE  1.    (continued)
 Area
               Response  Technology
                   Alternative
                                          Description
                                                                     Rationale  for Rejection/Acceptance
                                                                                                                  NCP
                                                                                                               Reference
   II
continued)
                            Disposal  of PCB-contaniinated  oil  and
                            aludge sediments  at  a Class  I
                            landfill
                                     • A successful French drain system
                                       is operating for similar problem
                                       at a GE site in Pittsfield,  HA
             (7) Ground water
                 Monitoring
                 (Accepted)
                            Monitoring of ground  water that  has
                            been recovered and treated
                                       State and Federal regulations
                                       require that fluids that are
                                       discharged into a surface water
                                       body must be monitored
  III
             (8) Containment without
                 Extraction
                 (Rejected)
             (9) Hell pumping system
                 for Extraction
                 (Rejected)
(1) Surface Grading
    and Runoff Controls
    (Accepted)
                            Employ physical barriers such as
                            surface sealing, a bentonlte slurry
                            trench cutoff wall around the area
                            and chemical grouting beneath the
                            contaminated zone to immobilize
                            the free oil by restriction of
                            ground water movement through contam-
                            inated zones
                            There would be no extraction of fluid
                            phase
                            Installation of wells to recover
                            oil
Grading and construction of berras
where necessary;  growth of
vegetative cover
                                       No way of ensuring the integrity
                                       of a chemical grout curtain, there-
                                       fore there is high risk that
                                       contaminated oil and oily ground
                                       water would move downward through
                                       breaks in grout curtain
                                     • Subsurface materials are hetero-
                                       genous; oil zone configura-
                                       tion not precisely defined thus
                                       would not be efficient; French
                                       drain much more flexible
                                       Large number of wells would have
                                       been necessary due to large
                                       plume size; even if geologic condi-
                                       tions were uniform the number of
                                       wells required would have greatly
                                       increased operational costs
                                     300.70 (b)(l)(iii)(A)
                                     ground water controls-
                                     impermeable barriers
                                     300.70 (bUOUHHC)
                                     ground water controls-
                                     ground water pumping
Only grading (vs.  grading and
surface sealing) deemed necessary
due to insignificant levels of
PCBs present in area
Constructing runoff control struc-
tures such as berms was undertaken
in response to request by state that
GE control storm water drainage
from this area
300.70 (b)(l)(ii)(c)
grading


300.70 (b)(l)(ii)(B);
(O,(2),(5),(6)
surface water
diversions
                                                                                                                  (continued)
-------
                                                                ^ABLE  1.    (continued)
         Area
                       Response Technology
                           Alternative
                                                        Description
                                                                 Rationale for  Rejection/Acceptance
                                                                                                                                HGP
                                                                                                                             Reference
 I
NJ
I, II
& III
                     (1)
Surface Runoff
Monitoring and
Discharge
(Accepted)
Three separate drainage  systems  all
of trtiich eventually  discharge  through
one main outlet
(1) Drainage from bentonite  soil  seal
    areas
(2) Drainage from building roofs
(3) Drainage from paved  areas
Fluids passing through each  drainage
system monitored  separately  and  then
discharged
Provides flexibility  of  system
isolation if monitoring  results
ever indicate high contamination
levels
                                                                                        Establishes effectiveness of
                                                                                        selected response technologies
-------
with those corrective measures  considered  for  Area 1.   As
previously  described,  the  problem  in  Area  I involved
surface  soil PCB  contamination to a  maximum  depth of 5
feet.  Consequently  the  alternative  remedial techniques
     confined to this zone of contamination.
     The  overall  contamination in  Area  II was  much more
widespread than in Area I.  The surface soil contamination
levels  were  higher  and   contamination  extended  further
below  the ground  surface.   In  addition,  free  oil con-
taining  high  concentrations  of   PCBs  occurred  in sand
lenses    Due to the more extensive contamination  problem,
the  corrective  measures  considered for  Area II  involved a
higher  degree  of  complexity,  than those  considered for
Area I.   Table 1 continues  with  detailed  descriptions of
the  remedial alternatives  assessed  for Area II.

      The  Phase  II field investigation activities conducted
in Area  III revealed insignificant  PCB concentration
levels  in both soil  and  ground  water  samples.   On the
basis of the low contamination levels it was  decided that
the  necessary  response in  this   area  would  involve the
grading  of  the area,  as  opposed  to  grading and  surface
seeding  for  other areas.   In addition, the state  required
 that the facility  management  provide storm  water control
 in this  area.

Extent of Site Response

      The ultimate extent of the  site response has not yet
 been established,  as  of  January  1983.  The  site response
 that has already been carried  out, and  is  described above
 is  the  immediate  correction plan; a long  term  remedy has
 not yet been initiated, but  is required by the  state, and
 is  now being developed by GE.    The  goal  and scope of the
 long  term  plan,  as  well  as  the extent of  the  immediate
 correction  plan is considered below.

      The "Long Term Mitigation Plan: as described  in the
 1980 CAO should "remove and/or treat contaminated soil and
 ground water to acceptable levels."  The research for this
 plan, occurring at GE's Schenectady, New York research and
 development   laboratories   includes ,   as   previously
 mentioned,  three areas of study:

       1.  Microbial degradation of  the waste  in-situ or in
          combination  with  other  methods such as  solvent
          extraction or chemical  pretreatment .
300.68OO
initial screen-
ing of
alternatives
  300.70(b)(iii)
 microbiological
 degradation
                                       9-30
-------
      2.   Treatment  of the soil with a liquid detergent  to
          "wash" the oil out of the soil pores and  flush  it
          into the French drain.

      3.   Chemical  destruction  with a potassium hydroxide
          and  polyethylene  glycol  combination similar  to
          the  sodium polyethylene  glycol  (NaPEG)  system
          developed by the Franklin Institute.

 The implementation of a "Long  Term  Mitigation  Measure"  is
 anticipated  in  1987 after  completion of  a research and
 pilot  scale program.

      The   extent  of the immediate  site response was  deter-
 mined  primarily by two  decisions:

      1.   Selection of the French drain instead  of another
          alternative such  as  excavation  and  removal,  is
          discussed in detail  above in  the  "Selection  of
          Site Response"  section, and only  in general  terms
          in this  section.

      2.   The level of treatment for the collected waste-
          water had  to  be established  for  removal of PCB
          laden oil and  grease.   This  decision on the  level
          of treatment for  the water  was  an  implicit result
          of  choosing  the French  drain.    This  system
          collects  PCB oil  and slightly contaminated water,
          which must be  decontaminated  to  some allowable
          PCB concentration before  discharging to the East
          Bay Municipal Utility District  (EBMUD).   EBMUD
          held  a meeting with GE in April 1981, regarding
          the  proposed discharge at which time GE indicated
          that  discharge to the  storm drainage  system was
          not  very  viable,  perhaps due  to required level of
          treatment.

     The  selection of  the  French drain largely determined
 the extent  of the  site  response for the immediate correc-
 tion plan.   In general, the French  drain  was accepted by
 the state based on  their understanding with GE that a long
 term mitigation plan would be  developed  and implemented.
 In  addition,  the  state believed that  some  immediate con-
 tainment and runoff control was needed, but concurred with
GE  and its consultant  that   immediate  excavation  and
removal would  be  excessively  risky and  costly.   However,
because   the state law  required  that  PCBs  be safely
disposed  of,  as  discussed  in  the   "Initiation  of  Site
Response" section  above,  the long  term mitigation  plan is
considered a necessary element  of the site response.
300.70(b)(iii)
(E)(l)
solution mining

300.70(b)(ii)(B)
chemical methods
300.68(j)
extent of remedy
                                     9-31
-------
     The  decision  to  limit  the  concentration  of the
effluent  from  the   treatment  system  to  an  average PCS
concentration of 50 ppb and a maximum of 150 ppb  was  based
primarily on estimated quality of the effluent which  could
be produced  from the FRAM  unit.    It  was  determined  that
these average and maximum concentrations would not  disrupt
the  EBMUD's  treatment  process  or  violate NPDES  permit
compliance conditions.  When  the  EBMUD was asked by  GE  to
set a standard  for  PCBs  in  a revised discharge permit  for
waste going  into  the EBMUD  system,  they referred to  their
wastewater  control  ordinance, which  has  no ^specific PCB
standard, but requires them to prohibit  anything  that will
cause harm tc District facilities.  After  determining that
PCBs would  not  harm  the  system,  the  EDMUD considered  the
limits  set  forth in  the  NPDES permit,  which  also has  no
specific  PCB  standard,  but  only a  limit  on the  amount  of
Total  Identifiable  Chlorinated  Hydrocarbon  (TICH)^. ^   By
calculating the PCB  influent as an  additional  identifiable
chlorinated  hydrocarbon  to  be considered  among  the  TICK
effluent,  the  EBMUD  set  the  PCB  levels given  above,
assuming  that  PCBs  are  not  removed  at  all   and   pass
directly  through  the  plant   (Aroclor  1260  is   generally
considered  to  be  very   refractory).    The EBMUD's  TICK
effluent  was  approximately  doubled by the  addition of the
GE  waste to  about  0.2  ppb, which  is still significantly
below their NPDES permit  level.   This  level was  set by the
RWQCB  to meet  federal  regulations  (40 CFR,  Sections
129.105(4))  which states that  "The ambient water  quality
criteria for PCBs in navigable water  is 0.001 ppb.  Since
Aroclor  1260,  has  a  solubility  of  3 ppb  in water,  the
saturated oil-free  FRAM  effluent  has  a PCB  level  at  or
below  3 ppb  before  dilution.    Subsequently,  a  new
discharge permit was issued  to GE based  on monitoring of
the  effluent from  this  facility  at a point nearer to its
discharge  into  the  sanitary  sewer   after the  FRAM  oil
 removal  unit  wastewater has  comingled  with  other  plant
wastes.
 DESIGN AND INSTALLATION OF RESPONSE TECHNOLOGIES

      The response  actions  finally  selected for use at the
 site, were designed  to  provide  containment and control of
 (1) 'the  oil-contaminated  zone  and  (2)   surface  runoff.
 The oil plume control system  operates to  remove oil   from
 subsurface soils and controls the water table  gradients in
 the  oil  plume  area   to  preclude any movement of ground
 water or other fluids vertically downward  into deeper  for-
 mations and therefore provides  containment  of  contaminants
 in  the  oil  plume  area.   The established  surface runoff
 controls  prohibit   the movement of PCB-contaminated  soils
 into  surface  runoff   and greatly reduces  infiltration of

                                       9-32
300.70(b)(l)
[(1) & (2)]
ground water
controls -
ground water
pumping
-------
rainfall   through   the   soils   to   the   ground  water.    In
reducing   infiltration,   the   runoff   controls  also  act to
enhance  the   ability  of   the  oil  plume control  system to
control ground water gradients.

     The  plans  and  specifications for  implementation  of
the  response  measures  at  the  GE  site  were  completed  in
June  1981.    The  successful  bidder  for  the  project  was
selected  in August  1981.   Construction  began in  August
1981  and  was  completed  in  December  1981.   The  response
program included the following  facilities:

     •  A  surface   sealing  system  of bentonite  and  soil
        overlaid  with  a permeable  gravel   layer;   and
        asphalt  paving

     •  Surface  runoff  controls  including curb  and  gut-
        ters,  catch  basins,  drainage  piping,  drainage
        channels and a monitoring  station

     •  A  three-trench  French drain system with a central
        collection  sump  and mechanical extraction  system

     •  Disposal of recovered PCB-oil and sediments at  a
        Class  I  landfill

     •  A  ground  water  treatment  system  and  storage
        facilities  for  treated  ground water,  sediment  and
        PCB-contaminated oil

     •  Modification  of  the  existing  tank  farm   for
        approved temporary  bulk storage  of PCS fluids  and
        drummed  storage  of sediments.

Surface _S_ea_l_ing  and^ Runoff Control  System

     The design  for the  surface sealing  and runoff control
system  at  the GE   facility  consists  of  two  soil sealing
techniques,  various  types of drainage  controls and  three
separately,  structured drainage systems.   The two  types  of
soil sealing techniques  utilized  are  (1*)  a soil-bentonite
mixture  covered with  a  gravel blanket  and  (2)  asphalt
paving and  base  rock coated with  a surface  sealant.   The
soil-bentonite  seal  was used over  those site areas where
(1)  there  were  high  concentrations  of PCBs,   (2)  where
automotive  traffic  was,  and  currently  is, prohibited  and
(3) those areas where no facility expansion plans  existed.

     A schematic representation of  the soil-bentonite seal
and  a  typical drainage  channel   is  shown  in  Figure   9.
Prior to applying  bentonite  to designated areas, grading
was often necessary to  provide  uniform slopes  for surface

                                     9-33
300.70(b)(l)
(ii)(A,B,C & D)
surface water
controls
-------
^c
I
-P-
        EXISTING
        PLANT PAVED
        SURFACES
SURFACE SEAL ON
CONTAMINATED
SOILS
                                              DRAINAGE
                                              CHANNEL
                                              <
SURFACE SEAL ON
CONTAMINATFD
SOILS
       CATCH
       BASIN
                          CULVERT

       BCNTON1TE /SOIL IMPERMEABLE LAYER
                                                                        GRAVEL
                          Figure 9   Typical Surface Seal  and Drainage Channel

                (From:  Immediate  Correction Plan  Report,  G.E. , Co., CA,  January  20, 1981)
-------
runoff  control.   Following the  grading  process, dry
bentonite  was  applied over the  contaminated  area using  a
truck  designed  with a rear spreader through which the dry
bentonite  was applied.  The bentonite  supply was  kept in  a
hopper  located  on  top of  the  truck.  The  rate of  bentonite
application  depended on  the  rate  at which  the   truck was
traveling.   On  the  average,  the  truck  would  spread 150
tons,  (136 Mt)  of bentonite  over  7 acres  every 2  days.
About  4 pounds  (2 kg)  of  bentonite was  used  per  square
foot  (.093 m ).   Following  behind  the  truck  was a  plow-
type  vehicle which  served  to churn up  the  bentonite and
soil,  mixing  the   two  together.    The  mixture  was  then
compacted  with  a  diesel  driven  roller.   The permeability
of  the  final seal,  when compacted  to 80 percent at optimum
moisture  content,  is  approximately 1  x  10    cm/sec.
Following  application of  the  soil-bentonite  mixture  to an
area,  a six inch  blanket of  gravel was  constructed  over
the  impermeable layer,  and sufficient  curbs  and channels
were  provided   to  control runoff.   Bentonite  and   gravel
were applied over  a total area of  156,000  ft  (14,492 m ).

     All  drainage  from  the  soil-bentonite   areas  is
conveyed to  concrete drainage channels  which  collect the
runoff  for discharge through  a single  outlet.   The  drain-
age  system constructed for the soil-bentonite sealed  areas
is one  of  the three  systems previously mentioned.  The two
other  drainage   systems  that  are  being  utilized control
runoff  from  (1) building  roofs  and (2)  the  site's  paved
areas.   The  effluents  from  the  three  systems  are  passed
through monitoring  systems  before  being  combined and
discharged through a single outlet.   This main  outlet is
located  in the  southwest  corner of the  site  and empties
into a  channel  which  eventually  empties  into San  Francisco
Bay.   Making use  of three  structurally separate systems
provides flexibility of  system  isolation  if  monitoring
results  ever indicate high PCB concentration levels  in the
combined discharge.  The  construction  of  the three systems
involved the reconstruction of the sewer  system around the
plant.    These  construction  activities  were  ongoing
throughout the  site  response program.

     The asphalt  paving  technique was  only  utilized  over
the  area  inside  the manufacturing  plant where  there is
known heavy  vehicular traffic.  A  total  area  of 135,000
ft   (12,542  m ) was  sealed  with  asphalt  during  the  site
response program.   In preparation  for  setting  the asphalt
seal,  the  soil was compacted  using  the diesel  driven
roller  and then  a  gravel  layer was laid down.   Once  these
preparations  were  complete  an oil  slurry seal  was applied
at  a r,ate  of 0.101  gallons  per square  yard (0.38  1 per
0.84 m  ).   This seal was  applied  over  both  existing and
newly paved areas  to seal any  existing fissures.

                                     9-35
-------
     Surface  sealing  was deemed  unnecessary for Area  III
due  to  the  low  levels  of  PCBs  present.    The  state,
however,  requested that  GE  provide  some  degree of  storm
water  control  in  this  area.    The  facility  management
consented to the request by grading  the  area,  constructing
berms  where  they  were  necessary  to  control  runoff  and
establishing a vegetative cover over   the  area.   A  total
area of 154,000 ft  (14,307 m  ) was  revegetated. With  the
use of these techniques,  runoff drainage  from Area III is
controlled  and   directed to   the main discharge outlet in
the southwest corner of the property.

     The  areas  of the site which  were already  paved  with
asphalt required  little or no modification.   Where  modifi-
cations were necessary, construction involved bounding  the
areas  with runoff  diversion  features such  as  curbs  and
gutters.    This  construction  was  undertaken  to  prevent
runoff  movement  onto  unpaved areas  and  to  direct it  to
appropriate catch  basins.

     Drainage  from building  roofs   is  collected and  con-
veyed  to either   catch basins  or  buried   drain lines, or
permitted   to drain across  paved  areas  to installed catch
basins.

     In general,   drainage across  the site is from east to
west,  and north  to  south.   The parking  lot along the east
side of the site,  and  the curb and gutter structure along
East 14th  Street  eliminate  storm water  runoff  from enter-
ing  the  site  from the north.   Storm water  is  prevented
from entering the  site from the east  by a  drainage  channel
along  the  property's  south perimeter that was constructed
as  part  of  the  site  response program.   Along all other
portions of the  site perimeter, concrete curbs  have  been
constructed.
     Much  of  the  construction  that  took place  involved
excavation  of  contaminated  soil.    This  soil  was  never
removed  from the  facility  property and  disposed  of  else-
where.   All  excavated  soils were  used  on  site  for  the
construction  of  the various runoff  control structures.

French Drain  Extraction System and  Ground Water Treatment

     The  system selected to  contain  and gradually elimin-
ate  the  PCB  contamination  problem  in Area II  consists of
three  French  drains,  a  central collection  sump  and  two
pumps.   An  oil-water interface  is  created within the sump
which  enables one  pump  to  remove  the oil  while  the  other
pumps  ground  water to the  surface.  A plan view and  cross
300.70(b)(l)(ii)
(c)
grad ing
300.70(b)(l)(ii)
(D)
revegetation
300.70(b)(l)(ii)
(B)
surface water
diversion and
collection
systems
300.70(b)(l)(ii)
(B).[(2) &  (3)]
surface water
diversion  and
collection
systems
                                      9-36
-------
section  of this unit  are given  in  Figure 10.  As  previ-
ously   described   in   the   "Selection  of   Response
Technologies"  section,  the overall  success  of the  site
response  systems   at  GE  depends upon  the oil  and ground
water  extraction   processes and   their ability  to  control
subsurface  flow and   eliminate the  potential  for   offsite
contaminant migration.   A schematic   diagram of  the French
drain  and  oil   collection facility  is  shown in  Figure 11.
     Extending  from the  extraction  sump are  three  French
drains  each  of  which  consists  of  three 6-inch  (15  cm)
diameter  perforated pipes.   The  three  pipes within  each
arm  are  vertically separated from  one  another by about  3
feet (1m).  The  three  level  design  provides  flexibility in
the  collection  of oil  and ground water.  The  bottom pipes
in each  arm are between  25  and  30 feet  (8-9  m) below the
surface;  the  top  pipes  are  about 20  feet  (6m) below the
surface.    The  piping  is  surrounded by  drain rock  which
extends  within  about 1 foot  (.3m)  of the ground  surface.
The drain rock is  overlaid by compacted  fill  and  then by a
surface  seal  so  as  not  to permit  surface  infiltration into
the  French  drains.   The  lengths of  the  arms are 60, 70,
and  80  feet  (18,  21,  and  24m).    In  the  design  of the
system,  the  lengths  of  the  arms  were  not considered
critical  to the  success  of  the extraction  process.   The
important design  feature  for  the  success  of  the system was
the  3   level  drain arm.    With 3  levels  the  oil-water
interface  could  be  intersected  at various  points due  to
the  existence of a cone of depression.   The  difference in
arm  lengths reflects  decisions  made during  installation.
There  are  two main differences  between  the  as-built and
the originally designed French drain  system.   One of  these
differences involves  arm  pipe placement.  Where buildings
were present  in  the vicinity  of  the  installation  site,
drain  arm  lengths were modified.   It was for this  reason
that the final  arm lengths  varied.   The second deviation
from the  original design was the  absence of  valves  along
the  ins ides of  the pipes, which would have regulated the
fluid  flow.   It  was discovered  during the installation of
the system, that  there  was not  enough flow to warrent the
use of valves and  therefore  they were  eliminated.

     The  location of the  collection  sump with respect  to
the oil  plume is shown on Figure  12,  along with the  soil
borings used to define the plume and  the  observation  wells
that are maintained to  monitor  any changes in the config-
uration and size of the oil plume.
300.70(b)(2)
UiiXcMU)
(2)]
ground water
controls —
ground water
pumping
                                     9-37
-------
                                                TRENCH (TYPICAL)
                                                   6" PERFORATED LINE
                                                                    GRAVEL
                                                                8"PERFORATED
                                                                 PIPE (TYPICAL)
     Figure 10.  Plan View and Cross Section of  French Drain
                  and Extraction Sump
(Source:  Paper by B.E.  Bracken and  H.M.  Theisen,  Brown and  Caldwell,
          CA,  1982)
                                   9-38
-------
                                  FRENCH OflAIN
                                            TO GSOUND*ATER

                                            TREATMENT SVSTEW '
                             * \ \ \ \ \ \
                             *r  \ COMPACTED ^u x
                                 \ \ \
          Figure 11.  French Drain and Extraction System
(Source:  Volume  I,  Preliminary  Phase Report, G.E.,Co.,  1-20-81)
                                  9-39
-------
              LCGCNO
                  O S604 SOIL BORING
                  • W30 MONITOR WELL
                                           PROPERTY LINE
  SCALE
1  IN ^40 FT
                   Figure  12.  French Drain Location
(Source:  Immediate Correction Plan  Report, G.E.,Co.s 1-20-81)
                                  9-40
-------
     Oil and sludge sediments  recovered by the extraction
system are stored on-site in 55-gallon (208 1) drums for a
period  of  90  days after which they are disposed of at a
I landfill.  The oily  ground water treatment system which
was  supplied  by  FRAM  Industrial  Filter  Corporation  is
shown  schematically  in  Figure  13.     Oil   is  collected
through  a surface  skimmer  directly  to  a  storage  tank.
Oily ground water is extracted and pumped to  the oil-water
separator.  The separator consists  of  a rectangular steel
box  made  up  of  a  series   of  vertical  and  horizontal
coalescing, hydrophobic and  oilophobic plates.    The
fabricated steel  box is  20   feet  (6m)  long, 6  feet (2m)
wide  and  6   feet  (2m)   high.    The  plates within  the
separator box cause any fine oil droplets to  coalesce into
larger  oil  globules.   The  larger  globules  more  readily
float to the surface where they are easily collected via a
static  skimming  pipe.   Any  solids  present settle  to  the
bottom of the  separator  and  then  drop  into sludge hoppers
for  collection by  periodic  pumping.    Treated  effluent
flows by  gravity  through a  monitoring  station  and then
into  the  East  Bay  Municipal Utility  District's  sanitary
sewer collection  system.    Effluent  that is in need  of
further  testing   is  pumped  to  a  storage  tank prior  to
discharge, until  additional  tests for  PCB-concentration
levels are conducted.

     As  part  of  the  design phase  of  the   French  drain
system  and  the   treatment  system, detailed  analyses  of
their expected  efficiencies  were  made.    The analysis  of
the  efficiency  of the  French  drain system  involved
simulation  of   the  drawdown  and  inflow  effects  due  to
extraction.    Simulated  effects  were  calculated  using
standard ground water  flow equations.    The  objectives  of
this  simulation were  to determine  (1)  the  inflow rate  to
the drain, (2)  the change in the inflow rate  with time and
(3)  to  predict the drawdown  produced  by  the  operation  of
the extraction system.  With the  results from the simula-
tion,  the size  of  the  pump needed  to  produce  optimum
extraction of  oil  and  water  was calculated.   The simula-
tion  results  also  provided  conceptual  verification that
sufficient drawdown would occur  to  reverse  the  shallow
ground water gradients.

     The expected performance of  the  treatment  system was
evaluated by the pilot testing of a small scale version of
a  specialized  package  plant  coalescer.   The  system  was
tested  at  the  GE  facility  using  small  scale  equipment
rented  from FRAM  Industrial  Filter  Corporation  and
influents similar to  those expected during initial  opera-
tion of  the  extraction  system.   On-site pilot  testing  of
the  treatment  system showed  oil  removal  efficiencies  in
300.70(b)(2)(ii)
direct waste
treatment Class
methods
                                     9-41
-------
the  range  of 95.7 to 99.7 percent.   The  full  scale system
was  expected  to  yield  similar  results.

     It  was during  the preliminary  stages  of  the  French
drain  system installation that the tank  farm  was  modified
to   provide  temporary  bulk  storage  of  PCS  fluids  and
drummed  sediments.   All  stored sediments were  eventually
used  for the  construction of  embankments  as  part  of  the
overall  site drainage  system.   At no  time were  contami-
nated  sediments  moved  off-site.

     Due to the  fact that the  tank farm  was  identified as
a contributor  to the subsurface oil plume as well  as being
the  primary contributor  to  the ground  water  mound  which
had  the  potential to  cause  increased mobility of  the  oil
plume,  it  was decided  that  the tank  farm would be  decom-
missioned  and partially  removed.   This  process  entailed
breaking  down the  boundary  dike  system surrounding  the
tank area,   removing  all  but  4 tanks  and constructing  a
building to shelter  the modified storage area.  A general
layout  of  the drainage  system  and  the surface  sealing at
the  GE site  is shown in Figure  14.

     The construction  activities undergone at the GE site
were  performed  by  several  different construction  crews.
One  crew was responsible for all excavation work; another
crew oversaw the pile  driving  process;  a  third  crew  was
responsible  for  all  the  piping  and  installation  work;
another group was soley responsible for reconstructing  the
sewer  system  and a  fifth  crew was in charge  of con-
structing  the buildings  to  shelter  the  modified  storage
tank  area.    Construction  equipment  utilized   over  the
course of the program  are  listed in Table 2.

     The  site response  program at  the  GE  site was com-
pleted  within a 5-month  period.    The  response  program
began  in August  1981 and  was  completed  in December  1981.
The  firm Brown and  Ca Id we 11 acted as the preparer  of  all
contract documents and provided  engineering  services
throughout  the  duration  of  the project.   Probably  the
single most  important  feature of the construction program
implemented  at the  GE  site was  the  assignment of a  full-
time on-site  project manager  by General Electric.   This
individual  had  a thorough  understanding  of the  site's
history  and  was granted  complete  authority to  execute
contract change  orders  and make  field decisions  for  G.E.

     As  with  many  construction projects,  there  were
unanticipated delays.   The most critical  delays  and  their
causes associated with  the GE project are discussed  in  the
following.
                                     9-42
-------
               OILY
               GROUNOWATER
               PROM
               EXTH ACTION
               SUMf
                    TO
                    SANITARY
                    SEWER
                   Figure  13.   Groundwater Treatment System
                                     TREATED
                                     EFFLUENT
                                     TO EBMUO
TREATMENT
AND STORAGE
BUILDING
               TO
               STORM
               WATER
               SEWER
                             OPEN DRAINAGE CHANNEL-^XTRACT)ONDRAIN
                                               eijup       PIPE
                                               ^^       OUTLET
                         PERMEABLE ROCK
                     8ENTONITE/SOILSEAL
           PERMEABLE ROCK/
           BENTONITE/SOiL SEAL
                                              ^^^^^^^f

                                             DRAINAGE CHANNEL
               Figure  14.   Surface  Sealing and Drainage  System
(Source:   Paper by  B.D.  Bracken and H.M.  Theisen,  Brown &«.Caldwell,  CA,  1982)
                                        9-43
-------
TABLE 2.  EQUIPMENT TYPES AND USES
Type of Equipment
Deep Backhoe
Pile Driver
(A) pneumatic
(fi) diesel driven
Bulldozer
Crane
Grader
Diesel Driven Roller
Bentonite Spreading
Vehicle
Quantity
1
2
2
1
1
1
1
Purpose
Trenching for French drain
installation
Soil stabilization during trench
excavations
Grading; earth moving
Placement of pipes; moving oil/water
separator
Grading
Soil compaction
Bentonite seal construction
               9-44
-------
      In preparation for  the  excavation for the extraction
 sump and French drains,  the  contractor attempted  to drive
 sheet  piling through the  site  soils  to prevent soil cave-
 in   and  ground  water  encroachment  into   the  excavation.
 Initially,  a pneumatic  pile driver was used, however, time
 and  time again  the piles  would  shift and  the ends would
 buckle  due  to the  presence of a hard clay layer below.  It
 was  then decided  to use  a diesel driven  pile driver but
 there  were  still  technical difficulties.   It  is  believed
 that the use of newer  and  thicker piles  would  have proven
 more successful.   Eventually two different techniques were
 utilized to drive   the  piles  using the diesel  driver.  For
 the  excavation  of  the area  for  the  extraction  sump,  a
 24-inch diameter (0.61  m)  auger  was  used  to drill several
 deep holes  in the  sump, permitting the piles to be driven.
 The  French  drain   trenches,  which  were   approximately  25
 feet deep  were  excavated  in sections with  the use  of  a
 backhoe  with  sheet   piling  added   later rather  than
 attempting  to drive  them  into  the ground  during excava-
 tion.   The  reason  the French drain trenches were excavated
 to  a depth  of 25   feet  (8 m) as  opposed  to the  depth  to
 which  oil  contamination had  been found i.e.,  32  feet  (10
 m),  is  because a major  oil-containing sand lense exists  at
 25 feet  (8  m).   It  was  decided  that this  lense  would serve
 as  the  main  extractable  soil unit.   Underlying  this unit
 are  primarily clays and discontinuous lenses.

     Soil  control   was  an important aspect  of  the excava-
 tion process.   As soil  was removed  from the  trench  and
 sump excavations,   it was  piled  according  to contamination
 level.   It was  later replaced  to  its  original excavation
 area and depth.   Contamination  levels were determined and
 logged  during the  field investigations.  Excavation during
 this stage  of  the  project  required a much longer period  of
 time than  anticipated  which  resulted  in higher costs  and
 overall  project  delays.

     Additional  time delays  occurred  during the  response
 activities  at the  GE site due to  contract specifications
 requiring that all  construction equipment leaving  the site
 first  be  inspected and  cleared.   Inspection activities
 included  what is  known as  a wipe  test.    The wipe  test
consisted  of wiping  one  square  foot  of  a piece   of  con-
struction equipment with  a swab  doused in acetone  and then
analyzing  the swab for PCBs.  Wipe  test  analyses had  to
show less   than  100 micrograms   per  square foot  of  PCBs
before  the  piece of equipment could leave  the  site.   When
equipment did  not   pass  inspection clearing the  equipment
to  meet  the  specifications  proved  time  consuming  and
expensive for the contractor.
                                      9-45
-------
     The  monitoring wells  that  are present  on-site, of
which  there are  76,  produced  some problems  during  con-
struction  activities.    Close to  one  third of  the wells
were damaged by impact with  construction  equipment.  The
wells  did  not  extend far enough  above  the ground  surface
to be easily seen by equipment operators.

     Another problem  encountered  involved underground
piping  and  utility  lines.    As-built  drawings   of  the
facility were not available and it was therefore necessary
to spend  a good deal of  time locating  piping  and  utility
lines prior to actual construction.

     The  original  time  schedule  planned  by  GE  for  the
completion  of construction  activities  at the Oakland  site
comprised 120 calender days,  with the  contractor required
to be  finished  by  November  1,   1981.   Neither  of these
deadlines were  met.   The project  was not  completed until
December 1981,  due to the problems described previously.
COST AND FUNDING

Source of Fund ing

     General Electric  Company paid  for  all project costs
which  amounted  to a total  of $1,583,300.   The  state did
not  assess  any   fines  on  GE   to compensate  for  the
monitoring costs.

Selec^tion _jaf_^ Con t r ac to r

     No  information  is  available  on the  contractor
selection process.

Project Cost

     The total  construction  costs  for  surface  sealing and
drainage,  and   the oil   recovery   system  was  about $1.6
million  (see Tables 3,  4  and  5).    This  cost   does  not
include  preliminary  study  and  design  work by  Brown  and
Caldwell.  No  cost information is  available for the cost
of this work, which included monitoring well installation,
sampling and analysis,  and  repair,  as well  as  design and
planning.    The following  cost   information  is   based  on
verbal  discussion  with  a General  Electric engineer;  no
invoices were available.
                                     9-46
-------
Surface Sealing and Drainage
     The   sum  cost  of  $734,000  for   surface  sealing and
drainage   includes  the  expenditures listed  in  Table  3 and
highlighted  in  Table 5.   The $42,000  cost of grading is
split  between  asphalt  and  clay capping   costs  for  the
purpose of calculating unit costs.  At  a cost of $155-000,
the  unit  cost  for the 135,000  square  feet  (12,542 m )  of
asphalt pavement was $1.15/square foot  ($12.36/m ).   At  a
cost  of $177,000,  the  unit  cost for  the  156,000 square
feet  (14,493 m )  of  bentonite capping with  a gravel  cover
was  $1.13/square  foot  ($12.21/m ).    The  unit  cost  for
constructing 4,150 feet  (1,265 m)  of curbs  and  gutters was
calculated by  dividing the  total  cost of $132,800 by  4,150
feet  (1,265 m),  which results  in  a unit cost  of $32/foot
($105/m).
300.70
UXbXiiXA)
surface sealing
Oil Recovery and Treatment  System
     The  sum  cost of $337,000  for  the  installation of the
French drain  system  is based  on drain  arm  lengths of 60,
70 and  80 feet (18,21 and  24 m).   The   unit   cost  of con-
structing a  total of 210 feet  (63m)  of 20-25 feet (6-8m)
deep  trenches  was  about  $1,605/linear  foot  ($5,264/m).
This  cost excludes  expenditures for  the sump and  other
related costs given in Table 4.

     The  operation  and  maintenance   (0. &  M.)  cost for
treating  between 1,000 and 1,500 gallons (3,785-5,678 1)
per  month  excludes  equipment  amortization  and  about two
hours/week of  the plant  manager's  time to   perform batch
treatments.  At a total 0.  & M.  cost of  about $50,00/year,
the  unit  cost   for  this   initial  rate  of  treatment  is
$2.70-4.16/gallon ($0.73-1.10/1).
300.70(l)(b)
(iiO(dXl)
subsurface
drains
300.70(b)(2)(ii)
direct waste
treatment
methods
PERFORMANCE EVALUATION

     The  monitoring  plan  developed  to  evaluate   the
effectiveness  of  the French drain system and the  surface
cover  at  the GE  site  involves the  measurement  of  static
ground water  levels and the analyses  of monitor well  and
surface runoff samples.  Through  this  type of measurements
and analysis, the following four  conditions  are monitored:
(1) ground water, (2)  recovered and treated  ground  water,
(3) recovered sediment and oil, and  (4)  stormwater  runoff.
The monitoring program  at  the  GE  facility has, thus,  been
four-fold.  A new and revised monitoring plan has recently
been designed, however, the details  of this  plan are not
yet available.  The parameter descriptions,  the monitoring
and  sampling  frequencies  discussed below  originate  from
the initial monitoring plan implemented  at the site.
                                     9-47
-------
      TABLE 3.  SURFACE SEALING AMD DRAINAGE COST-GE,  OAKLAND,  CALIFORNIA
	 	
Surface Sealing and Drainage
• Equipment mobilization
• Equipment demobilization
( includes cleaning)
• Paving
• Perimeter fencing
• Drainage system pipe
• Curb and gutter
• Manholes
• Monitoring equipment at
end of manhole for surface sealing
• Supervision (on-site
contractor and consultant oversight)
• Soil removal
• Grading
• Claying sealing; top rock
subtotal
$ 26,000
$ 3,600
$134,000
$ 6,000 ($10/foot, $33/m)*
$150,000 ($18/foot, $59/m)
$132,800 ($32/foot, $105/m)
$ 4,700 ($280 each)
$ 12,000
$ 20,000
$ 47,000 ($23/cubic yard, $30/m3)
$ 42,000
$156,000
$734,100
*Unit costs are as-built
                                     9-48
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TABLE 4.  OIL RECOVERY SYSTEM COST - GE, OAKLAND,  CALIFORNIA
Oil Recovery System
• Equipment mobilization
• Demobilization
• Sump, including sheet pilling
• Treatment system
• Plumbing modifications on existing tank
farm to receive material before treatment
to test for treatment need
• Tank farm building
• Sanitary sewer system modifications
to discharge treated effluent to EBMUD
* Electrical and instrumental
oil recovery system
• Monitoring equipment for EBMUD
• Project management for EBMUD
modifications
• French drain system
• Prepurchased equipment
(oil/water separator,
pumps, water handling)
• Operation and maintenance (excluding
about 2 hours/week plant manager's time)
$ 41,000
$ 14,000
$ 85,000
$ 49,200
$ 8,000
$ 50,000
$ 33,000
$117,000
$ 12,000
$ 20,000
$337,000
$ 80,000
subtotal $846,200
$ 50,000/year
                           9-49
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                        TABLE  5.   SUMMARY OF PROJECT COSTS-GENERAL ELECTRIC, OAKLAND,  CALIFORNIA
I
Ln
O
Task
:3BBKSRaDBSBB=i:xBe!=ia±dQEtVEfl:AK=;:
A. Surface Sealing
and Drainage (a)
1. Asphalt paving
2.Betonite cap
with gravel
3. Curbs and
gutters
B. Oil Recovery System(c)
1. French Draln(d)
2. Operation and
Maintenance of
treatment system
TOTAL Project Cost
Quantity
135,000 sq.ft.
(12542 m2)
156,000 sq.ft.
(14,493 n2)
4,125 feet
(1,265 m)

length:210ft.(63m)
doptli:22.5ft.(7m)
1,000-1,500 gallons
(3,785-5,678 I)/
month
—
Actual Expenditure
Subtotal:$734,100
<$155,000)(b)
($177,000)(b)
($132,800)
Subtotal:$846L200
($337,000)
$50,000/year
$1,580,300
Unit Cost
= =S3S=3:a±±:343E±±9aisnM •«•!••=
$1.15/sq.ft.
($12.36/m2)
$1.13/sq.ft.
(12.21/m2)
$32/foot
($105/m)
	
$l,605/foot
($5,264/m)
$2.70-4.16/gallon
($0,73-1.10/1)
—
Period of
Perfornumqc
1981
1981
1981
1981
1981
1981
1982
1981
                  (a) Subtotal also Includes other costs
                     given in Table 4.
(c) Subtotal also includes other costs
   given in Table 5.
                  (b) Cost Includes half of $42,000 cost
                     for grading.
(d) Excluding sump cost.
-------
Ground Water

     Ground water monitoring  is  performed  to identify PCBs
in  the  ground  water  and  to  determine  changes  in  the
ground water  surface elevation.   The parameters  analyzed
are static water levels,  filtered  and  unfiltered PCBs,  and
oil and  grease.  Water level measurements have  been  taken
monthly  from  all 76  on-site  monitoring  wells.   All  wells
are monitored within  the  same 24-hour  period.   Samples  for
laboratory analysis are collected  from 19  selected on-site
monitor  wells on a  semiannual schedule.

     The  water  levels  measured are  compared to  previous
readings  to  confirm  whether  or not the  operation of  the
French  drain continues   to  result  in a  drawdown of  the
ground water mound  level  and in a  reversal  of the shallow
ground water  flow direction.   The result of  the  reversal
in shallow ground water flow  in  the vicinity of the ground
water  mound,  has been  that  ground water flow  is in  the
direction towards  and  into the French drain  system.
Figure  15A shows  ground  water  levels prior  to  the  con-
struction  of  the French  drain while Figure  15B  shows  the
same area  and  its  ground water  levels 8 months  after  the
start-up of the  system.   It can be  seen by  the  difference
in the configuration  of the ground water  contours and  the
ground water flow direction that  the extraction system has
produced  a  reversal  in   the shallow ground  water  flow
regime.
Recovered, Treated Ground  Water

     The  treated  effluent  from  the  oil-water  separator
process is monitored  to  evaluate  the  treatment  process and
to  ensure  that  the discharge to the district sewer  system
meets   EBMUD  requirements.   The  parameters  analyzed
includeflow  rate,  PCBs,  total  identifiable  chlorinated
hydrocarbons  (TICK),   oil  and  grease  and total  suspended
solids  (TSS).    Parameter  measurement  and  analysis  is
currently  performed  monthly  on  grab  samples.    Average
weekly  values  for  these  parameters  during the  first  8
months of system  operation are  given  in Table 6.

Recovered _Sediment_and, Oij.

     The  sediment sludge  and oil  recovered  by the  treat-
ment  process  is  sampled  and  analyzed  to  determine  PCB
concentration  levels  of the wastes  removed  by the  treat-
ment process.  Parameters  analyzed are  PCBs  for the  sludge
and  oil;  and fluid level  in the  oil   storage  containers.
Sediments are  usually stored on-site in  55-gallon  (208 1)
drums  and samples  of the sludge material  are  collected

                                     9-51
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                                          I INSTALLED
                                          NOVEMBER 19811
                                        LEGEND   0  20  40

                                        — LINE OF EQUAL WATER
                                             LEVEL ELEVATION IN FEET
                                           — SHALLOW GROUNDWATER
                                            FLOW DIRECTION
  Figure  15-A.  Groundwater Contour Map  - September 1981

(Source:   Paper by B.D.  Bracken &  Theisen,  Brown  & Caldwell,
           CA, 1982)
                               9-52
-------
                                             LINE OF EQUAL WATER
                                             LEVEL ELEVATION IN FEET
                                           — SHALLOW GROUNDWATER
                                             FLOW DIRECTION
   Figure 15-B.   Groundwater Contour Map  - August 1982
(Source:  Paper  by B.D. Bracken & H.M. Theisen, Brown &  Caldwell,
          CA,  1982)
                           9-53
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TABLE 6.  RECOVERED, TREATED GROUND WATER MONITORING RESULTS
          FOR FIRST EIGHT MONTHS OF OPERATION
Parameter
Flow, gpd
PCBsa, ppb
Oil and grease, ppm
Total suspended
solids, ppm
Average value
Influent
-
6.5
9.2
5.8
Effluent
1,100
0.1
7.1
5.8
            aActually total identifiable chlorinated
             hydrocarbons.
            Note:  For first 8 months  of operation.
             (From:  Paper by B.D.  Bracken and H.M. Theisen,
                     Brown and  Caldwell,  CA,  1981)
                              9-54
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 from each drum prior  to  it  being  sealed.   Oil samples are
 collected and analyzed on a monthly basis.

 Stormwater Runoff

      Stormwater runoff  is  monitored such  that  an evalua-
 tion can be made of the effectiveness of the bentonite and
 asphalt surface sealing  systems  across  the  site.   Param-
 eters analyzed are PCB  and  TSS  content  of surface runoff.
 Sample collection  for surface runoff  is   automatic.   The
 sample  collection  system   in  this  case,  was  installed
 during the construction  of  the  drainage system.   It  con-
 sists of a portable automatic vacuum compressor sampler,  a
 sampler  actuator  and  sample enclosure.    The  automatic
 sampler is set  to collect  approximately 4  liters  over 24
 hours of operation or 160  milliliters per  hour.   Samples
 are also removed  from  the sampler  after every storm event
 or at least once every 48 hours  for long-duration storms.

      In addition  to  the  seemingly  complex monitoring
 system described  above,  during  the first  6 months  of the
 system's  operation representatives  from the Department of
 Health  Services  observed  operating   procedures   and
 inspected   site  conditions  bi-monthly.    Currently,  site
 inspections are  infrequent  and unplanned.

      In general,  the  combined systems  at  the GE  site are
 per forming as  ant ic ipated.   However,  there  are  always
 differences between predicted and  actual performance effi-
 ciencies.   At  this site, differences  were  noted  between
 predicted  and actual  efficiencies the extraction  system.
 As shown  in  Figures  15A and 15B, the operation of the
 French  drain  system has resulted  in sufficient drawdown to
 control  shallow  ground water  flow  and reverse  flow direc-
 tions   towards  the  French  drain   system.    However,   the
 quantity  of  oil  and   ground  water removed  is much  lower
 than  anticipated.   The  system was designed  to  recover
 14,000-15,000   gallons  of  total  fluids  per  month.
 Currently  between  1,000  and  1,500 gallons  of  water  per
 month  are  pumped  and  treated   through  the  extraction-
 treatment  system;  and  approximately 1 gallon (3.7 1) of
 oil is  recovered per  month.    The overall  consensus
 regarding  these  low recovery rates seems  to be that  the
 system  is  overdesigned  for  the  existing   hydrogeological
 conditions.   As  it turns out, ground  water flow rates in
 the  area  are  much  lower  than originally  estimated.    The
 system was  designed for  a  ground  water flow rate of  150
 gpm.   The  flow  rate   on-site  is only 15  gpm.   In other
words the  design is more conservative  than necessary  for
 the existing hydrological conditions.
                                     9-55
-------
     It  was  explained  earlier in  the discussion  on  Che
site's hydrogeological  conditions,  that  the  ground  water
flow system  was defined as a  single  homogeneous unit  for
the  purpose  of  calculating   average  permeabilities  and
ground water  flow rates.   As evidenced  by comparison of
the calculated  values  for  flow rates  and  permeabilities,
and actual recovery  rates,  it  is  apparent that it is very
difficult to estimate average  values  for these parameters
for strata  that  consist  of discontinuous  clay,  sand  and
gravel units.    The  result  of such  an  attempt,  in this
case,   is  a system designed for much  higher  ground  water
flow rates.   It is  for  this  reason that there  is  such  a
discrepancy between predicted  and actual  recovery rates.

     The combined systems at the GE site  have  successfully
controlled  contaminant  movement  through  the   use  of both
surface and  subsurface  techniques.   The  surface  seal  and
drainage  systems together serve to  (1) reduce  infiltration
of  precipitation into  the   ground  water  system  thus
enhancing the ability of the oil control  system to control
ground water gradients  and  (2) to  direct and  control  the
movement of  surface  runoff such that  all runoff  is
monitored  and   eventually  discharged  according  to   State
regulations.    The  subsurface French drain   system has
worked to reverse shallow ground water flow directions  and
diminish ground water  gradients, thus preventing any
further movement  of  the  oil plume.  The  treatment system
performs   adequately, discharging   an  effluent  with  con-
stituents  that  are within   the   state  and  district1s
concentration level standards.

     In general terms the response  actions  taken at the GE
facility   have  proved successful.   The  extraction system
does  not  recover  materials at  the   rate   which  was
originally  estimated,  but  the effect  produced  has  been
that which was  predicted.   The primary concern during  the
design of the  system was not  oil removal,  but rather  the
immediate reversal of ground  water flow  and  the lowering
of  the shallow ground water  table.   The primary concern
and goal was   to  prevent  any  further  movement  of  the
existing  oil plume.   The removal  of oil was  a secondary
concern.   In this light, the fact that the  system recovers
only 1 gallon of oil  per month is  not as  critical an  issue
as  it might  be otherwise.  The effect  that the operation
of the system has had upon the shallow ground water regime
is that which was anticipated.

     Surface sealing is  applicable  in  any situation  where
there  is  a need to control surface  infiltration.  The need
to  diminish or eliminate  infiltration  will   arise  from
problems  associated  with  a  particular  area's  ground  water
regime.   Surface sealing  is most   frequently  used  in

                                     9-56
-------
conjunction with  some other  contaminant control measure,
such as  ground  water pumping or  a French drain  system  as
in the case of  the  GE site.  A surface  seal  is most  often
used  as  an  ancillary  measure   with   another  technique,
serving  as  an  aid   for  the successful  operation of  more
primary  contaminant controls.   It is  seldom a  technique
that  can  be  utilized  alone  to  remedy  a  ground  water
pollution problem.

     Ground water treatment  systems are  utilized  in situa-
tions where ground  water will be  pumped  to  the surface and
ultimately  discharged into  some  surface water   system  or
back into the ground water system.  The  type  of  treatment
system  selected will depend  upon the  contaminants  to  be
removed  and pretreatment  standards  needed  for  the  local
Publicly Owned Treatment  Works  (POTW)  to meet  water
quality  regulations.  This  technique can either  be  used  in
conjunction  with other  measures,  or  soley  on  its  own,
depending on site specific  conditions.

     The  French  drain  system  is relatively new  to  the
realm  of site  response  actions  and  there  are  still many
questions  concerning its  applicability.   There  are, how-
ever,  some  general  guidelines that can  be  used  during the
response  technique  selection process.

     The  primary  alternative  to a French drain for  extrac-
tion purposes is  the use  of a well pumping system.   There
are situations, however,  in which a well pumping system is
not the  most efficient means to  recover subsurface  fluids.
There  are  four  types  of  conditions  that  influence  the
applicability  of a French  drain system in  a  particular
situation and  these are:    (1) the movement of extractable
fluid  relative  to  ground  water;  (2)  the  permeability  of
the  subsurface  material;  (3)  the plume  configuration and
depth  to plume and;  (4)  the viscosity  and  density of the
plume  fluid.

     The initial consideration  involved in  the selection
of a French drain system  is whether  or not  the fluid to be
extracted flows in  the same direction  as  ground water in
the area*   In order for a  French  drain to operate properly
the extrable  fluid  must be moving with the  ground water so
that it  can be  collected  in a central  sump.

     The permeability of  the subsurface materials  affects
the ease with  which fluids can be extracted.  In a  situa-
tion where  the  materials have a  very  low permeability, if
a well  pumping  system were to be  employed, a large number
of  wells would probably be warranted due  to the need for
close  spacing of the wells.   The more  wells and  pumping
time necessary, the more  costly  the operation.   In  a case

                                      9-57
-------
 such  as  this,  if all  other conditions  permit,  a  French
 drain  may  very  well be  more  cost  effective.   A  French
 drain  system  relies on  gravity  for  much of  the  fluid
 movement.  The fluid is  then  collected in a  central  sump
 area  from  which only one or two  pumps are necessary  for
 final  extraction.   The French  drain  system  is also
 applicable in  situations  where the subsurface material  is
 heterogenous in nature, e.g.  the  GE site.  Where  geologic
 units are  discontinuous,  it  may be difficult  to precisely
 define the  configuration  of  the  contamination  zone.    In
 such  a  case,  the French drain  system  provides  greater
 flexibility  in  terms of  the amount of  area it is capable
 of  extracting  from.    In a  situation  where  the geologic
 conditions   are discontinuous  due  to  impermeable   strata
 such as clay,  the  system  would  not be able to operate and
 therefore would not be considered applicable.

      The  configuration  of the contamination  zone  and the
 depth to the zone and  also  important  considerations.   A
 French drain  system is  applicable  where  contamination
 exists over a large area,  because the system is capable  of
 creating  a large  zone of  influence.  In  the  case  where a
 large contamination  zone  exists,  such  as a plume  with a
 100-foot  radius,  if  a well  pumping  system was  selected,
 the  conditions would demand  that  a large  number  of wells
 be  used  and,  as previously  mentioned,  this results  in a
 very costly operation.   In a case  such as this, the French
 drain should  be viewed as  a  viable alternative.

      The  depth to the plume  surface can also  play  a large
 part  in the decision-making  process.   The deeper  the drain
 trenches  will have to be  excavated,  the  greater the cost
 of construction.

      The  last factors to  be  considered  are the  viscosity
 and  density  of  the  fluid to  be  extracted.   The  French
 drain system  is  most applicable  in  the  case where  the
 fluid  floats  on the water, i.e., its  density  is  less than
 water; and  where  the  fluid has  a low viscosity.  Where the
 contaminated  fluid  is naturally separated  from the  exis t-
 ing water,  with  the use  of a French drain system,  the two
 fluids  can  be  extracted  separately.    This  would  not  be
 possible with a well  pumping  system.   The  viscosity of the
 fluid  is  considered because  a highly  viscous material  may
 cause  clogging  within  the  drains.    The  French  drain
 system, therefore,  is more  suitable  for  recovery of  low
viscosity fluids.
                                     9-58
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                                  BIBLIOGRAPHY
 Bracken,  Brian  D.,  December  1982  and  January  1983.   Personal  communications.
     Brown  and  Caldwell, Walnut Creek,  California.

 Bracken,  Brian  D. and  Theisen, Hilary M.,  of  Brown  and Caldwell.   Cleanup
     and  Containment of PCB's—A  Success  Story.  Presented  at:  3rd National
     Conference  and Exhibition on Management  of Uncontrolled  Hazardous Waste
     Sites.  November 29 - December  1, 1982.   Washington, D.C.

 California  Regional Water Quality Control  Board, San Francisco Bay Region.
     Letters  of correspondence to and from General  Electric Company.

 Condit, Richard.  December 1982.  Personal communication.   California Regional
     Water  Quality  Control Board, Oakland, California.

 General Electric.   General Electric Company Oakland Plant Site:  Volume I,
     Preliminary Phase I Report,  Problem Definition and Proposed Correction
     Program.   June 1980.

 General Electic.  General Electric  Company Oakland  Plant Site:  Volume I,
     Preliminary Phase I Report;  Problem Definition and Proposed Correction
     Program.   September 1980.

 General Electric.   General Electric Company Oakland Plant Site:  Phase II,
     Problem  Definition Work Plan.  January 10, 1981.

 General Electric.  General Electric Company Oakland Plant Site:  Immediate
     Correction  Plan.  January 20,  1981.

 General Electric.  General Electric Company Oakland Plant Site:  Final Phase
     II Report,  Problem Definition.   June  1981.

Hatayama, H.  December 1982.  Personal  communications.  State of California,
     Department  of Health Services, Hazardous Waste Management Branch,
     Berkley, California.

Mah-hing, G.  December 1982.  Personal  communications.  Underground
     Construction, Co., Inc., Oakland,  California.

Rhodes, John.  February 1983.  Personal communications.  General Electric
     Company, Pittsfield, Massachusetts.
                                     9-59
-------
Thayer, J.H., December 1982 and January 1983.  Personal communications.
     General Electric Company, Pittsfield, Massachusetts.

Thompson, A.  December 1982.  Personal communication.  East Bay Municipal
     Utility District No. 2, Oakland, California.

U.S. Department of Agriculture.  Soil Survey, Alameda Area, California.
March 1966.
                                     9-60
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                                  GALLUP SITE

                            PLAINFIELD, CONNECTICUT
 INTRODUCTION

      During  1977-1978,  approximately 1,400  barrels  and
 an unknown  quantity  of  free  liquids  were  dumped  into
 three  gravel   pits   located  on  a   parcel  of  land  in
 Plainfield,  Connecticut.   Chemical  wastes  identified on
 the    site   included   chlorinated   and   unchlorinated
 solvents,   flammable  sludges,  organic  chemicals,   and
 acidic and  caustic  materials.  The  wastes  contaminated
 ground water below  the site  that  discharges  into  Mill
 Brook.   Although contamination  of  Mill  Brook had  not
 occurred,  the  state intitiated remedial  action  on  the
 site  because of  the threat of pollution of Mill Brook
 and nearby wells.   Levels  of contamination in the ground
 water under the  site  exceeded drinking water  standards
 for   copper,  nickel,   iron,  zinc,   cadmium,   dissolved
 solids, chlorides, and various solvents.

 Background

      Hazardous  waste  dumping  on a   29  acre (11.74  ha)
 site   in  Plainfield,  Connecticut  began  in  1977  when
 Stanton  Gallup, the  property   owner,  agreed to  receive
 shipments  of  hazardous  waste  from  the  Dick  Trayner
 Trucking   Company.     Trayner  made  arrangements   for
 Chemical   Waste   Removal,    located   in   Bridgeport,
 Connecticut,  to transport  free liquids  and barrels  of
hazardous  waste  to  Gallup's   property  in  Plainfield.
While  Chemical  Waste  Removal  was  licensed  by   the
Connecticut  Department of  Environmental  Protection  to
 transport  hazardous  wastes   to   licensed  disposers,
neither  Gallup  nor  Traynor had  permits  to dispose  of
 these wastes.

     The  site  was  discovered  in   January 1978 when
hunters on the  property witnessed drums being thrown  out
of  a   box  trailer  into the gravel  pit.    The hunters
photographed the incident and  later  gave the pictures  to
the Conncecticut State Police  (CSP)  and Connecticut
NCP
References
300.63(a)(4)
incidental
observation
by public
                                     10-1
-------
Department  of  Environmental  Protection   (DEP),   which
immediately began  investigating the  site.   Trayner  and     300.64
Chemical  Waste  Recovery were  linked  to  the  disposal     preliminary
operations by  the  photographs,  which showed the  license     assessment
number  of  a trailer  that was leased to Chemical  Waste
Recovery.      Chemical   Waste  Recovery  acted   as   a
transporter for  hazardous wastes  between generators  and
disposers.   During the  course  of police investigation,
Chemical Waste Recovery  was  linked with illegal  dumping
operations  in  Coventry,   Rhode Island.   State  officials
believe  that  when  this   site  caught  fire  in  1977,  an
arrangement  was  made  with  Gallup  to provide  needed
disposal capacity.

     In February  1978, after approximately  one month  of
police  surveillance,   simultaneous raids  were  made  on
Gallup's   property   in   Plainfield   and   Canterbury,
Connecticut   and   on   Chemical    Waste   Recovery   in
Bridgeport, Connecticut.   Gallup,  Trayner,  and  the owner
of  Chemical Waste  Recovery  were arrested  and  charged
with  violation   of  Connecticut   law  prohibiting  the
discharge  of substances  or materials into  the  waters  of
the state  without a  state permit.   Gallup pleaded nolo
contendre  to these charges  and agreed to pay  the state
the sum of $15,000  for the costs  of  immediate protection
and  control   of   the s ite.    Gallup   also  agreed  to
reimburse  the  state for  its  clean-up  costs  up  to the sum
of $750,000.  Further, the state fined him $25,000.

Synopsis of Site Response

     The   Connecticut    Department    of    Environmental
Protection conducted  a  two phase site response.   The
first phase consisted of a hydrogeological  assessment of
the site  and was  conducted  from  June to August  1978  by
Fuss and O'Neill  Consultants under contract to  DEP.  The
second  phase,  which  ran  from June through August 1978,
consisted  of  excavation  and removal operations.   Chem-
trol  Pollution   Services  Inc,   a   subsidiary  of  SCA
Disposal   Services,   conducted  all  phase   2  operations
under  contract to DEP.   Remedial work  included  excava-
tion  of   waste  pits  and  lagoons  and  excavation  and
removal  of approximately 1,400  barrels of  waste.   Chem-
trol   transported   the  excavated  wastes   and  heavily
contaminated  soil  to its  Model  City  Landfill   in  New
York,  580 miles  (928 km) away.   Slightly  contaminated
soil  was  transported 1.5  miles   (2.4  km)   to  a  nearby
landfill    in    Canterbury,   Connecticut.       Clean-up
operations took  two  months with crews  working  12-14
hours a  day, seven  days  a week.

     Treatment of  the ground water was not  undertaken as
part  of  the  site  response  because  the hydrogeological

                                      10-2
-------
 assessment  suggested  that the geology of  the  area  would
 cause a  natural  attenuation  of the plume and dilution of
 contaminants  to  the point where they would  no longer be
 a  threat.   Thus,  the  state's clean-up goal was only to
 remove the  source  of  contamination,  not  treat  the ground
 water.

 SITE DESCRIPTION

 Surface Characteristics

      The Gallup  site  is  located on  a 29 acre  (11.7  ha)
 tract  of  land  in  Plainfield,  Connecticut  (see Figure
 1).   This  vacant  property  is bounded  on  the west  by
 railroad tracks  for about 2,400 feet  (731.5 m), on  the
 north by a power transmission line crossing  the property
 at an oblique angle, on  the  south by Tarbox  Road, and on
 the  east  by  Connecticut  Route  12  and  several   rural
 residential tracts.   Mill Brook  meanders  from east  to
 west across the  northern portion  of the Gallup property
 and passes  under  the  railroad  tracks.   A large wetland
 area is  associated with the  brook.   Before the dumping
 incident,  DEP designated  Mill  Brook  as  a  "class  A"
 stream,  meaning  that  it  was considered  to  be pristine
 and a potential future drinking water supply and that no
 treated  industrial discharges were allowed into it.    (As
 of^January  1983,  it has been  redesignated  "class  B/A,"
 which means  that  it  has been  polluted  but  that  DEP's
 goal to bring  it back to  class A status).   The Gallup
 parcel  was once  used  for a  gravel mining operation and
 its  generally  flat  surface has  many  excavation pits and
 overgrown  stockpiles,   but  no  significant  vegetation
 overall.

      Continental    glaciation   during  the   Pleistocene
 period  significantly affected  the  soils  and topography
 of  the site,  as  it did  the  entire New  England region.
 Glacial  ice advanced through  the area, eroding soil and
 upper  bedrock, then retreated,  depositing  a  lodgement
 (or  lower till)  consisting of  a wide  range  of  materials
 having various textures,  colors and  thicknesses, and  an
 ablation  till  (or upper till) made of  a  friable mixture
 of  sediments  that  ranged  from  silt  and  clay  to large
 cobbles and boulders.

     From  June 6   to  October  30,1978,   Fuss &  O'Neill
 conducted a  geologic assessment  of  the Gallup site using
 22 borings  and 18  test  pits.   The bedrock underlying the
 site was a  metamorphic  rock,  gneiss,  believed to be  part
 of  the  Putnam gneiss.   Its  surface  was  not weathered,
 apparently  because  the weathered zone had been removed
by glacial  scour.   This rock was extensively fractured,
with a predominant  fracture dip of 47 degrees that was

                                     10-3
-------
Figure 1.  Location Map of Gallup Hazardous Waste Site,
           Plainfield, Connecticut
                       10-4
-------
believed  to  dip  in  a  northerly  direction.    Below the
bedrock's  surface  were  found numerous vertical weathered
cavities  or  fractures  that  were  similar  to  solution
cavities  in limestone.   Larger cavities were filled with
a  gray  silt  that  probably came  from  overlying  soils.
Fuss  & O'Neill  believed that  these  vertical cavities or
fractures  were  associated  with  a  vertical fault  with
relative horizontal  motion that was  located near some of
the  borings.    A  bedrock  contour  map in Figure 2  shows
that  the bedrock  surface  rises  beneath a  hill in the
east-central  part  of  the  property and  slopes  northward
beneath  the disposal areas to form the southern flank of
a  buried rock  valley that  contains  Mill Brook and its
sediments.

     An almost  continuous  layer of glacial  till overlies
the bedrock.  A dense to friable gray silt  and fine sand
and  soil  mixture   that contains  clumps  of  medium  to
coarse  sand,  gravel, cobbles and boulders,  this  glacial
till varies from  2-22 feet  (0.6-6.7 m)  thick.  The till
was thickest  on the  hill at the east-central part  of the
property and  thinned  to  the  north and northwest.

     For  most  of   this  tract  of   land,   a  layer  of
interbedded  sands  and  gravels, with  isolated units  of
silt,  overlies  the  glacial till.   This  layer is  3-40
feet (0.9-12.2  m)  thick, and Fuss &  O'Neill  believed it
to  be  deposition  from  glacial outwash  along the  Mill
Brook  valley.  Above the sand  and  gravel  layer lies  a
fine grained  sediment unit originating from glacial Lake
Quinebaug  deposit.    This  unit  was   found  to be 2-18.5
feet (0.6-5.6 m) thick.

     These   upper   layers   of   soils  have  various
distortions in  depth and  area  due,  according to Fuss  &
O'Neill, to erosion  and accumulation of  stream alluvium
and swamp deposition  since glacial time.

Hydrogeology

     Fuss & O'Neill  used  22 monitoring wells placed  in    300.68(e)(2)
borings and 13  wells  placed in test  pits on-site plus 12    (i) (D)
surface water reference points,  which were believed  to    hydrogeological
reflect  the  ground  water   system,   to determine  the    factors
hydrogeology  of the  Gallup  site.   Wells had  polyvinyl
chloride (PVC)  screens  that  were placed at various  zones
below  the  water table and  connected by solid PVG  riser
pipes  to  the  ground  surface.   The wells were  developed
by pumping  so that  they could yield water  for sampling
and react  freely  to  local  changes  in head.   Some  wells
were  sunk  into the  saturated  bedrock  by inserting  the
solid riser piper into core holes in the bedrock and
                                     10-5
-------
Figure 2.  Bedrock Contour Map, Gallup Site
  Source:   Fuss & O'Neill,  January  1979
                    10-6
-------
 sealing  them to  the  rock with  rubber  gaskets and  a
 bentonite seal.

      Fuss & O'Neill  periodically  monitored water levels
 in these wells  to develop the water  table contours and
 define  horizontal  ground water  flow.    To  determine
 vertical flow, pairs of wells  were  installed at certain
 locations  with  differing depths.    This  enabled  the
 engineers  to  compare  the differences  in ground  water
 heads.    The  ground  water contours  shown  in Figure  3
 suggest that  the  shape and slope of the  water table is
 "significantly  influenced  by   the   local   geologic
 materials  and  demonstrates  a  continuous  relationship
 between flow in  the fractured bedrock and the saturated,
 unconsolidated materials," according  to  Fuss  &  O'Neill.

      Generally  speaking,   ground  water   flows  radially
 from  the  hill  located at the  east-central portion of
 Gallup's property.   From the west  side  of  the  hill,
 ground  water moves westerly to northerly  and discharges
 into  Mill Brook and  its  wetlands.  From  the north  side
 of the hill, ground water moves northerly to Mill  Brook
 and its wetland  located east  of the  railroad.  This  flow
 has  a  significant downward vertical  component  of  flow
 caused  by a recharge mound found  near wells SWI,  2D, 2S,
 3D, 3S  and  16, as  shown in Figure  3.

      Several  local features  of the  ground water system
 west  and northwest  of  the main hill  were noted.   Near
 wells   SW  10  and   11,  the water table  is  within  the
 fractured   bedrock  and   moves   northwesterly   with  a
 gradient of 0.05 ft./ft.   (1.5cm/30.48 cm).   Around  well
 SW 12,   the  flow is in the upper fractured  bedrock and
 bottom  5 feet (1.5  m)  of glacial till  and  moves  in  a
 northerly  direction  with  a gradient of  0,02  ft./ft  (0.6
 cm/30.48 cm).   Fuss & O'Neill state  that  the  smaller
 gradient in  this  area  "reflects  the increasing system
 transmissivity  in the  downgradient  direction."   Along
 the flow path near wells  SW 14, SW 18 and SWR,  the  flow
 is  in  the  fine-grained stratified drift  sediments  that
 overlie the  till  and  bedrock.   The  flow is  northerly
with  a  gradient  of 0.01  ft./ft.  (0.3 cm/30.48 cm).  At
wells   SW   15  and  SW  1*71,  the   water  table  gradient
 flattens  further to 0.0025 ft./ft.   (0.08  cm./30.48  cm),
which  is believed  to  reflect  "the  increased  saturated
 thickness and material  permeability in this direction."

     Using  its  monitoring well  data,   along with  some
assumptions  about  relative quantities of  recharge rates
in the  till compared to the stratified  drift areas,  and
about  the  saturated  thickness of the  bedrock  system,
Fuss &  O'Neill calculated  order of magnitude values  for
                                     10-7
-------
o
 I
00
           CO
           o
                                                                                                                                 /F MEW HAVEN TRAP ROCK CO
                   N TRAP ROCK CO
                                                                                                         N/F
                                                                                                ATLAS  WEATHER
                                                                                                     MASTER, INC. (
                                                                                                                                                 MONITOR WELL COMPLETED IN BOBWG WITH
                                                                                                                                                 lOENTincarioN CODE AND WATER  LEVEL FOD
                                                                                                                                                 7-iS-78 SHOWN
                                                                                                                                                 MONITOR WELL COMPLETED IN TEST PIT WITH
                                                                                                                                                 IDENTIFICATION CODE AND WATER LEVEL FOR
                                                                                                                                                     -78
                                                                                                                                                  TEST PIT LOCATION

                                                                                                                                                  GROUNOVMTEH CONTOURS  FOR  7-ZS-78

                                                                                                                                                  SURFACE WATER REFERENCE LOCATION
                                                                                                                                                 DOMESTIC WELL IN THE VICINITY OF THE
                                                                                                                                                 PROJECT
                                                                                                                                                 SURFACE WATER SAMPLING  LOCATION

                                                                                                                                                 OAOUNDWATER SPRING
-------
 material permeability, flow  rates  and flow volumes  (see
 Table 1).  The firm's report stated that "although there
 is an  increase  of more than two  orders  of magnitude in
 the system permeability,  there  is  only a one-half order
 of magnitude  increase  in the flow volume  and velocity.
 That   is  a   direct   result   of   increasing   system
 transmissivity and material porosity."

      Fuss &  O'Neill stated  that  the ground  water  flow-
 pattern,  described above  with respect to flows westerly
 and northwesterly  from  the  main  hill,  was  similar to
 that found northerly  from that  hill.   The  latter  flow
 was presented  graphically  by  two  cross  sections   (see
 Figures 4 and 5;  the locations of the cross sections are
 shown in Figure 3).  These cross  sections  show soil and
 rock materials, ground water heads  and flows  paths.

      Several   local  features  of  this  northerly   flow
 pattern were  discovered.   Ground water  flow  near wells
 SW 6  and SW  8  is within  the  glacial  till  and moves
 northerly.    North of  these wells,   the  flow is found
 mainly  within the stratified drift sediments at wells SW
 1- SW 5 and SW 16.   These sediments  were  thought to be
 from the  Mill Brook outwash, discussed above.  Overlying
 this  outwash  are  fine-grained  Lake  Quinebaug deposits
 that  restrict the  upper  portion  of  ground  water flow.
 These  fine-grained  materials,  combined with locally high
 recharge   rates  caused   by  overlying   coarse-grained
 sediments, have created  a ground water mound 3 feet (0.9
 m)  high.    This  mound causes  a  downward  ground water
 flow, as  shown in Figure 4.

     Apparently,  the  water table in this portion of the
 property  fluctuates  with  the seasons.   During dry summer
months, the ground  water  discharges into Mill Brook and
 its  wetlands  through a  deep flow  path.    During winter
months, the water table  is higher and a second  path of
discharge  exists   through  the   coarse  materials  that
overlie  the   fine-grained  Lake  Quinebaug deposits  (see
Figure  4).    According  to Fuss  &  O'Neill, "a seasonal
water  table rise  of 2 feet (0.6  m) or more would cause
 flow  rates  to  increase  by  more  than  one  order  of
magnitude along the upper  portion  of  the  water table due
 to the increased material  permeability."

     Beavers  have modified ground water flows  beneath
the northern portion Gallup property  recently.  A beaver
colony  built  a dam across  Mill  Brook where  it  passes
under the railroad,  creating a small  impoundment  across
the  stream channel  and  raising  the  elevation  of  the
surrounding wetlands.   This  seems to have changed  the
radial  flow  system  discussed above  to  a  flow  through
system, whereby the pond recharges the ground water

                                     10-9
-------
TABLE 1.  ESTIMATE OF HYBROGEOLOGIC PARAMETERS,
          GALLUP SITE
0) r*
01 >
(- 1U
m "J "O
^ -C X
Z LJ CO
10
Q £
Saturated
Thickness
-— ffl
0 T)
o x*
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> t.
Ul
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Q.
-meability
Ft. /day)
OJ ^
a
Average
charge
w Path
„ 
5 01
li
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i

-— I!
LL Q


CM
CD
Tj


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d) LJJ_
-- ^ p
£ Q £
O "a 5
? £ tf

« o 5
3 i =
Q 0) LL
Stmrce
               & O'Neill, January 1979
                   10-10
-------
 Figure 4.   Cross-Section A-A,  North-South,  Gallup Site
                    MILL  BROOK
             TRIBUTARY MILL BROOK
    MONITOR WELL 3W2D w 5 /£
TEST PITS/ »
—   MONITOR WELL SWI
    MONITOR WELL SW6
                             ELEVATION US.G.S.
         Source:   Fuss  & O'Neill,  January 1979
                                10-11
-------
        Figure 5.  Cross-Section  B-B,  East-West, Gallup Site
      WELL SW 5
03
i
03
Ul
CO

CO
CO
o
tr
CJ
      WELL SWI6
WELL SW7D
      WELL SWI3
      WELL 5WIS
                                ELEVATION U5.G.S.
          Source:   Fuss &  O'Neill,  January  1979
                               10-12
-------
system  along the  northern  and  eastern wetland-terrace
border  and  the  ground water  flows  westerly through  the
terrace  to  the  railroad.    However,  ultimate  discharge
still is into Mill Brook.  The changed  flow patterns  are
shown  in Figures  5  and  6  (in  Figure 5,  the  beaver-
altered  flow pattern  is referred  to as "Flow Path  in
December").

WASTE DISPOSAL HISTORY

     Disposal operations took place  at three  locations
on the  Gallup property:  a seepage bed, a primary barrel
pit and  chemical lagoon, and a secondary barrel  pit  and
liquid  burial  area (see Figure  7).   The  disposal  took
place sometime during 1977.

Seepage Bed

     The seepage bed was an  area  approximately  50'  x  40'
(15.24  x 12.19   m)  that  had been  excavated down  to  the
glacial  till  and  partially  backfilled   with  crushed
stone.   Some of the  layer of crushed stone was  covered
by  an  inverted  dump truck body,  which  in  turn  was
covered with soil.  A metal  pipe  connected  the  dump body'
to the  surface.   Liquids were pumped  through the  pipe
into  the  dump  body and  then seeped through the  crushed
stone into  the   surrounding  soils.   An unknown quantity
of liquids were  disposed of in this manner.

Primary Barrel Pit and Chemical Lagoon

     This was  a pit  about 0.4 acres  (0.16 ha)  in  area
and  about  10-15 feet   (3-4.6 m)   deep.    Approximately
1,200 barrels  of wastes were dumped  into  the southern
portion of  the  pit,  while the northern portion was  used
as a lagoon for  an unknown quantity of free  liquids.

Secondary Barrel Pit and Liquid Burial Area

     This area was  located about  100  feet  (30.48  m) west
of  the  Primary  Barrel   Pit  and  near the  railroad.   It
covered 0.67 acres  (0.27 ha)  and  was  about  7-10 feet  (2-
3 m)  deep.   The  Secondary Barrel  Pit  contained  about  200
drums of wastes  and an  unknown quantity of free  liquids
apparently  had   been  dumped  into  it  and  covered.    At
least  two  layers  consisting of  crushed drums,  liquids
and soil were discovered here.

DESCRIPTION OF CONTAMINATION

     Fuss & O'Neill  conducted  a field  investigation at
the  site consisting of  ground  water, surface  water  and
soil  samples.  Ground water  samples were taken  from

                                     10-13
-------
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                • i«i.l»    MONITOR WELL IN BORING WITH  li'7-78 WAT Eft

                         LEVEL INDICATED.
                X n> tt   MONITOR  WELL IN TEST PIT WITH IZ-7'T8  WATER

                         LEVEL INDICATED,
*	   SURFACE WATER REFERENCE LOCATION WITH
         WATER LEVEL INDICATED.

-^150
         '-.ROUNOWATER CONTOURS FOR 12-7-78
                                                                          I, BASE  MAPPING  1953 DOT PLANNING MAP


                                                                          2. PROPERTY LINES ARE APPROXIMATE
     TAR BOX ROAD^SITE
CHEMICAL  WASTE DISPOSAL ARE

 WATER  TABLE  MAP

  PLAIUFIELO .  CONNECTICUT
                         OROUNOWATER FLOW PATH
                                                                          3  CONTOURS MAY BE CHANGES DUE To
                                                                            EXCAVATION
                                                                                                                                                                                     hrj
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                                                                                                               SECONDARY  BARREL PIT S

                                                                                                               LIQUID BUR./'.L AREA
                                                                                                                          APPROXIMATE LIMIT OF CONTAMINATED

                                                                                                                          SOIL AT GROUND  SURFACE
                 [SEEPAGE  SEP
                                          LIMIT OF GROUNDWATER  8, SOIL

                                          CONTAMINATION  BASED ON

                                          HYDROGEOLOGIC  8 CHEMICAL

                                          ANALYSIS  CONSIDERATIONS
                                                                                                            CHEMICAL WASTELA600NJ
                                                                                                               PRIMARY BARREL DISPOSAL PIT
                            MONITOR WELL COMPLETED IN BOSING



                            MONITOR WELL COMPLETED IN TEST PIT




                            CORE CONTAMINATION DURING  JULY SAMPLING




                            S'J""T'$.AU-P_PL1' "ELL PROXIMATE TO  AREA
                            OF INVESTIGATION



                            SURFACE WATER SIMPLE LOCATION




                            THICKNESS  OF LACUSTRINE  SILT  UNIT
                                                                                                                                                              H-

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-------
monitoring  wells  that had  been placed  in area  borings
and test pits  in  and  around the  apparent disposal areas,
as well  as from  nearby  domestic  water  wells.   Surface
water  samples  were   taken  at  points   that   had  been
selected based  on their relation  to the disposal  areas
and current knowledge  of the geology and hydrogeology of
the site.   As  the  samples  were analyzed,  the new  data
were used to expand the network of monitoring wells.

     Water  extracted   from  the  wells  was   initially
analyzed  for   three   field  parameters:   specific  con-
ductance,  pH  and in-situ  temperature.   In addition  to
these  parameters,  samples  taken  in  July   1978  were
analyzed  by  gas  chroma tography  for the  presence  and
relative concentration of  metallic ions.  When chemical
species  were  identified,   they  were verified  by  more
detailed gas  chromotography and atomic absorption.   Gas
chromotographic methods  used  included  flame  ionization
detection   for   aromatics,   hydrocarbons,   esters   and
ketones;  electron  capture  for  chloro  compounds;  and
ultra  violet   for  phenols.    These methods  had  the
following detection limits:
    Ultra Violet

    Electron Capture

    Flame Ionization
Lower Detection Limit

1 ppm

1 ppm

1 ppm
Accuracy
± 0.05 ppm

+,   10 ppm

+   10%
    Source:   Fuss & O'Neill,  January  29,  1979.
     A  second set of  ground water  samples  was  taken in
October   1978  and  analyzed  for  indicator  parameters,
hydrocarbon constituents  and  metallic  ions,  with  the
latter being evaluated directly by atomic absorption.  A
third  set  of samples  was  taken in  December 1978  and
similarly analyzed.

     The results  of  the  sampling and  analysis  program
are discussed below with respect to each disposal area.

Seepage  Bed

     Prior  to  installing  the  monitor  wells for  this
 area,   Fuss   &   O'Neill  obtained   some   contamination
 information   from  the   clean-up  contractor.     During
 excavation  of   the   inverted   dump   truck  body,  the
 equipment operator and  observing  geologist  encountered  a
 vapor irritant  that  caused  a burning sensation  in their
                                     300.68(e)(2)
                                     (D(B)
                                     amount and form
                                     of substances
                                     present
                                      10-16
-------
eyes and mouths.   They left the  pit  open for some time
to  allow  the  vapors  to  subside,   then the  clean-up
contractor  sampled  and analyzed  the  soil  moisture and
ponded  surface  water  that  resulted  from  a rainfall.
Results  indicated  a  PH of  less  than 2  and a specific
conductance  o£  contact  water  exceeding 10,000   ohms,
suggesting  that  a low  pH liquid had been dumped  here.
The contractor  then  took  soil samples from  the test pit
walls and  performed  an extraction analysis  for metallic
ions.  Metals found included:
    Iron as Fe
    Manganese as Mn

    Copper as Cu

    Zinc as Zn
    Nickel as Ni

    Chromium as Cr

    Cadmium as  Cd

    Cobalt as  Co
    Free Acid  as B^SO^
    Equivalent Acid as H,
25 -
2.7 -
1.5 -
0.2 -
0.2 -
0.3 -
0.1 -
0.24
0-1
1.5 -
6100
98
7.9
9,7
5.8
4.2
4.0
- 0.33
.3%
• 3.0%
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1


     Source:   Fuss & O'Neill, January 29, 1979.
 Fuss   &   O'Neill  believed    that   these   data   were
 characteristic of an industrial pickling liquor.

      Based on  this  information about soil  contamination,
 Fuss &  O'Neill installed monitoring wells SW  10,  11 and
 12  within the  fractured bedrock  system and  located  in
 and around  the Seepage Bed (see Figure  7).   Significant
 levels  of  contamination  were  found in  the  July  and
 October   samples;   indicator   chemical  analysis  showed
 elevated  total dissolved solids,  total acidity, and very
 low pH.   Various solvents were found  in wells SW 11 and
 12,  including  acetone,  methyl ethyl  ketone  (MEK>, and
 methatvol.    Analysis  also detected  a nonvolatile  salt,
 possibly  a  high molecular  weight  nitrogenous compound
 believed  to be an  industrial  dye.   This *»bs'f1" h*d*
 concentration of about  100  ppm at  well SW  11  (it also
 was  found  at  wells  SW  73,   7D,  9,  10 and  12).   The
 analysis    for   metallic    ion    concentration    found
 significant  quantities  of   dissolved  copper,  nickel,
 iron,  zinc, and aluminum, plus trace levels of titanium,
 chromium, silver, and cadmium.
                                       10-17
-------
       Downgradient   from   the    Seepage    Bed,    lesser
  contamination levels were observed  in wells SW 9   14   15
  and R,  as  shown in Figure 7,  although each well  showed
  elevated dissolved  solids concentration  and  a  low pH
  Trace  levels of  hydrocarbon  compounds  were  found   in
  wells SW 9  and  14,  but wells SW  18 and R had very high
  concentrations of ethanol, methanol, isopropanol, ethyl
  acetate, plus  trace   levels  of  trichloroethylene  and
  tnchloroethane,  which suggested  to Fuss  & O'Neill that
  dumping  activities  other than   what   occurred  at  the
  Seepage  Bed  were  responsible.     Metallic  ion  con-
  centrations  in all  downgradient wells showed significant
  levels  of iron and nickel in wells  SW 9,  14 and  18,  and
  trace   levels of  copper,  nickel,   zinc,  titanium  and
  cadmium.

 Primary  Barrel Pit and  Chemical Lagoon

      Most   of  the  dumping   occurred   at   this   area
 including about 1,200 barrels  and  an unknown quantity  of
 free liquids.   Barrels  were dumped  in the  southern part
 of  the   pit  and  liquids  were  found in a  pond  in the
 northern part, as shown in Figure  7. Wells SW 1,  6, 16,
 J and K  were  placed  in  and around  this area,  as shown  in
 Figure  7.    Underlying  soils  were   found  to  determine
 significantly the direction and extent of contamination;
 the  Primary  Barrel  Pit  was  located  in   free-draining
 soils under  which lay  or  almost  continuous silt  unit,
 the Lake Quinebaug deposits.

      Fuss &   O'Neill  observed  that  during  the  period
 between  cessation of dumping activities  in mid-winter of
 1978 and the  first series  of  samples  in  July   1978,
 contaminated ground  water in the saturated  section  above
 the  silt unit  flowed  radially  west,  north  and east and
 discharged  into the wetlands northeast   and  east  of the
 pit.   Although contamination also  was found within and
 above  the silt unit,  wells  SW 1,  4, 5, 25,  2D, 3S and 3D
 showed  littled  impact.    However,   the   October samples
 from well SW  1 showed  a significant increase in hydro-
 carbon constituents  (indicator parameters   showed  a 12-
 fold  increase in chemical  oxygen  demand value  and a  6-
 fold  increase in   total   organic   carbon/total  carbon
values)   below the   silt   unit,  indicating  that  con-
 tamination had broken through  the silt unit  between July
and October.   Metallic ion  concentrations for copper and
nickel also increased during this period.

     East  of  the Primary Barrel  Pit, wells SW 4  and  5
remained  unaffected by the  dumping  throughout the  period
of investigation.   Fuss &  O'Neill  stated that  although
normally  the  radial  ground  water flow at the site  would
have  carried  contaminants  to  these  wells,   the changed
                                     10-18
-------
flow  patterns  resulting  from  the  beaver  'dam,  which
caused water  to flow from  the  area of the wells  toward
the pit, prevented contamination of the wells.

     South of  the  pit,  wells SW 6 and 8 were  relatively
unaffected  by   disposal  activities.    The  engineers
reported  that  SW  6,  located close  to the  pit  and  its
nearby  temporary  barrel storage  area,  had trace  levels
of  TCE   and   trichloethane,  possible  resulting   from
migration of these volatile  chemicals laterally  from the
pit area through unsaturated soils.

     Although breakthrough of contaminants did not occur
in the wells to  the  east and south of the Primary Barrel
Pit, breakthrough  seemed to have occurred in  wells  SW K
and  16,  located  near  each  other  within  the pit  (see
Figure  7).    Well SW K was screened  in  the saturated
material  in  and  above   the  silt  unit, while  SW 16  was
screened in the Mill  Brook  outwash sediments immediately
below  the  silt unit.    Significant  contamination   was
found  at  each  well  with  individual parameters   more
concentrated at  SW K,  above the  silt  unit,  than "at SW
16.   Hydrocarbon  solvent  concentrations  at both wells
had similar compositions and were  at the  20  ppm  level.
Low level  metallic  ion contamination was significantly
higher at SW  K than at SW 16, suggesting again  that the
silt unit retarded migration.

Secondary Barrel Pit and Liquid Burial Area

     This disposal site was  a linear trench  adjacent and
parallel  to   the   railroad  in  the  northeast  corner of
Gallup*s  property.   About  200  barrels of  wastes  were
buried  here  along  with an unknown quantity  of  free
liquids.  Wells  SW 7S  and 7D were placed close  together
next to  the Secondary Barrel Pit, wells SW 13,  0, P, Q,
17S and  17D were  located northwest and downgradient  from
the pit, and  wells  SW  15,   18 and R were  situated  more
distant  from the pit and to  the west  (see Figure 7).

     Indicator parameters at wells SW 7S and 7D  showed a
sharp decline  in  contaminant levels  from July  to October
but some increases  from October to  December, resulting
in a relatively  lesser decline as measured  between  July
and December.    At well SW 7S,  chemical  oxygen  demand
went  from 8,050  mg/1  in  July  down to  3,900  mg/1 in
October  but  back up  to  4,900  mg/1  in  December.   A
similar  pattern was  observed for  dissolved solids, while
chlorides  and  organic   carbon  concentrations increased
throughout the  study  period.  Well SW 7S had some  of the
highest  levels  of contamination by metallic ions  of any
wells  tested,  with very high concentrations  of copper,
aluminum,  nickel,   iron,  manganese,  magnesium,  zin'*

                                     10-19
-------
chromium,  cadmium  and boron.    These  levels  decreased
from  July  to October  but  returned to about  the  initial
levels  in  December.    Even  at  their  lowest  point  in
October, some levels were  still extremely excessive:  for
example, copper went from  1,185 mg/1  in July to 625 mg/1
in  October, but  Connecticut's  drinking  water standard
for copper  is 0.5 mg/1, and most  accepted  standards  for
adverse  impact  to sensitive fresh water  fish  are  below
1.0 mg/1.   The  results from wells SW 7D  were  similar to
SW  7S  - significant  levels  of  copper,  nickel,  iron,
zinc, chromium and cadmium.

     Downgradient  from the  Secondary Barrel  Pit, con-
centrations    of    indicator    parameters    increased
significantly over  the observation  period, with  hydro-
carbon concentrations  (solvents)  following  the down-and-
up  pattern  exhibited  by  wells  SW 7S and  7D.   Fuss  &
O'Neill  concluded that "the results suggest that  we  are
observing a dynamic chemical wave migrating and changing
over  time  and  distance.   Concentrations  in the  central
core  of  the  wave  are   decreasing  due  to   dilution,
dispersion  and   downgradient  migration.     Downgradient
wells are  exhibiting  a concentration which  has  yet  to
pass those ground water observation points."

     The  samples  indicated  that  the ground  water  had
numerous contaminants, the  diversity and  concentration
of which decreased  over time.   For example, Well  SW 7S
in July had a total solvent  concentration of 100-200  ppm
with  at  least  10 distinct chemical species  identified.
In  October,  concentration  was   about   60  ppm  with
distinctly  fewer  chemical species.   But  in  December,
total solvent concentration was in the 85-130  ppm range
with  6   major  species constituting  most  of  the con-
tamination.    Generally speaking,  the  long  term  trend
seems to be decreasing concentration and diversity.

     Consistent  with the chemical  wave hypothesis,  down-
gradient well SW 13 showed a  slight  increase in  total
solvent  concentration   between  July  and  October, with
major chemical species shifting from xylene and  toluene
in the  first samples  to acetone,  isopropanol,  methanol,
and various aromatics  (including xylene  and toluene)  in
the   second.    Then   from  October  to  December,   the
diversity  and  concentration   of  solvent   contaminants
decreased by about  50   percent,  with  acetone and MEK as
the main constituents.   On the whole, at well  SW  13  all
indicator parameters in December were significantly more
concentrated than in  July,  but chemical oxygen  demand,
dissolved solids  and chloride parameters were  more con-
centrated in October than  in December.   Significant  and
increasing  levels  of metallic  ions were  detected  at SW
13,  including  copper,   nickel,  iron,  zinc,  chromium  and

                                     10-20
-------
 cadmium.

     Wells  SW 17S, 17D, 0, P  and  Q were located further
 downgradient   than  well   SW   13  and   their   samples
 fluctuated    unpredictably    over   the   investigation
 period.    Some anomalies  also  occurred.   For  example,
 well  SW 15, which  was  west of  the  Secondary  Barrel Pit
 and  out of the predicted ground water  flow from the pit
 area,  changed from parts  per  billion  levels  in July to
 parts  per million levels of hydrocarbon concentration in
 October   and   December,   plus  had  increases   in   the
 indicated  parameters.    Well  SW  15  also had  increased
 concentrations of copper,  zinc,  nickel, iron and cadmium
 over  the  period  of investigation.   Another anomoly was
 that wells  SW R and 18, thought to be  out  of  the ground
 water  plume,  had very  high  solvent concentrations  and
 high  indicator parameters  such  as dissolved  solids  and
 chemical oxygen demand.

     Fuss & O'Neill offered  several hypotheses  for  the
 aberrant  data:   hydrocarbons   might  migrate   in   ways
 significantly  different from  ground water flow; there
may have been  distict disposal stages,  with hydrocarbons
being deposited first and  hence  migrating at  the leading
edge  of  the   contaminant   plume;  or  the  existence  of
undetected  disposal areas  around  the  Gallup property.
None of  these hypotheses were  tested during  the period
of  investigation,  although Fuss  & O'Neill  noted  some
evidence  that tended  to  weigh against  the  hypotheses
about   unique   hydrocarbon  migration   and   additional
disposal areas at this site.

     Fuss & O'Neill drew  several  conclusions from  the
sample  data regarding  the contaminant plume emanating
from the Secondary Barrel Pit:

    (1)  ground water  contamination had  existed at  the

         pit area for 1.5 years  and had just begun to be

         removed  from the  system by discharge into Mill
         Brook;

    (2)  the  core  of  contamination  had migrated   less

         than  140 feet  (42.7 m)  during that period,  and
         it  would take  at  least  2 more years before  the

         core  began discharging into Mill Brook;

    (3)   contaminant concentrations  at  the core of   the
         plume had  not  abated  significantly over   the
         one-half  year  investigation period;

                                    10-21
-------
    (4)   assuming that  the  decline in  concentration at

         the point of discharge would  occur at the same

         rate as the  observed  concentration increase, a

         minimum of  8 years  of contamination  would be

         predicted;

    (5)   high  levels  of  residual  soil   contamination

         would   add    to    the   time   required    for

         concentrations to decrease, with the extra time

         computed  to  be  as   high  as  one  order  of

         magnitude (4-44 years).

These conclusions were also believed to  apply reasonably
well to the Primary Barrel Pit and the Seepage Bed.

Off-site Water Supply Wells

     Fuss  &  O'Neill  sampled  domestic  supply  wells on
neighboring  properties  and  detected no  hydrocarbon  con-
tamination.   Analysis  for  metallic  ions   revealed  only
low  levels  that  were  believed to reflect the  general
background quality of  the area's ground  water and not be
attributable   to  disposal   activities  at the   Gallup
Site.   A 525  gpm  (1,987  1/m)  public water supply well,
owned  by  the Gallup  Water  Company   and   located about
4,000   feet   (1,219  m)  north  of  the  disposal  areas,
apparently  was not  tested  for contamination.   However,
Fuss &  O'Neill concluded  after an  analysis  of the well  s
location  and specifications  (525  gpm,  1,987 1pm;  756,000
gpd,  2,861,771  Ipd)  that any  interaction  between  con-
taminated ground water at  the disposal  areas  and  the
area of well  influence would be unlikely.

Mill Brook

     Surface water  samples  were  taken  along Mill Brook
and its  tributaries  in September, October and November
1978.    Samples were  taken at  the following  locations
(see Figure 7):

     Sample Point       Location
    	  £51            Mill Brook at  Route 12

          32            Wetland   impoundment   350   feet
                         northwest  of  SW 15
          S3
Mill Brook at railroad bridge
                                      10-22
-------
          S4
Mill Brook above  confluence  with
Fry Brook
          S5
          86
          S7
Fry  Brook  above confluence  with
Mill Brook

Plainfield    Sewage   Treatment
Plant overflow to Fry Brook

Mill Brook below Packer Pond
 Source:  Fuss & O'Neill, January 29, 1979.

      September samples were taken when Mill Brook was at
 1.4 times the  annual  low flow,  i.e., at 75 percent flow
 duration.    Water  quality  in  Mill Brook  was  fairly
 uniform.    The Fry  Brook  sample  had  noticeably  more
 copper, nickel, zinc  and  lead,  which were attributed to
 discharges from the sewage treatment plant upstream from
 the sample point.   All samples from Mill brook and Fry
 Brook  had   trace  levels  of   trichloroethylene   and
 trichloroethane.   The  Mill Brook sample  from  point S3,
 at the railroad  bridge,  contained  a C-7  or  C-8 hydro-
 carbon in  the low  ppm  range;  however,  since  no  such
 chemical  was  found  in  the ground  water  at  the Gallup
 site,   Fuss   & O'Neill  did  not  attribute  it  to  the
 disposal  activities.

     A second series of samples taken later in September
 again   showed  fairly   uniform   content   for  indicator
 parameters  and metallic  ions  in Mill Brook,  but sample
 points S3 and S4 (at Mill Brook above  the  confluence
 with  Fry Brook)  showed increased hydrocarbon  diversity
 and concentrations.  These levels were in the ppb range,
 but Fuss  & O'Neill thought they might reflect  some  con-
 tamination  from  the  Gallup   site.    November  samples,
 taken  when Mill Brook  was approaching annual  low  flow,
 further supported  this  hypothesis  because  hydrocarbon
 content     at      S4      increased      dramatically.
 Trichloroethylene,      methylene,      chloride      and
 trichloroethane   levels   were  detected   at  20-70   ppb.
 Moreover,  these  constituents  were  also  present in  the
 ground  water   downgradient  from   the   disposal areas.
 Since   the  ground water  samples  had  levels  of  these
 chemicals  that weren't  concentrated  enough  to  account
 for the surface water  levels, Fuss  & O'Neill  postulated
 that higher concentrations might have passed  the monitor
well areas  prior  to ground water  sampling, or  that  the
beaver  impoundment might have modified ground water  flow
 in ways that increased these concentrations.

     To supplement  its  surface  water sampling  program,
Fuss &  O'Neill  attempted  to estimate the total  impact  of
                                    300.68(e)(2)
                                    (ii) extent
                                    of substance
                                    migration
                                     10-23
-------
contaminated ground  water on Mill  Brook.   It  predicted
that  outflow from  the  three major  disposal  sites  into
Mill brook  was  10,300 gallons/day  (38,989.7  1/d).   The
flow of Mill Brook  was estimated  to be 867,000  gallons/-
day (3,281,932 l/d>  at the  90 percent  flow duration.   To
compute  the contaminant  impact,  the engineers took  the
concentrations observed  in  the  October 1978 samples  from
individual  wells  and weighted  them based on  estimated
transmissivity at each well  over  total transmissivity at
all wells.   They  then converted  the results  into pounds
per day  loading  and a maximum  concentration  increase at
the stream  (see Table 2).

     Fuss & O'Neill concluded  that  copper and iron  had
the  greatest potential  for  concentration, followed  by
methanol,  nickel  and  zinc.   Copper  was   considered  to
pose  the  greatest  ecological  threat  to  the  stream.
Eventually,   such   toxic   and   possibly  carcinogenic
substances  as  trichloroethylene,   toluene,  xylene  and
chloroform  are  expected to  enter   the  stream from  the
site.

     The  engineering  firm  pointed out   in  its  final
report  that metallic ions seemed to be migrating toward
Mill  Brook  at  slower  rates than  the hydrocarbon  con-
stituents  or indicator  parameters  such as the chloride
ion.    If   so,  this might  lower the  concentrations  of
metallic  ions  predicted  in Table  2,  but  it also would
lengthen the critical period of impact to  Mill  Brook.

PLANNING THE SITE RESPONSE

Initiation  of Response

      The    Connecticut    Department   of   Environmental
Protection   (DEP)  learned  of  the   site's existence  in
January  1978,    seized   it   in   February,   and  began
investigating  the  nature  and  extent  of   contamination.
The  DEP  hired   Fuss  & O'Neill  to   conduct  a  hydro-
geological  assessment of the  site, which it  performed
from June  to December  1978.  Fuss  &  O'Neill found that
the ground  water was contaminated by  a  wide  range of
metallic ions and  hydrocarbon  solvents and  that it was
moving  north and northwesterly from the Gallup property
toward  ultimate  discharge  into  Mill Brook,  which was
then a "Class A" recreational  stream but  not a  drinking
water  source.    The  DEP  concluded  that an  immediate
 response  action  was  necessary  because,  although  Mill
Brook appeared fairly uncontaminated  and  nearby  private
 drinking water  wells  were not  contaminated,  the  con-
 tinued loading  of   contaminants  from  the  disposal  areas
 into this ground water system eventually could result in
300.68(e)(2)
(iv)
environment al
effects and
welfare
concerns
300.68(f)
remedial
investigation
                                      10-24
-------
TABLE 2. ESTIMATED IMPACT ON MILL BROOK
Parameters
Methanol
Acetone
Higher Acetates
Chlorinated Propane
Isopropanol
MEK
MIBK
Propyl Acetate
Toluene
Xylene
Aroma tics
Ethylene
Copper
Nickel
Iron
Zinc
Titanium
Chromium
Silver
Cadmium
Pounds/Day
0.291
0.1
0.117
O.01
0.162
0.069
0.217
0.155
0.004
0.003
O.031
0.013
1.877
0.231
1 .49
O.336
0.006
0.008
	
0.011
MUligrams/L-iter
.04
.01
.016
.001
.022
.009
.029
.021
ppb
ppb
.004
.001
.26
.031
.203
.046
ppb
.001
ppb
.001
                    10-25
-------
 a significant plume of pollutants  threatening  the  stream
 and possibly the wells.

 Selection of Response Technologies

      DEP officials  stated that  the choice  of clean-up
 measures was  based on  the nature  of  the contamination
 and  the hydrogeology  at  the site,  not  on  cost con-
 siderations.    DEP  chose  to  remove contaminated  soil,
 drums and free liquids from the site in order  to prevent
 further  ground  water   contamination.     Pumping  and
 treatment of the ground  water was  rejected  because DEP
 believed that  the   hydrogeological system  would   dilute
 the plume  of contaminated ground  water  to  levels con-
 sidered acceptable  for discharge  into Mill Brook.

 Extent  of Response

      The DEP's  clean-up  goal  was  to eliminate the  source
 of   contamination  by  removing  all  contaminated  soil,
 drums and  free  liquids  from  the  disposal areas.   This
 goal was apparently accomplished at two  of the disposal
 areas,  the  Primary  and Secondary Barrel  Pits,  where ex-
 cavation was  done  down  to  soil  containing  only  a
 residual amount  of  contamination.     Composite   soil
 analyses were performed  and soil  was divided into highly
 contaminated,  lightly contaminated, and  residually con-
 taminated  classes.    The  goal did  not  appear  to be  met
 with respect to the Seepage  Bed,  however.  During  ex-
 cavation at this area, which  tests had shown to contain
 solvents, both  the  equipment  operator  and an  observing
 geologist encountered  irritating vapors.   The excavation
 pit   as   left  open  for   some time until  the vapors
 subsided.   When excavation resumed, it  became clear that
 there  was  extensive  soil  contamination  that  would  re-
 quire removing  a very large volume, which was considered
 economically  prohibitive.   Since  the   soil  was highly
 acidic,   the   state's  computations  indicated that   a
 neutralizing  dose  of  lime would  bring the  pH into  an
 acceptable  range.    State officials decided  to apply  a
massive  dose  of  lime (approximately 30  tons,  27.2 Mt)  to
 neutralize  the  contaminants in situ, then cover the  pit
with  local  soil.   Thus,  economic  considerations  seemed
 to  play a  critical role  in   determining  the  extent  of
 response at  the Seepage  Bed,  but not at  the  Primary  and
 Secondary Barrel Pits.

     Officials  from DEP  stated  that settlement of  the
 department's  law  suit against  Gallup,  whereby Gallup
 agreed to pay for clean-up costs up to  $750,000, did not
 affect  the  extent  to  which the  state  sought  to  remedy
 the  problem.    The  $750,000  figure  represented  DEP's
 estimate  of the total clean-up cost for  the site.   The
 300.68(e)(2)
 source  control
 remedial
 action
300.68(h)
initiaJ.
screening of
alternatives
300.680)
cost
effectiveness
                                     10-26
-------
 officials   acknowledged   some   contraints   from   this
 settlement  figure:  since  state  funds would  have to be
 used  for  all costs  above $750,000,  the  state tried to
 monitor  clean-up  costs   closely   to insure   that   the
 operation  came  in under  this amount  which,  in  effect,
 was a  self-imposed budget.  DEP officals stated  that if
 unforeseen problems  had arisen, the  state  was prepared
 to pay any  necessary  additional costs.    Regarding  the
 clean-up of  the  Seepage Bed,  it appears  that the extent
 of response was determined by a  decision that excavation
 of contaminated soil  was unnecessary or too  costly.

 DESIGN AND EXECUTION  OF SITE RESPONSE
      Upon learning of  the  probable  nature  and extent of
 contamination,  DEP  decided  to   remove the  contaminated
 soil,   drums  and  free  liquids  from  the  three  main
 disposal areas.   Chem-Trol,  Inc.,   a  subsidiary of  SCA,
 Inc.,   was  the  clean-up  contractor  and  performed  the
 excavation,  transportation  and  disposal  work.    The
 techniques  used varied  according to the  characteristics
 of each disposal  area.

 Seepage Bed

     This  area  had significant amounts of metallic  ions
 and hyrocarbon solvents.    First Chem-Trol  removed  the
 soil  surrounding  the  inverted dump  truck bed.   The  soil
 had very little contamination.   Then  the  dump truck bed
 was removed.    When the  field  crew attempted  to  remove
 the highly  contaminated  trap  rock  below the  truck  bed,
 the  equipment   operator   and  an   observing  geologist
 encountered irritating  vapors that  forced them  to cease
 work  and leave the pit open until  the vapors  subsided.
 Removal of  rock  and  soil  resumed,  but it became clear
 that   contamination  was   extensive   and  would  entail
 removal of  a  large soil volume.   State officials decided
 that removal  was  too  expensive,  and  sought  to neutralize
 the contaminants  in situ with about  30 tons  (27.2  Mt)  of
 lime.   The pit was then  filled  and covered with fresh
 local  soil.   No  subsequent field testing was  performed
 to  determine  the  effect of  this treatment,  other  than
 continued sampling of the surrounding monitoring wells.

Primary Barrel Pit and Chemical Lagoon

     Response  action   in   this   area   had  two  phases.
First,   the   free    liquids  ia the  lagoon,   which were
primarily solvents, were pumped  out.  Mud at  the  bottom
of  the  lagoon was removed with excavation equipment  and
stockpiled on-site in depression  zones to minimize run-
off.    It   subsequently  was  mixed  with  drier  heavily
contaminated  soil  to  lower the average moisture content
and facilitate handling  and disposal.   The second phase
300.70(b)(2)
in situ
treatment ;
neutralization
300.70(c)(2)
contaminated
soil removal
                                     10-27
-------
involved removing drums  and contaminated soil.  A  clear
area adjacent  to the  disposal  site was  excavated to  a
depth  of between  15  and  18  feet  (4.6  - 5.5  m)  and
constructed  with an  access ramp.   From there  lateral
excavation  of  the  contaminated  materials  took place.
The  technique employed  for exposing  the  drums  was  to
slightly  undercut   the   lower   soils,   allowing   the
overlying layered soil to  slough  by gravity and expose
the  drums.    As  the  drums  were  exposed   they  were
selectively  and  carefully  removed without damage  using
barrel hooks.   Drums  and contaminated soil were  removed
down to recognizably clean  soil.

Secondary Barrel Pit and Liquid Burial Area

     Excavation  of this  area was similar  to the  Primary     300.70(c)(2)
Barrel Pit.   An area  next  to  the  pit  was cleared  and     contaminated
excavated to a depth of  12-15  feet  (3.6 - 4.6 m), then     SDl1 removal
work proceeded  laterally into the burial area.  Layers
of  drums and  contaminated  soil were  removed  using  the
techniques employed in the  Primary Barrel Pit.   Excava-
tion continued down to recognizably clean soil.

On-Site Storage  of Contaminated Materials

     Heavily   and  lightly  contaminated   soils  were
separated  upon  excavation  and  placed   into   different
piles  located in  depression areas  on-site.   This  was
done to  minimize surface run-off.   Separation of  soils
was  done by visual examination  and  smell: heavily con-
taminated  soil  was  noticeably  colored  and had a very
strong  odor, while  lightly contaminated  soil was less
stained  and  had  less odor.   Free liquids pumped from  the
Primary Barrel Pit were  placed  in a  recently constructed
100  x  40 foot  (30.5  x  12.2  m)  bermed  containment area
having a hypalon liner.

     Drums  were also  stored  on-site prior  to  transport
to  a disposal landfill.   The contents of each drum were
analyzed, using  a mobile laboratory equipped  with  a  gas
chromatograph  and recorder,  flash point tester, pH  and
conductivity  meters,    and  various  other   laboratory
supplies  and  sampling   equipment.    An  inventory  and
description  of the composites  of the drum  contents  was
made and  included the  following  classes:

     «    Aqueous Subclass of Acids
         Number  of drums, pH range,  percent free acid as
          sulfuric  acid,   percent equivalent acid,  total
          inorganic carbon,  and  total organic carbon.

     •    Aqueous Subclass of Alkaline  Wastes
          Number  of   drums,  pH  range,   percent   free

                                     10-28
-------
         alkalinity   as   sodium   hydroxide,   percent
         equivalent  alkalinity   as   sodium  hydroxide,
         percent equivalent  alkalinity,  total inorganic
         carbon, and total organic carbon.

         Aqueous Class of High Total  Organic Carbon
         Number  of  drums,   pH  range,   total  inorganic
         carbon and total organic carbon.
         Solvent Class of Nonchlorinated Solvents
         Number  of  drums,  BTU1s per  pound,  BTU' s
         gallon, and percent chlorine.
per
    •    Chlorinated Solvents
         Analyzed  only   for  specific  gravity.    The
         limited testing on  the chlorinated  solvents was
         based  on  the   fact that  attempts  to  make  a
         composite    sample    for    analysis    caused
         polymerization and precluded further analysis.

Classification of Substances for Disposal

     The  contaminated  materials   stored  on-site  were
classified  into  4 groups for  disposal:   (1) an aqueous
class  subcategorized  into  acids,  bases  and high  total
organic carbons;  (2) a  solvent  class  subcategorized into
chlorinated   and   nonchlorinated    solvents;    (3)   a
contaminated  soils  class   subcategorized   into highly
contaminated  and slightly  contaminated  soils;  and  (4)
flammable sludges.

Transportation and Disposal

     Chem-Trol  handled   the  transportation  and  disposal
work.     Drums   and  heavily  contaminated  soil  were
transported  in  20 ton (18 Mt)  sealed  dump trucks to  the
licensed SCA facility in Model  City,  N.Y.,  a distance  of
580  miles  (928  km).   Free  liquids were transported  to
the Model City  facility in  one  tanker that  had  a 4,000 -
5,000  gallon (15,141.6  - 18,927  1)  capacity.    Lightly
contaminated soil was  taken in  20  ton  (18 Mt)  sealed
dump  trucks  a  distance  of 1.5  miles (2.4  km) to  the
Yaworski, Landfill in Canterbury,  Conn.

COST AND FUNDING

Source  of Funding

     All costs  of response  at  the  site were paid by  the
state  which,  in turn,  was  reimbursed  in  full by  Mr.
Gallup.     Following  its   discovery  of   the   disposal
activities  in. January  1979  and seizure of  the property
in  February, DEP  filed a  civil  suit against  Gallup  on

                                     10-29
        300.70(c)
        off-site
        transport
        for  secure
        disposition
-------
 May 17,  1978, charging him with violation of Connecticut     300.68(c)
 law prohibiting the discharge of substances or materials     judicial
 into state waters without a permit.  While this suit was     process
 pending,  Gallup asked DEP to estimate the total costs of
 cleaning  up the site  so  that  he could attempt to settle
 the suit.  During  July,  DEP worked with  Fuss  & O'Neill
 to  determine  the extent  of  the  problem and the required
 response   actions,  and  concluded  it   would  cost  about
 $750,000.   On  September 13,  1978, Gallup pleaded  nolo
 contendre to  the charges  against him,  was assessed  a
 $25,000  fine  by the  court,  and agreed  to reimburse the
 state  $15,000 for the costs of  immediate protection and
 control  of the  site,  plus up  to  $750,000 for response
 costs, payable  in $100,000 installments.

 Selection of  Contractors

     DEP  hired  Fuss  & O'Neill Consulting Engineers,  of
 Manchester,   Conn.,    to   perform  the   hydrogeological
 assessment  of the site.   Fuss & O'Neill was  selected  by
 direct procurement  based on past experience,  and  a  lump
 sum contract  with a  ceiling  of  $90,000 was used.   Work
 was completed  on  time,  although  a  no-cost  3  month
 extension  was  required   for  the  firm  to complete  its
 final   report,   and   for  almost   $30,000  below   the
 ceiling.   DEP hired Chem-Trol Pollution Services, Inc.,
 a  subsidiary  of  SCA  Chemical Services,  Inc.,  of Model
 City,  N.Y.,  to  perform  all  excavation,  transportation
 and disposal  work.  Chem-Trol  was hired under  a time and
materials  contract with a  $640,000  ceiling  and  with
payment  to be  made  monthly  on  the  basis  of  itemized
vouchers.   The firm  was  selected based on  past  ex-
perience.   Chem-Trol   subcontracted the disposal of the
 lightly   contaminated  soil   to   Yaworski,   Inc.,    of
Cantebury,  Conn,  because of its  proximity to  the site;
 the  remaining  materials were   disposed   of   at  SCA1 s
 licensed facility in Model City.

Project Costs

     Response costs totalled $610,445.35,  well  under the
 settlement  figure of  $750,000,   and  are  summarized  in
Table  3.   Approximately  7,020 tons (6,368  Mt) of  soil
and  drums  were excavated,  transported and disposed of,
consisting of 4,020 tons  (3,647  Mt) of drums and heavily
contaminated  soil and 3,000 tons  (2,721  Mt)  of lightly
contaminated  soil.    This  amounted to 201  dump truck
 loads  of   drums  and heavily  contaminated  soil and 150
loads of lightly contaminated  soil, with an average  load
of  20  tons (18  Mt).   The quantity  of  material  excavated
was assumed to be the  sum of the quantitites of soil and
drums transported and disposed of.  Approximately 5,114
                                     10-30
-------
                   TABLE  3.   SUMMARY OF COST INFORMATION-GALLUP SITE, PLAINFIELD,  CONN.
o
i
LO
Task
Excavation
Transportation
A. drums & heavily contaminated
soil
B. lightly contaminated soil
C. bulk liquids
Subtotal- transportation
iDi-sposal
A. drums & heavily contaminated
soil
B. lightly contaiminated soil
C. bulk liquids
Subtotj'l-disgosal
Engineering & hydrogeologic studies
State Health Lab-analysis fees
Equipment & Consumables
TOTAL
-^Hiyyi&y-E-^lL-
7,020 tons
(6.368 Ht )
201 loads
(4,020 tons;
3,647 Mt )
150 loads
(3,000 tons;
2,721 Mt )
1 load
5,114 gal.
(19,359 1)

201 loads
(4,020 tons;
3,647 Mt >
150 loads
(3,047.4 tons;
2,764.5 Mt )
1 load
5,114 gal
(19,359 1)





Expenditure
i fc *± = K=t= =; = = = E i==±±
$89,285.47
$269,742.00
$2,534.60(c)
$1,342.00
$273,61B.60
$160,800.00
$21,331. 80(c)
$1,789.90
«Sifi3AS2i. 2Q_
$60,324.78
$1,009.46
$2,285.33
$610,445.34
__Unit_Q£St
$12.72/ton
($U.02/Mt )
$l,342/load(b)
($67.10/ton;
(73.96/Mt )
$16.90/load(b)
($0.84/ton;
$0.93/Mt )
$l,342.00/load(b)

$800/load(b)
($40/ton;
44.t)q/Mt ^
$142.21/load (b)
($7 ton; $7.72/Mt)
$l,789/load (b)





_Fund ing^ _Sou r ce
Gallup
Gallup
Gallup
Gallup

Gallup
Gallup
Gallup

Gallup
Gallup
Gallup
Gallup
Period of
Performance
11/78-12/78
11/78-12/78
11/78-12/78
11/78-12/78

11/78-12/78
11/78-12/78
11/78-12/78

6/78-10/78


6/78-12/78
              (a)  1 load of soil - 20 tons, 18.14 Mt .

                  1 load of bulk liquids= 4-5,000 eal

                  (15,142-18,927 1)
(b) from contract between Chem-Trol  (SCA) and DEP


(c) based on invoices
-------
gallons   (19,359   1)   of   free   (bulk)   liquids  were
transported  in  one tanker  with a 4,000  - 5,000 gallon
(15,141.6 - 18,927 1) capacity.

     Fuss & O'Neill was paid a sum of $60,324.78  for  the
hydrogeological  study.    The  State  Health  Lab  charged
$1,009.46 for some chemical analyses performed on water
samples.    Equipment  and   consumables  relating  to   the
response action were also charged as costs.

PERFORMANCE EVALUATION
     DEP's  decision to  remove  the source of  contamina-
tion  but not  to  pump  and treat  the  ground  water  was
based on  the available  data regarding  probable dilution
of  the  plume of  contaminated  ground water and the  fact
that no  sources  of drinking water were threatened.   The
data  upon which  DEP  made   its  decision seem  sound,  but
the decision is  open to criticism on the ground  that it
reflects  only  short  term  health concerns  and  doesn't
sufficiently  consider  longer  term  public health   and
environmental concerns.   The Fuss  &  O'Neill  study showed
clearly  that  numerous   species  of  metallic   ions   and
hydrocarbon  solvents would continue to  discharge  into
Mill  Brook  for at least 8 and possibly as  long as  44
years.   Although  these contaminants  can  be expected to
be  diluted  by the ground water system  and by  the waters
of  Mill Brook  itself,  the extent of  dilution  and  the
total   amount   of  contaminant  discharge  are unknown.
Given  the hazardous substances present  at the  site,  this
decision  could   commmit  the  stream  to  a  substantial
degree  of  pollution.   The planning process  lacked  the
necessary consideration of  contaminant  sources,  fate and
transport,   sensitive  receptors   or a  clear planning
horizon to mitigate  this  pollution cost effectively or
to  understand it.

      Justification of the   state's goal of  only removing
the source  of  contamination  is  undermined by the  fact
that  one  of the  three  sources  of contamination,  the
Seepage Bed,  was  not  excavated  to recognizably  clean
soil.   Further,  no test of the effectiveness of the in
situ  lime treatment was made,  other than continuing the
normal  sampling   program.    While  the   lime  might
neutralize   some  of  the  acids  in the soil,  it is  not
likely to immobilize other contaminants such  as volatile
organic compounds  (VOCs)   and  metallic ions.   Metallic
ions    may   be   substantially   immobilized,   but   not
completely and not permanently, which  is important since
 they  may be elemental and  hence will not biodegrade  into
begin metabolitis.   The effectiveness of  lime or VOC s
 is evnr  less substantial,  but many VOCs will eventually
biodegrade,  even  in  a capped   anaerobic  environment.
Although the large amount  of contamination at this  area

                                      10-32
-------
might  have  been very  expensive  in  the  short  run  to
remove,  the  extent  of contamination would seem to  argue
strongly for  a  response that more effectively  mitigates
and minimizes the  long  term threat to public health  and
welfare and the environment.
                                    10-33
-------
                             BIBLIOGRAPHY
Bowe, Steve. SCA Chemical Waste Services, Inc.   June 18,  1982,
     January 24, 1983.  Personal communications with Environmental
     Law Institute.

Burton, Donald, Jr., Chief Field Inspector, Oil and Chemical Spill
     Section, Connecticut Department of  Environmental Protection.   June -
     July   1982   and  May  24,   1983.     Personal  communications   with
     Environmental Law Institute.

Connecticut Department of Environmental Protection. Undated.
     "Clean-up Cost:  Plainfield Dump Site (Gallup Property)."

Connecticut v. C. Stanton Gallup, No. 7750, Superior Court,  Windham
     County, May 12, 1978.

Fuss & O'Neill, January 29, 1979.  "Evaluation of a Chemical Waste
     Disposal Area, Tarbox Road Site, Plainfield, Connecticut".

Jacobson, Milton L. Brown, Jacobson, Jewett and Laudone,  P.C.
     September 13, 1978. Letter to Allan M. Kosloff, Assistant
     Attorney General, Connecticut Department of Environmental  Protection.

Kulinowski Kenneth, SCA Chemical Waste Services, Inc. January 24, 1983.
     Personal communication with Environmental Law Institute.

Marple, David V. Chem-Trol Pollution Services,  Inc.  Undated.  Letter
     to  Robert   B.   Taylor,   Connecticut   Department   of   Environmental
     Protection.

SCA Chemical Waste Services, Inc. Invoices to Connecticut Department
     of Environmental Protection, June 23 - August 30,  1978.

Taylor,Robert B. Director of Water Compliance and Hazardous Substances,
     Connecticut  Department of Environmental  Protection.    June 7, 1978.
     Letter to David Marple, Chem-Trol Pollution Services,  Inc.

Yaworski, Inc. Invoice, August 11, 1978.
                                 10-34
-------
                                   GOOSE  FARM

                                PLUMSTED, N.J.
 INTRODUCTION

      The   Goose  Farm   abandoned  hazardous waste  dump  is
      located   in a  rural  area   in   Plumsted  Township,
 Ocean County,  New Jersey (see Figure 1).  Originally, the
 site  was  a  pit  in which  drums and  bulk liquid  chemical
 wastes,   includ ing  solvents,   chlorinated  solvents,  and
 polychiorinated  biphenyls (PCB's), were dumped.   At the
 time  the  site was  discovered, ground water  near  the pit
 was contaminated and  seepage containing organic chemicals
 was discharging  into a  stream  on the  site that drains  into
 the Delaware River.

 Background

      From 1945  to  1969, a manufacturer  of  rocket  propel-
 lants,  ammunition,  and  specialty chemicals dumped  and
 buried  various hazardous wastes in a pit 300 feet by 100
 feet  by 15 feet deep  (91 by  30 by 4.6 m) on  a piece of
 property  called  Goose Farm,  under  contract  with the owner
 of the  land.   Wastes  disposed on the  site included solids
 and liquids in bulk, 55-gallon  (208 liter) drums, 5-gallon
 (19 1) pails, and lab packs.  The site is located approxi-
 mately  20 miles  (32 km) southeast  of Trenton,  N.J.,  in a
 2-acre (0.8 ha)  clearing surrounded by woods, farms, cran-
 berry bogs, and  scattered homes.  The closest residence is
 about 400 feet  (122 m)  from  the site,  and  about 30 other
 homes are  within one-quarter to one-half mile (0.4-0.8 km)
 of the site.  Site  location is  shown in Figure 1.

     In the course of a New Jersey Department of  Environ-
mental  Protection (DEP) investigation  of possible pesti-
 cide  contamination  of  local  drinking  water wells  in Jan-
 uary 1980, the Plumsted Township Sheriff's office informed
DEP of  the existence of  the  Goose Farm  site  and  several
other  sites  in  the area.   Over the  next  6 months,  DEP
 resistivity studies and  ground  water  monitoring indicated
 that  a  plume  of contaminated ground  water extended  from
 the pit.   In  addition,  tests  of  a small  stream  running
past  the  site  indicated surface  water contamination.
NCP Reference
300.68 (f)
investigation
                                     11-1
-------
Figure 1.  Index Map for Location of the Goose Farm Site
-------
 Metal detectors  indicated a  large quantity of buried metal
 on the property.

 Synopsis of Site Response

      In  July  1980,  DEP decided  that  the  site  posed an
 immediate threat to human health and  in August 1980, hired
 O.K. Materials, Inc. (OHM) to conduct preliminary environ-
 mental testing  to  determine the  extent of contamination.
 In September 1980,  OHM  began an emergency clean-up of the
 site using  money from  the  New Jersey  Spill Fund.   From
 September 1980 to March 1981, OHM installed and operated a
 ground water recovery and  treatment  system to contain the
 plume,  prevent contaminants  from entering the stream, and
 flush contaminants  from the  soil.   in addition,  OHM exca-
 vated contaminated  soil and over 4,800  drums  and  pails
 from the pit  during  the  autumn  of  1980.    Over  9,000
 gallons  (34,000  1)  of  liquid were bulked and transported
 off-site  for disposal,  although soil,  drummed  solids and
 treatment system wastes  remained.    In  March  1981,  the
 ground  water recovery system was dismantled  and  all  oper-
 ations  at the site  except  security ceased.   From October
 1980  through  March  1981  the clean-up  was  funded  almost
 entirely  by  the  Revolving  Fund  under  section  311(k)  of the
 Clean Water Act, and  by the Superfund  Emergency  Response
 Fund.  The  remaining necessary  funds  were provided by the
 state.

      There was a  seven-month  period between March 1981 and
 autumn  1981,  when  clean-up  operations  came to  a  halt.
 This  interlude  occurred due  to  a  lack of  available  State
 and Federal  funds.

      In autumn of 1981,  additional  funds were provided and
 operations  resumed   when  DEP hired  OHM and  CECOS Inter-
 national  to  bulk and  transport the  remaining wastes  and
 heavily  contaminated soil  to a CECOS landfill  in Niagra
 Falls,  N.Y.   The site was  graded and  additional ground
 water monitoring wells were installed.   In September  1982,
 the U.S.  Environmental  Protection  Agency  (EPA) authorized
 Superfund  funding for  an  investigation to determine  the
 extent of contamination remaining at the site.

 SITE  DESCRIPTION

jSurface Characteristics

      The Goose Farm  site is located in a unique ecological
 area  known as the Pinelands.  The  New Jersey Pinelands is
characterized by acidic  sandy soils and  low lying forests
predominantly of pine with a  lesser population of oak.
                                     11-3
-------
     The  local  climate is continental,  experiencing sig-
nificant  seasonal,  daily,  and   day-to-day  temperature
fluctuations.   The  average  winter temperature  is 33* F
(0.6°  C) with  the  average  daily  minimum temperature
reaching  24°  F  (-4.4° C).   The  lowest  recorded  winter
temperature  in  this  area  was  -14* F (-26*  F)  recorded in
Toms River  in February, 1961.   Average summer temperature
is 72*  F (22°  C)  with an  average  daily maximum  of 83° F
(28° C).   The  highest temperature recorded  in  the county
was 103° F (40* C) on July 4,  1966.

     Precipitation averages between 42 to 46 inches (107 -
117 cm)  per  year  with  a   range  of 25  to  67 inches (64 -
170 cm) per year.   The period of highest rainfall has been
found to be  between  July  and  August  while January, Febru-
ary, and October tend to be the driest months.  Precipita-
tion is distributed relatively evenly throughout  the year;
however, droughts  and  heavy rains have  occurred (highest
1-day rainfall  was 4.9 inches - 12.4  cm).   Thunderstorms
occur about 25 days per year predominantly in summer.   The
average  seasonal  snowfall is 17  inches  (43 cm)  with  the
highest  recorded snow depth for any 1 time being  13 inches
(33 cm).

     Relative humidity averages about 56  percent in mid-
afternoon with  higher  values at  night,  averaging 81 per-
cent at  dawn.  The percentage of average daily sunshine is
45 in winter and 60  in summer.

     Winds  are  predominately  southerly from April  through
October,  changing  to northwest  during winter months.   The
highest  average windspeed  is  12 miles  (19 km) per hour in
March.

     The  site  is  located  in a gently sloping well-drained
area adjacent to  a small  stream to the north.   Slopes  are
typically  from  0  to 5 percent.   The surrounding soil  has
been classified as the Kvesboro sand, a  sandy soil  of high
permeability,  low water capacity,  and  low organic  content
and  fertility.   Unless limed,  the  soil  is  acidic.  Eves-
boro sand possesses  severe wind erosion  characteristics.

     Goose  Farm is located in a relatively  sparsely popu-
lated  area  about  2 miles  (3.8 km) northeast of  New Egypt,
a  small  town  with  a  population of  1,769.  The site is
about  1 mile  (1.6  km)  southeast of  the  lesser town of
Hornerstown.  There  are a  number of  residences  in the  area
with private wells.

     The site   is  located   about  400  to  600   feet (122  -
152 m)   south   of  a  small stream flowing northward.   The
stream   is   a   tributary   of  Lahaway  Creek, which  drains

                                      11-4
300.68(e)(2)
(i)(E) climate
 300.68(e)(2)
 (i)(A)  popula-
 titon at risk
-------
into the  Delaware River.  Latiaway  Creek  is designated by
the State  of  New Jersey as "FW-1 Non-trout;  suitable for
potable water supply".   A number  of cranberry  bogs are
located from 1/2 mile  (0.8 km)  to 1 mile  (1.6 km) east to
southeast of the site.

Hydrogeology

     The Goose Farm site is situated  in the Coastal Plain    300.68(e)(2)
(consisting of tertiary  and  cretaceous sedimentary forma-   (i)(D) hydrogeo-
tions of  sands,  clay   silts,  shell beds, and glauconite.   logical  factors

Strata which are exposed within a mile" of the site include
the Red Bank, Hornerstown, Vincetown, Kirkwood, and Cohan-
sey formations.   Figure 2 is a geologic  map of the Goose
Farm area.  Although the regional survey shows the site is
located  within  the  outcrop  of the  Vincetown formation,
local test well  drilling has  indicated  that a thin veneer
of  the  Kirkwood  formation  underlies the site.   Figure  3
shows a geologic  cross section  of the regional formations
relative  to  the  Goose Farm site.   A brief description of
each formation is presented below:

Cohansey Formation (Teh)—
The  Cohansey  is  a  light  gray  to  yellow-brown  to   red,
medium  to  coarse quartz  sand  with visible  amounts of
ilmenite present.  It may contain clay lenses varying  from
an  inch to more  than  2 feet (0.6 m).  The  Cohansey is the
single  most   important  aquifer  in  the  State  and  is the
water table aquifer for much of South Jersey.  However, as
can be  seen  from Figures 2  and 3,   the  recharge  zone for
the Cohansey  is well outside the perimeter  of the site and
outcrops at a higher elevation than  the Goose Farm area.

Kirkwood Formation (Tkw)—
The Kirkwood   is  the   uppermost  formation  underlying the
Goose Farm  site, and  ranges  from 0 to  15  feet (0-4.6 m)
thick in this area.  It  consists of  two distinct  units, an
upper unit  of fine  to very fine slightly  clayey quartzy
sand and  a lower unit  of dark brown  fine  to  very  fine,
peaty  or   lignitic  quartz  sand  and  silt.    The  Kirkwood
serves as a recharge  zone  in  the  Goose  Farm area for  both
the Kirkwood and the lower Vincetown Aquifer.

Manasquan Formation (Kmg)—
The Manasquan  is an  aquitard  composed of  two substrata.
The upper  member is  a  greenish gray to  tan clayey silt.
The lower  unit  is  a  dark greenish  gray  clayey quartz-
glauconite sand.  The  Manasquan  ranges  from a depth 15 to
23  feet (4.6-7.0 m) thick  with  the  upper regions pinching
out into Kirkwood.
                                     11-5
-------
Figure 2.  Geologic Map of the Goose Farm Site Area
            (O.H.  Material  Co., 1981)
                                11-6
-------
                          Goose
                        Farm Sice
                                                                      r20O
                                                                      1T200
                                                          SCALE

                                                    Vertical 1"- 1001

                                                    Horizontal 1"- 20001
Figure  3.   Subsurface Cross Section of the  Goose Farm Area
                                  11-7
-------
Vincetown Formation (Tvt)—
The Vincetown  is  an aquifer  composed  of two units.   The
upper  member  ranges   from  a   greenish  gray  clayey,
micaceous, glauconitic,  calcareous  fine-to-medium grained
sand to  a  sandy,  clayey coquina.  The  clays  are  calcitic
originating from  decomposed  shell fragments.   Occasional
indurated  sandstone  or  limestone  beds  occur.    The
Vincetown is 30 to  50  feet  (9.1-15  m)  thick beneath Goose
Farm  and is  the  drinking water source  for  6  of  the 96
local wells.

Hornerstown, Red  Bank  and Navesink  Formations  (Kht;  Krb;
Kns) —
The Hornerstown,  Red  Bank,   and  Navesink  formations  are
aquicludes  separating  the Vincetown from  the  underlying
Mt. Laurel-Wenonah aquifer.   The  uppermost  of  these
aquicludes  is  the  Hornerstown,  composed  of 99  percent
glauconite clayey sand with a thickness ranging from 30 to
35  feet  (9.1-11  m).    The  Red  Bank  consists  of  a  dark
clayey,  very micaceous  glauconite sand in  the  Goose Farm
area at  a  minimum thickness of  10  feet  (3.0  m).   Most of
the Navesink  consists  of a massive  dark  green  to grayish
black,  medium  to  coarse  grained   glauconite  sand  with
varying  amounts of sand  and clay at a thickness of 35  feet
(11 m).   Shell  layers  are  present  in the  lower regions
with a massive  shell bed separating the Navesink from the
Mt. Laurel-Wenonah formation.

Mt. Laurel-Wenonah Formation  (Kmw) —
This  formation is  a  major  aquifer ,in Ocean County with
about  1  million  gallons (3.8 X 10   1)  of  water  pumped
daily.   It is  used by  other counties as well.   The Mt.
Laurel-Wenonah  is the  source  aquifer for  76 percent or 73
of  the  96  local wells.   The Mt.  Laurel begins  with  a
massive  shell  bed  in  the  upper layer  but  is  primarily
composed  of a  glauconitic  clayey to  fine  to very coarse
pebbly sand.   The  lower Wenonah formation consists  of  a
silt to medium grained yellow uniform micaceous sand.  The
Mt.  Laurel-Wenonah is  about  90 feet  (27  m)  thick and
occurs at  a depth  of  about  150 feet  (46  m)  in the Goose
Farm area.

     The  uppermost  water  table (Kirkwood)  follows  the
general  topography, i.e. ground water  flow direction  is 5°
to  10° east of  north toward  the  stream.  The rate of  flow
had been calculated to be about  0.5 feet (0.15 m) per day
horizontally  and  about  0.6  feet (0.2  m)  per  day verti-
cally.   Estimated permeabil_i±y of the underlying Manasquan
formation  is  about 2  X 10~  feet  (6  X 10   m)  per  day,
which  suggests it  is  a leaky  aquitard.   A second  flow
regime exists  in  the underlying Vincetown  formation,  which
dips  to  the Southeast.   Gross  permeability of the Vince-

                                     11-8
-------
 town foundation has been measured  by pumping tests to be 1
 to 3 feet (0.3-0.9 m)  per  day.   The two  nearest  drinking
 water wells  tapping the Vincetown  aquifer  are located more
 than one mile (1.6 km)  south  of  the site.   Most  wells  on
 the area  are  located  in  the  isolated Mt.  Laure 1-Wenonah
 foundations.
 WASTE  DISPOSAL  HISTORY

     The  Goose  Farm site   was   used   as  a   hazardous  waste
 disposal   site  between 1945  and   1965   by   a  manufacturer
 of  solid  rocket   propeHants,   ammunition, miscellaneous
 plastics,    synthetic    rubber  and   organic   fibers.   The
 wastes were dumped at  the Goose  Farm site under  contract
 with the  then  owner  of the property.   Data  suggest  that
 dumping  may  have   continued  until  sometime   in  the   mid-
 1970's.

     The  dump  site was  a pit  dug  into   the  fine  sand,
 approximately 100  feet (30 m)  by  300 feet  (91 m)  and  from
 10  to  15  feet (3.0-4.6  m)  deep.   Fifty-five gallon (208  1)
 drums  containing  liquids and solids, 5  gallon (19 1)  lab
 packs, and  bulk liquids were  dumped  into the  pit.  Clean-
 up  efforts  indicated  that over 4,800 drums and containers
 of  miscellaneous  chemicals  were  disposed  at the  site.
 Over 9000 gallons  (34,000 1) of  bulk chemicals have been
 removed from the site.   Since  many  drums  and containers
 had  deteriorated  and  the dumping  of bulk chemicals was
 also involved,  the estimation of exact quantities  disposed
 at  the site  is  not possible.

     ^Samples from the upper ground water and surface seep-
age  indicate that a large variety of organic and inorganic
chemicals  may  have  been  dumped  at  the site,  including
chlorinated  compounds,  solvents,  and pesticides.   During
drum excavation,  numerous  drums  containing PCBs  were
found.    Specific  chemical substances  identified  at  the
site are listed below:
     Toluene
     Ethylbenzene
     Xylenes
     Styrene
     Pentachlorophenol
     Endrin
     BHC (lindane)
     Ant imony

     Arsenic

     Beryllium
Mercury
Zinc
Adipic acid
PhenoIs
Naphthalene
Pyrene
Methylene chloride
Vinylidene chloride
  (1,1-dichloroethane)
Ethylene dichloride
  (1,2-dichloroethane)
Trichloroethane
                                  300.68(e)(2)
                                  (i)(B) amount
                                  and form of sub-
                                  stances present
                                     11-9
-------
     Chloroform
     Trichloroethylene
     Benzene
1,1,2-trichloroethane
1,1,1-trichloroethane
Chromium
DESCRIPTION OF CONTAMINATION

     In  January 1980,  the  Plumsted  township  sheriff's
office informed the NJ Department of Environmental Protec-
tion (DEP) of the existence of  the  Goose  Farm site.  This
information was  provided  as input  to  a  DEP investigation
of possible pesticides  in  drinking  wells  in  the Plumsted
area.   During the  next  six months, DEP  conducted hydro-
geological  assessment  activities  including sampling the
nearby  stream,  installing  and  logging 17  ground water
wells, conducting a metal detector and resistivity survey,
and reviewing regional geology and well drillers logs from
existing local wells.

     The results from the metal detector survey identified
the location of two separate drum disposal pits.  Also the
data  from  the test well cores were used to construct the
following lithology beneath the site.

     A surface resistivity survey was performed to approx-
imate the  extent of  ground water  contamination  from the
site.   By varying  the  spacing of  electrodes,  different
depths in the subsurface can be tested.  The resistance of
the  subsurface media  is measured  at  various  depths  to
provide an indication of changes  in strata or evidence of
ground water  contamination.   Profiles of  a certain depth
across a horizontal distance can also be obtained to indi-
cate strata variations or contamination.   The resistivity
profiles  conducted  by DEP  indicated  a  contaminant plume
200  feet  (61 m)  wide originating  from  the drum  pit and
moving to  the stream north of  the  site.   The resistivity
soundings  suggested potential  contamination  of up  to  60
feet (18 m)  in depth beneath the site,  with the majority
of  contamination occurring within  a  depth  of  40  feet
(12 m).

     Stream sampling data has also  indicated that  polluted
ground water was leaching into  the  stream causing contami-
nation of surface water.  Resistivity  sounding data on the
other side of the stream indicated  that contaminant migra-
tion was  halted by the  hydrologic barrier created by the
                                 300.63(a)(2)
                                 investigation
                                 300.64(a)
                                 preliminary
                                 assessment
                                     11-10
-------
                           TABLE 1

             GENERALIZED GEOLOGIC SECTION OF SITE
Depth Below Site (feet)
0-13
13-15
15-23
23-60
60-62
meters
0-4
4-4.6
4.6-7
7-18
18-19
Formation
Kirkwood (upper)
Kirkwood (lower)
Lower Kirkwood
and Manasquan
Vincetown
Homers town
 stream.  ^ DEP  also  concluded  that  the  contamination
 extended  into the Vincetown  aquifer and possibly down  to
 the Vincetown-Hornerstown  interface,  but  did  not  affect
 any^local wells.  However,  a  potential  for  future  contami-
 nation  of wells  in  the Vincetown aquifer did exist  if  the
 problem was  not corrected.

      In August  1980, O.K.  Materials Company (OHM),  Find-
 lay,  Ohio,   initiated  additional ground  water monitoring
 and prepared to  implement  site clean-up through an  exist-
 ing state  contract.    O.H.  Materials Company installed  34
 additional wells  to  further define  the contaminant  plume,
 took  soil samples and developed data  to support the  design
 of  a  ground  water recovery  system.   The OHM data from mon-
 itoring wells indicated that  the plume  was less than  140
 feet  (43 m)  wide.  O.H. Materials  Company also concluded
 that  the  plume  had  not  reached below a  depth  of  36 feet
 (11 m), which corresponds  to  a cemented sand seam encoun-
 tered in the Vincetown formation.   A review of monitoring
 data  indicates  that  contamination data  at  depths  greater
 than  36 feet (11  m)  were available  from only three  of the
monitoring wells, one  of which was  outside the boundaries
 of  the  shallow plume.   The  hydrologic data developed from
 the resistivity survey  and  well  sampling  was adequate for
 assessing  the  shallow  ground  water  and   surface  water
contamination.   However, resistivity data  is  qualitative
below 40  feet  (12  m)   at  this  site  due   to the  complex
geology.  Therefore,  because only three wells were used to
define  the lower limit of plume depth, complete definition
of  the  plume  at  depths below  40   feet  (12 m)  was  not
developed.
                                     11-11
-------
     Initial levels  of  contaminants in ground  water were
highest  for  methylene chloride, benzene,  and  toluene  at
134, 106,  and  88 parts per million (mg/1),  respectively.
Total organic carbon in shallow ground water depths ranged
from 1600 to 17,000 ppm (mg/1).  Metals values were in the
parts per billion (ug/1) range  and  not considered a prob-
lem.   Soil  samples were also  taken which also  gave very
high TOG readings.
PLANNING THE SITE RESPONSE

Initiation of Response

     Based  on  data from DEP tests of surface and  ground
water that  indicated the presence of a number of contami-
nants, including benzene, toluene, and methylene chloride,
DEP concluded in July 1980  that  the  Goose Farm site posed
a threat to human health.   Ground water testing indicated
contamination of  a  shallow aquifer below  the  pit.   Tests
of  a deeper  aquifer,  which  provides  drinking water  to
nearby  residents,  were inconclusive.   However,  local
geological characteristics, the  downward  vector of ground
water  movement,  and  the long period of time that wastes
had  been at  the site   suggested  that the  lower aquifer
might  soon  become contaminated.  In addition, an  uncon-
trolled discharge to surface water,  which justified fund-
ing  under  311 (k) of the Clean Water Act,  prompted DEP1 s
response.  Although  tests of nearby  drinking  water wells
during  the summer of 1980  showed no  contamination above
background  levels, DEP believed  that the threat to drink-
ing  water  was additional  incentive to justify immediate
action.  Another  factor  prompting DEP's  response  was the
fact  that  the  site  was  causing  an  apparent uncontrolled
discharge  into  the  adjacent  stream  system and  thus  was
potentially eligible for section  31l(k) funding.

Selection of Response Technologies

     The selection of response activities and technologies
at the Goose Farm  site  occurred before definite protocol
was  available from  the  presently emerging (CERCLA) Super-
fund  program  such  as   the  procedures   outlined   in  the
National  Contingency Plan.   Also,  selection  of specific
technologies  and  the decision  to clean-up  the  site seems
to  have  been  carried   out  under  a  climate  of  urgency
prompted by the executive management  of DEP and the poten-
tial  availability of 311(k)  funds.   As mentioned earlier,
the N.J. Department of Environmental  Protection (DEP) con-
ducted  the  preliminary  site investigation during January
through June, 1980.  They then utilized OHM in August 1980
300.68(e)(2)
(i)(C) hazard-
ous properties
300.68(e)(2)
(i)(D) hydrogeo-
logical factors
300.65(a)(2)
threat to
drinking water
                                     11-12
-------
through an existing  time and materials  contract  basis  to
accomplish the following objectives:

     •  Accumulate data that indicated there was an uncon-
        trolled release  of  hazardous substances  into  the
        tributaries  of  Crosswick Creek  and determine  if
        this release was originating from Goose Farm site

     •  Obtain  sampling  data to  show the  extent  of  the
        ground water contamination  to  a  degree sufficient
        to enable  assessment with  respect  to  the  elimi-
        nation of the discharge to the Creek

     •  Contain the  discharge by a  three-phased  approach
        which included:

        - a  peripheral ground water  treatment  system
          (referenced as System A in the literature),
        - excavation of  the  drums   and  the most  grossly
          contaminated soil on site,
        - possible  further  ground  water control  at  the
          heavily contaminated area, if needed.

     •  Improve or  protect  ground   water  quality  at  and
        adjacent  to  the  site  sufficient  to  assure that
        further significant surface water discharges would
        not occur.
     The DEP directed OHM to proceed with clean-up efforts
using  ground  water  pumping  and  treatment  to  remove  the
contaminants from the ground water.  In addition, OHM pro-
posed  (with DEP  approval)  to  use  their patented system to
collect contaminated ground water  directly  under the drum
burial site, treat the collected water, and spray irrigate
and pressure  inject  treated  water over the  site to flush
contaminants  from the  underlying  soil with time.   O.H.
Materials Company also proposed to use biological degrada-
tion  with  mutant  microorganisms  to   complete the  soil
clean-up process.

     Several alternative remediation  techniques were con-
sidered by DEP,  including:

     •  Installing an open or gravel filled trench between    300.68(g)
        the site and  the stream to intercept contaminated    development of
        ground  water  with  treatment  prior to discharge    alternatives

     •  Pumping  and  treatment  to  contain  the plume rather
        than to collect it
                                     11-13
-------
     •  Installing a slurry wall with ground water pumping
        or a french drain upgradient of the wall

     •  Capping the site

     The first  two  measures  were  temporary containment
measures  that  could  have  been  implemented to stop the
immediate ground water discharge to the stream.  The major
benefit of  utilizing  the trench or  pumping  methods would
have been to  provide  DEP with  temporary  stabilization of
conditions  at  the site  while  a more  detailed assessment
could be conducted to determine optimal long term remedia-
tion.  These measures would have involved lower quantities
of collected ground water requiring treatment.  Thus, low-
er  treatment   costs  would  have resulted  over  thex short
term.

     The installation of a slurry wall to a 60-foot (18 m)
depth (beginning of Hornerstown aquiclude) with pumping of
the upper aquifers may have been a technically and econom-
ically viable long-term alternative, given a more detailed
hydrogeological  and  engineering assessment.    The  slurry
wall  may have  prevented  migration  of   the  contaminated
ground  water  into  the  stream,  and  further  into  the
aquifer.  The Hornerstown, Red Bank,  and Navesink forma-
tions  consist  of 75  to 80  feet  (23-24  m)  of relatively
impermeable  strata.    The  thought  behind  considering  a
slurry wall is that it would have cut off a portion of the
aquifer  (or the  entire aquifer depending  on  design)  so
that  a minimum  of clean  ground  water   would be  pumped
during pumping of  the  contaminant  plume.   This would have
substantially  reduced pumping  and  treatment   costs,
especially  given  the  high permeability of  the subsurface
at  the  Goose  Farm site.   The   slurry  wall  alternative at
this time, however, wasn1t considered by state and Federal
decision-makers to be a reliable technology and there were
doubts concerning  this technology's effectiveness  in the
situation at hand.

Extent of Response

     The  DEP's goals in  the  Goose Farm clean-up were to
eliminate the  discharge  of contaminants to surface water
and  to mitigate  the   threat  to ground  water.   The DEP
issued  itself  a  permit  which established   an  effluent
criterion for  the  treatment system,  requiring that water
discharged  from the  system contain  less  than 100  rag/1
total organic  carbon  (TOG).   By December 1980,  NJDEP had
established a ground water  clean-up  goal  of 100 mg/1 TOG.
The pumping and treatment response was terminated in March
1981 when NSDEP  had determined ground water contamination
to be below 100 mg/1.

                                     11-14
300.68(e)(l)
initial measures
300.68(j)
extent of remedy
-------
     Another  factor  that  determined  the extent  to which
the site was cleaned up was the amount of available funds.
While DEP had  intended,  after the  ground  water treatment
system  was  dismantled,  to attempt a  relatively complete
decontamination  of  the  soil  and  ground  water  using
biological  treatment,  no state funds  were then available,
and  the  section  311(k)   and  Superfund  funds  were  only
available  for  emergency  responses.   By March  1981,  the
situation at Goose  Farm was  not  considered  an  emergency.
The  DEP removed  the  excavated  wastes  in  November 1981,
when additional state  funds became  available.
DESIGN AND EXECUTION OF SITE RESPONSE

     The  following  sections describe  the  design,  construc-
tion,  and operation conducted  at the Goose Farm  site  from
August 1980 to January 1982.

     Remedial actions conducted  at Goose  Farm  consisted  of
the  following activities:

     •   The installation  of  a wellpoint  collection/spray
        irrigation  system to  contain  and thereby  prevent
        contaminated  ground water  from entering  the  creek
        (System A)

     •  The  installation  of   a  wellpoint  collection  and
        recharge  system  to  flush  contaminants  from  the
        soil  and  collect  contaminated  ground  water
        directly  beneath  the drum disposal area  (System  B)

     •  Treatment of  contaminated ground  water

     •  Drum removal, segregation and  treatment

     •  Temporary storage  of drums and  bulked  wastes

     •  Final disposal of  drums  and bulked wastes.

     The  above remedial  actions  are  discussed in the  fol-
lowing sections:

Wellpoint/Spray Irrigation (System A)

     Wellpoint  system  A was installed  in  September  1980
between   the drum  pit  on the  Goose   Farm  Site  and the
nearby stream  to  prevent further   contamination  of  the
surface   water  by  contaminated  ground  water seepage.  The
The   wellpoint   system    composite   cone   of  depression
acted  as  hydrologic  barrier  to  the  migration  of  the
contaminant  plume  to  the stream.   The  wellpoint  system

                                      11-15
300.70(b)(D-
ground water
pumping ; plume
containment
-------
 consisted of  about 400  feet  (122  m) of  6-inch  (15  cm)
 exposed   aluminum  header   pipe  with  52 wellpoints  spaced
 about  every 7.5  feet  (2.3 m).   The wellpoints  were  com-
 prised  of  3-foot  long  (0.9 m)  long  jettable  recovery
 points screened  with 200  mesh dutch  weaved  stainless steel
 screens.   The wellpoints  were joined  with  1  1/2  inch  (3.8
 cm) diameter metal pipe,  and  installed by water jetting to
 a  depth  of  approximately 22 feet  (6.7  m),  which  corre-
 sponds  to the beginning  of  the Manasquan  aquitard.   (The
 configuration  of  wellpoint   system  A  is  shown  in  Figure
 4.)   The wellpoint  system was pumped  at a  rate  of about
 50,000 to 75,000 gallons  (189,  271  -  283,  906) per  day to
 contain  the migration  of contaminants.  Following  treat-
 ment  to  remove contaminants  (which will be  discussed later
 in  this  section)  the  collected  ground water  was  spray
 irrigated via  6-inch (15  cm) aluminum  headers.   Two spray
 irrigation  systems were  initially installed  to handle  the
 flow  from  the system  A  wellpoints.   The primary  spray
 irrigation  system was  located  behind the main battery  of
 wellpoints,  so  that  the mound  created  by  infiltrating
 water  would form  a second positive hydraulic barrier  in
 addition  to  the  negative  hydraulic  barrier created  by  the
 wellpoints1  composite  cone   of  depression.   A  secondary
 spray  irrigation  system  was  located  northwest  of  the
 collection area  to handle the remaining flow.   The primary
 spray  system  was  dismantled  after  a time and  used as  a
 recharge  system  for wellpoint  system B in  the  drum  pit
 area.

     A  vacuum receiver  (himulator) was  used  to  effect
 ground water  recovery in  the wellpoint system.  A  second
 vacuum system  had  to be added to  achieve  the  required  flow
 rate for  creating  an adequate cone of  depression.

     Certain  operational  requirements  were  addressed
 during site  clean-up with respect  to wellpoint  system  A.
 Winterization  of  the wellpoint  system had  to be  carried
 out to protect system elements  from  freezing  temperatures.
 This  was  accomplished by constructing  wooden   housings
 (snake barns)  around  the piping.   Wooden housings were
 also constructed  around vacuum system elements.   Adjust-
ments to  the  wellpoint system  were  made throughout pump-
 ing.   Initially the  system  was adjusted  to  give  uniform
 flow.   Later  adjustments to the  system involved  turning
 off wellpoints in which  relatively  clean water was being
 pumped.   This  action allowed  greater pumping  of wellpoints
 located in pockets of higher  contamination.

     During the course of pumping, OHM decided to  extend a
 section of wellpoints  60  feet (18 m) to  the  southeast,  to
 offer greater  containment of  the contaminant  plume.
                                      11-16
-------
                                                     Temporary Drum
                                                    Storage Cells
                                                            System A

                                                             ^^^ Recovery Header
                                                             ——- Primary Irrigation System
                                                             	Secondary Discharge System

                                                            System B

                                                             — • — Recovery Header
                                                             —..  Wellpoint Injection System
       Grossly
     Contaminated
     Soil, Crushed
     Drums, Waste
       Carbon
                                                                    Stream
                                                                          Former
                                                                          Drum Pit
To Rt. 539
(300 yds.)
NOTE; System A Primary Irrigation Piping Dismantled and
      Remade into System B Piping for Weilpoint Injection

   Figure 4. Ground water Pumping and Treatment System at Goose Farm.
                               Plumstead, New Jersey
                                         11-17
-------
     During  the  winter operation  of  the spray  irrigation
system it was noticed  that  spray nozzles  were  freezing  and
clogging.   The  spray  nozzles were removed  and  the  system
continued to  be  operated without  any significant  perfor-
mance impact.  At one  point during the  pumping/treatment/
irrigation  operation,  runoff  from  the  secondary  spray
irrigation  system was  severely  eroding  a  channel to  the
stream.  The eroded  area was  filled with  gravel  to control
future erosion problems.

     System A was operated  from September 1980 to February
1981,  when  it  was  determined  that  the   drawdown  from
system B was enough  to contain the plume.

Wellpoint Collection/Spray  Irrigation/Pressure Injection
(System B)

     Wellpoint collection/injection  system B  (also shown
in  Figure 4)  was   installed during December 1980 in  the
drum burial  area  to  remove  contaminants  in  the unsaturated
zone  and  the  ground water directly   beneath the site.
The  first   phase  of   operation   consisted  of  installing
wellpoints  to a  shallow depth,  i.e. in  the unsaturated
zone  above  the water  table,  which occurred  at   depths  of
around 7 to  13 feet  (2-4 m),  under the site.   Ground water
collection and injection at this  depth would flush contam-
inants  from the  unsaturated  zone.   Later,  the  wellpoints
were  lowered into the water  table  to collect  the contami-
nated  ground  water  plume.    Collected  water   underwent
treatment,  as did  the water  from System  A.    Initially,
treated  water was spray  irrigated onto  the drum disposal
area  to  flush contamination  from  soils  in  the unsaturated
zone.   Eventually treated water was  pressure  injected  via
a  separate wellpoint system directly into substrata in the
drum  disposal area  in order  to   accelerate  flow movement
along  surfaces  of less permeable  layers.  As with system
A,  wellpoints were  constructed  of  3-foot (0.9  m)  Dutch
weave  stainless  steel screens  joined with 1.5  inch (3.8
cm) metal  pipe  on centers of 7.5  feet.   Approximately 100
wellpoints  were  connected  to about 900  feet  of  6-inch (15
cm) aluminum header  pipe.   Again,  a vacuum system was used
to recover  the ground  water.

     Prior   to  soil  flushing,  observations  in   test  pits
(dug  by  a backhoe)  indicated that contamination was pres-
ent as a black ooze above  a  clay layer, which  was 3 to  4
feet  (0.9-1.2 m)  deep.  Analysis of the  clays  indicated
that  a high level   of organics  (30 mg/g TOG) was  seeping
slowly through the  clay layer.   To facilitate flushing of
the contaminants from the  low permeability clay  layer, the
300.70(b)(2)-
(iii)(E)(l)
in situ treat-
ment:  solu-
tion mining
                                      11-18
-------
 pressure  injection system was operated with  varying  pres-
 sures  by  using  on/off  relays  in  order  to  create a pressure
 pulse.

     Initially,  bench  scale leaching tests  indicated  that
 10  complete soil rinses, or a total of 11,000,000 gallons
 (4.2 X 10  1) of water would  be  required  for complete soil
 flushing  to  acceptable levels.    When  OHM  was  asked  to
 terminate operations,  the  total  amount of water processed
 was  approximately 7.8  million gallons (2.9  X  10' 1)  for
 systems A and B.   Soil TOG values  in the drum  pit area  at
 the termination  of soil flushing  operations  averaged  about
 3,300  mg/1.  The above criteria  suggest that  decontami-
 nation  of  soils  may   have  been  incomplete.    System  B
 operations  were  terminated  in March 1981.

     As with system A,  snake  barns  were constructed around
 piping  to  protect against  freezing during  winter opera-
 tion.
Contaminated Ground Water Treatment

     The   250,000  gallon   (950,000  1)   per   day  capacity
treatment  systems  at  the Goose  Farm  site  received  contami-
nated  ground water collected  by wellpoint system  A and  B.
It   consisted  of  an activated   carbon  fume scrubbers  to
remove volatilized organics, a clarifier,  a  four-cascade
aqueous  carbon  treatment  system,  aeration to  strip organ-
ics  not treated by  the  aqueous carbon treatment  system,
and  an effluent storage  tank.   The configuration of the
treatment  system is shown in Figure  5.

     Contaminated  ground water  flowed through each of the
two  wellpoint  systems  to   two  vacuum  receivers,  one for
each system, which developed the necessary suction for the
collection  systems.   The vacuum  in  these  units  enhanced
volatilization of  organics  from the aqueous to the vapor
phase.   Organic  loading  in the influent  stream  averaged
about  157 mg/1 Total  Organic Carbon  (TOG).  Volatilization
occurring  at the vacuum  receiver  removed about  13  percent
of  the TOG present  in  the  aqueous  stream.    Vapor phase
carbon  treatment systems  (fume scrubbers) were  then used
to  remove  organic contaminants from the  resultant vapor
stream.  The carbon fume scrubbers reduced organics  in the
vapor  phase from about 800  ppm  to below 100 ppm.

     The carbon adsorption  units  off the vacuum  receiver
were vessels with a bed surface area of approximately 38.5
square feet (3.57 m ).  Air  flow (generated  by  the vacuum
receiver) could  reach up to 300 cubic  feet  (8,500  1) per
minute.  Each vessel  was  charged with  up to 4,500 pounds
(2,041 kg)  of carbon  for treating the organic vapors.
300.70(2)(ii)
direct waste
treatment
methods
300.70(b)(2)
carbon
adsorption
                                     11-19
-------
          Sample Locations

          1.  Vacuum receiver influent
          2.  Vacuum receiver influent
          3.  Clarifier
          4.  Absorber unit 'A*
             Absorber unit 'B'
             Absorber unit *C*
             Holding tank
             Holding tank
                      NaOH
         10.
Fume scrubber effluent
(air)
Water storage container
 I
t-o
O
typical
r~7<5Ji 1 f
> i i ;,.J-
A/' F
-A^
Ground Water
X"*^ Containment
/ • System
Drum Pit
-*^* Recovery System
f/J J.
                           Discharge to Primary or
                           Secondary Spray System
                                                                                Recovery and Treatment Equipment
                                                                                A.  Vacuum receiver (Himulator)
                                                                                    Portable clarifier
                                                                                    Liquid transfer station
                                                                                    Multi-stage carbon absorption units
                                                                                    Storage and sampling tanks
                                                                                    Vapor phase fume scrubber
                                                                                G.  Water storage container
                          Figure  5.   Schematic  View of  Treatment  System  at the
                                        Goose Farm Site (O.K.  Material?   Co., 1981)
-------
      The  aqueous  effluent  from  the two  vacuum receivers
 flowed  into  a  clarifier  to  reduce  suspended  solids  and
 heavy metals  prior  to treatment with  carbon.  The  pH of
 the stream was adjusted with sodium hydroxide to about 6.0
 to enhance clarification.   Polymer flocculants  were tried
 but found to be only  marginally  effective.   The clarifier
 was a  portable  unit of 12,000 gallon  (45,000 1)  capacity
 with  a mixing  chamber,  a  sludge collector  and  decant
 system, and  a  skimming apparatus.   Detention time  in  the
 clarifier was about 200 minutes.  Organic  loading  in  the
 clarifier influent  stream  averaged about  136  mg/1.   About
 9 percent of TOG in the influent stream was removed by the
 clarifier.   Effluent  from clarifier flowed  to  a  transfer
 station,  where  flow  equalization  occurred.   Multi-stage
 pumps  provided a flow rate range of from 25 to 150 gallons
 (95 -568 1)  per minute to  the carbon adsorption system.

      Carbon  adsorption of  the  aqueous  stream consisted of
 three  2-cell  adsorbers,  in  which  any  two  would  be  con-
 nected  in series during  operation,  while the remaining
 unit was being  recharged  with fresh carbon.  Influent to
 the carbon   adsorption system  averaged  125  mg/1.    The
 carbon adsorption system  removed about 62 percent  of  the
 remaining TOC.   Final  effluent TOG  after carbon  adsorption
 was about 54 mg/1,  which  demonstrates  an  overall  removal
 efficiency of 66 percent.   Spent  carbon was stored on-site
 for six months  prior to off-site  disposal.

     A  100,000  gallon  (3.8 X  105  1)  storage tank  was
 installed  as  a modification to the  existing system to col-
 lect  effluent overnight prior  to discharge.  This  elimi-
 nated  the  additional cost  of night-time sampling  and  also
 provided  a  safeguard  against releasing  water that  was
 above  the  effluent discharge limit  of  100  rag/1 TOC.

     TOC was  the main  parameter used to monitor treatment
 plant  operation.  Analyses  for  additional  chemical com-
 pounds  were   conducted only  during the 21-day treatment
 plant  study  period in  February 1981.   It was during this
 time  that  methylene chloride  was observed to be breaking
 through  the  carbon   system,   i.e.  it  was  not  being
 adequately  removed  and causing  abnormally  high effluent
 concentrations.

     The methylene chloride  problem was  solved by install-
 ing an aeration  system  within the 100,000  gallon (380,000
 1)  storage  tank.  The  aeration  system  consisted  of a
 series  of  3-inch  (7.6  cm)  PVC headers  installed  about 3
 feet  (1  m)  over the  liquid surface.    Stored  water  was
 recycled through the spray aeration system until the water
met the discharge limits.
300.70(b)(2)
(ii)-(C)(l)
air stripping
                                     11-21
-------
     During winter  operation the  spray  irrigation  system
was observed to be sagging due to the weight of the  ice on
the headers; however,  no corrective  action was required.
The treatment  system was operational  from September 1980
to March  1981,  during  which a total  of  7,800,000 million
gallons  (2.9  X  10   1)  of  contaminated ground  water was
treated and discharged.

Waste Removal^

     Waste removal operations  at the Goose Farm site were
carried  out from September  to October of  1980.  During a
45-day period,  over  4,880  drums  and containers were
excavated,  analyzed,  secured,  and  segregated.    Table 2
gives  an  inventory  of  drums and  containers recovered from
the burial area.
300.70(c)(2)(i)
excavation
                          TABLE  2

        Inventory of Recovered Drums and Containers
Drummed Solids
Drummed Liquids
Overpacked Solids
Overpacked Liquids
Lab Packs
5 gallon (19 1) drums (full)
5 gallon (19 1) drums (empty)
55 gallon (208 1) drums (empty)
55 gallon (208 1) drums (crushed
or fragmented)
TOTAL
containers
1,201
402
23
278
92
2,037
512
288
54
4,887
      Excavation  operations   proceeded  as  follows:    The
 boundaries and the depth  of drum burial were  defined.   A
 bench was  then excavated near one end of  the burial pit to
                                      11-22
-------
  the drum  pit floor  level.   This  allowed  "above-ground"
  access  to the  buried  waste  materials.    Excavation  of
  drums, containers and contaminated soil proceeded from one
  end of the pit to the other.

      A backhoe/front end loader and  two  QHM-designed drum
  grapplers  were used  to  complete removal operations.   The
  backhoe  was used  to excavate to the  surface  of the drums.
  The drum  grapplers  were  used to  grasp  the  drums  and
  transfer them from  the  excavation  area  to  the  front  end
  loader.    The  loader was  used  to  transport  drums  to  the
  operations area and  to  the  staging area.   Drums that could
  be  overpacked were  overpacked.    Other  drums  containing
  solids were  secured  on  site while  badly degraded  drums
  containing  liquids  were  tested   for  compatibility  and
  emptied  into  separate concrete  tanks according  to whether
  they   were  acid,   base,  or  neutral  materials.    Bulked
  liquids  totalling 9,077 gallons (34,000  1) were  disposed
  of  via Chem Clear,  an aqueous waste  pretreatment  facility
  in  Chester, PA.

      About  3,500  tons  (3,200 Mt)   of highly  contaminated
  soil  and  about   20,000  tons  (18,000  Mt)  of  moderately
  contaminated soil were excavated from the drum burial  area
  and  segregated into  two  separate  piles  on  site.    The
  severely contaminated soil  was  analyzed and found  to  con-
  tain less than 50 mg/kg PCS.

 Temporary Storage  of Drums and Bulked Wastes

      By December 1980, drums  and bulked wastes were  staged
 on-site in anticipation of final disposal.  Provisions  for
 temporary  storage were  made.   Contaminated  soils and PCB
 contaminated carbon were stockpiled on-site.  A  6-ml black
 plastic  liner  was placed  as a  foundation for  the waste
 piles  while  a plastic  liner was  also  used to  cover the
 piles.   Wood from dismantling the  snake barns  was used to
 weigh  down  the plastic   top liner.    Stored  drums  were
 underlain and  covered  with a clear  plastic liner.

      The  wastes remained  on site for several months await-
 ing  funding  for  final  disposal.    In  July  1981,  a  site
 visit   revealed general   deterioration  of  provisions  for
 temporary  storage.   Wind  conditions had partially  torn
 plastic top liners from  the  drum  storage  area  and  waste
 piles.   Drums  were  observed  bursting  from the  excessive
 heat  caused by a  "greenhouse" effect  resulting  from using
 clear  plastic  to  cover  the  drums.    The  clear  plastic
 lining  was  degrading due  to contact  with  the  organic
vapors  and  citizens  in   the  area were  complaining  about
health  problems they  felt were  caused by  noxious  fumes
from the  site.   Heavy rains  had  eroded  some of  the  waste

                                      11-23
-------
from  Che  storage piles.   Several  of the  drums were  in
danger of falling into the drum pit, because of erosion.

Final Disposal

     In November 1981 final disposal  of  the stored mate-
rials  was initiated.  O.K. Materials Company used a dozer
and  a front end loader  to empty and crush the drums, and
loaded the bulked  wastes for transport.   About 4,320 tons
(3,930 Mt) of  wastes, including the 3,500 tons (3,200 Mt)
of highly contaminated soil, were transported in 205 truck
loads  to the CECOS International disposal site in Niagara
Falls, New York.  In  addition,  12  drums  of PCB waste were
transported to Rollins Environmental Services, Bridgeport,
NJ for disposal.
300.70(c)
off-site trans-
port for stor-
age, treatment,
destruction, or
secure dis-
position
COST AND FUNDING

Source of Funding

     Before   initiating   a  response,   state  officials
attempted   to   enlist   the  cooperation  of  the  party
responsible   for dumping  the  wastes.   The state was not
able  to  negotiate  an  acceptable  settlement with  the
dumper.  The  DEP began work on the site on August 25, 1980
using money  from the New Jersey Spill Compensation Fund.
By  October  19, 1980,  costs  for  the clean-up  averaged
$25,000 per day, and the  state had spent $1.1 million.

     As the state neared  the  limit of  available Spill Fund
monies, DEP  made a  request  through U.S.  EPA  to  the U.S.
Coast  Guard   for funds  under  the Clean Water  Act section
(311k)  Revolving Fund.    Since  the  site was contaminating
surface  water  that   flowed   into  the  Delaware  River,   a
navigable water of the U.S.,  the  clean-up was eligible for
emergency  funds under  section  311(k).   The  request was
approved as state  funds  ran out.

     Accordingly the Coast Guard approved  section  311(k)
 funding  for   the site and set an initial spending ceiling
of  $500,000.    An  on-scene coordinator  for the  site was
 appointed  from  the Emergency  Response  and  Hazardous
Materials  Inspection Branch  in  the  Region II office  of
EPA.   Federal  funding  for the  clean-up  began on October
 20, 1980.    The  DEP's  Division  of Hazard  Management
 continued  as  the managing authority  at the  site,  while EPA
 reviewed  invoices  and forwarded  them  to  the Coast  Guard,
 which  then  reimbursed  the state.  The  DEP  stayed  in  charge
 throughout   the clean-up,  choosing  the contractors, tech-
 nologies,  and  the  clean-up   criteria in  coordination  and
 with concurrence of  the Federal government.
300.68(c)
responsible
party
 300.68(b)
 state RA
                                      11-24
-------
     There was  no  formal cooperative agreement between New
Jersey  and  either EPA  or  the Coast Guard  concerning the
specific  uses  of the federal funds.  The state had a mem-
orandum of understanding from the Coast Guard stating that
the  Coast Guard would reimburse the state only for expend-
itures  approved  by  the  EPA on-scene  coordinator.    The
Coast Guard placed an important restriction on spending  at
the  outset of  EPA involvement,  namely that section 311(k)
funds  could  not  be  used  for waste disposal.   The  Coast
Guard believed  that  New Jersey  Spill  Fund money should  be
used to pay for disposal.

     As work on the  site progressed,  EPA made requests  to
the  Coast  Guard every 2 to  4 weeks to raise the spending
ceiling at the  site, usually in increments of $500,000  or
$1   million.     In December  1980  the  Coast Guard  began
authorizing  smaller  increases,  ranging  from $30,000   to
$200,000  because the 311K money was  nearly depleted.    In
February 1981 part of the  ground water recovery system was
dismantled and  most  of  the  clean-up  personnel  and equip-
ment were removed   from  the site.    These  actions  were
intended  to  reduce  clean-up costs  at the  site  to $5,000
per  day.

     The  Emergency  Response Division  (ERD) of the  EPA
Office  of  Emergency   and  Remedial  Response  assumed
authority  over  section   311(k) funding for Goose Farm  in    300.68(k)
March 1981.  ERD  reviewed   the  status  of Goose Farm and    balancing
concluded that  the site did not present  an emergency and
should  be  given  a  low  priority  in view of the  limited
funds available to ERD  and the  more immediate problems  at
other  sites.     Accordingly,  the  ERD  terminated  federal
funding for the Goose Farm clean-up in March 1981,  with a
final total authorization  of $2.75  million.  According  to
both EPA  and  DEP, the  site  no  longer posed  an  immediate
threat to human health when operations ceased.

     In November  1981, additional  state  funds became
available  for   Goose  Farm.   The  DEP  spent approximately
$600,000 from the  Spill  Fund to  remove and dispose of the
wastes that had been excavated the previous year.

Selection of Contractors

     In August  1980, DEP chose O.H. Materials,  Inc.  (OHM)
of  Findlay,  Ohio  to install and  operate a  ground  water
recovery and treatment system and to excavate wastes.  The
state signed  a  sole-source  contract  with OHM on a  time-
and-materials basis, using the New  Jersey "X-83" contrac-
ting system.   The X-83  system was a mechanism wherein the
state accepted  price sheets  for time and  materials  from a
number of contractors,  then  chose contractors as  the need

                                     11-25
-------
arose, basing  the  selection  primarily  on  qualifications
and availability of the firm and secondarily on prices.

     At  the  time of  the  site response  DEP  believed that
OHM  was  the  only  contractor  offering  the  ground  water
treatment  technology  that was  selected.  O.H.  Materials
billed the  state weekly  for  labor  and  equipment  used in
the clean-up.  No  limit was  set  on  total expenditures for
the job.  The DEP  kept  an official  on the site throughout
the  clean-up  to  oversee the  work  and review  invoices
submitted to the state.

     The second  major contractor chosen for the clean-up
was CECOS  International of Niagara  Falls, New York, which
was  also prequalified and had received  an  X-83 contract.
The  DEP cho se  CECOS  in  November  1981   to  t r anspor t and
dispose  of  4,320 tons (3,930 Mg) of  waste  excavated  from
the  site.    CECOS  was chosen through  an informal compet-
itive  bidding arrangement  because  the   firm  offered the
lowest price for transportation and disposal.

Pr_o_j_e_ct  C_o_s_t_s_

     The cost  of the Goose Farm  clean-up operations  from
August  1980 to  January  1982 was $5.1  million.   Of  this
amount,  $2.35 million came from the New Jersey Spill  Fund
and  $2.75  million  from   federal  sources.    Because the
project  was ongoing  when CERCLA was  enacted  in December
1980,  the  federal funds came from both  the  section  31l(k)
Revolving   Fund  ($1.75 million)  under the Clean Water Act
and   the Superfund Emergency  Response  Fund ($1 million).
Table  3  provides a summary of cost  information.

      Precise  cost breakdown  of  each  of  the  clean-up
elements is not  possible for two major reasons.    First,
the  New Jersey DEP did  not provide  detailed  information  on
costs,   as  well  as  on   other  aspects  of  the  clean-up,
because  release  of such information might have been detri-
mental to  the state's  litigation  against the  responsible
party.  A cost  summary was made  available, but  did  not give
a detailed breakdown of  expenditures.   Second, the  more
detailed cost  information that  EPA  provided  on the  section
311(k)-funded portion of the clean-up  did  not  differen-
tiate between the various tasks  that  OHM performed  concur-
rently at  the site because bills were submitted  to  DEP  on
a  time-and-materials basis.    While   invoices  specified
hourly rates for labor  and daily rental  charges for equip-
ment,  they did  not state  the  tasks  for which the labor and
equipment   were  used.   Given  these   limitations,  only  a
general analysis of expenditures is possible.
300.6l(c)
CERCLA-f inane ed
response
                                      11-26
-------
                 TABLE  3.   SUMMARY OF COST INFORMATION  - GOOSE  FARM,  PLUMSTED TOWNSHIP, N.J.
Task
Mobilization,
excavation and
demobilization
jfoundwater
recovery and
treatment
operation
cost only
Bulking and
.oading wastes
'or disposal
iisposal of
soil and drums
at CECOS
Transportation
of wastes to
Niagra Falls, N.Y
440 ml (708 km)
Off-site sample
analysis
'CB transporta-
tion and disposal
at Rollins,
Bridgeport, N.J.
)rilling
monitoring wells
Site security
guards
Electric power
iscellaneous
Quantity

7,817,480 gal
(29.5 million 1)
4320 tons
(3900 Mg)
4320 tons
(3900 Mg)
4320 tons
(3900 Hg)
(205 loads)

12 drums




Estimated
Expenditure


$380,000(a)
$1,258, 000 (a)
Transporta-
tion and
disposal


$15, 000 (a)




Actual
Expenditure
$3,104,845
$1,120,000
$193,834
$171,272
$246,000
$150,000
$4,100
$24,127
$58,371
$19,260
$12,123
Variance


-$186,166
(-51%)
-$840,728
(-67%)


-10,900
(-72%)




Unit Cost

14^/gal.
(3.7^/1)
(25-40^/gal.
including
set-up)
$45/ton
($50/Hg)
$40/ton
<$44/Mg)
$1200/load or
$57/ton or
12.9^/ton/mi.
(8.84/Mg/km)

$34 I/ drum




Funding Source
N.J. Spill Fund
311(k)/Superfund
N.J. Spill Fund
311(k)/Superfund
N.J. Spill Fund
N.J. Spill Fund
N -J. Spill Fund
N.J. Spill Fund
311(k)/Superfund
N.J. Spill Fund
N.J. Spill Fund
311(k)/Superfuml
N.J. Spill Fund
311(k)/Superfund
N.J. Spill Fund
311(k)/Supcrfund
N.J. Spill Fund
Period of
Performance
8/80-4/81
9/80-3/81
11/81-12/81
H/81-1/82
11/81-1/82
7/81-1/82
1/82
7/80-12-81
4/81-1/82
4/81-1/82
7/80-1/82
I
ho
            Total
                                        $5,000,000 (b)    $5,103,932
              (a) NJDEP estimate - May,  1981
                 (not a binding contractual estimate)
+103,932
(+2%)
      (b) NJDEP estimate - October, 1980
         (not a binding contractual estimate)
-------
Ground Water Recovery and Treatment—
     Installation, operation1 and dismantling of the ground
water recovery  and  treatment system  cost  between $2 mil-
lion and $3 million,  paid  for  from both state and federal
funds.   Of the  $2  to 3  million, DEP  estimated  that the
cost of operating the system, including chemical analyses,
was  $1.12  million.    Counting  operation costs  alone, the
treatment  cost  for  7,817,480  gallons  (2.96  x  107  1)  of
recovered  ground water  was $0.14 per gallon (3.8£ per
liter) based  on the  DEP  estimated operating cost.   How-
ever, if  installation and dismantling costs are included,
the  cost  probably ranged  between $0.26 and    $0.40 per
gallon (6.8  - 10.l£  per  liter).   Unit cost of operation
varied, depending on  the quantity of water processed.  For
example, during  the  last  week  of November 1980, when only
the  A system was operating and no  other work was ongoing
at the site,  the unit cost for recovery and treatment was
$0.27  per gallon  (7.l£  per  liter).    The  unit  cost  of
treatment  can  also   be  expressed  as  a function  of TOG
removal.   During a  21-day efficiency  study  of  the  treat-
ment  system  in February  1981,  when  both  the  A  and  B
systems were  operating,  the system removed  an  average of
31  pounds (14  kg)   of TOG  per day.   Unit  removal cost
ranged from $343 to  $1,300 per pound  ($156 - $591 per kg)
of TOC removed.

Waste Removal and Disposal—
      The  cost of excavating  and staging  4,887 drums and
30,000  cubic yards  (22,800  m )  of  contaminated soil was
between  $1 million  and $2 million,  all federally  funded.
Again, an exact figure is unavailable  because  of the lack
of a cost  breakdown.

      Final removal  and disposal of 4,320  tons  (3,900 Mt)
of  drums  and  soil   and  12 drums  of PCBs  cost the  state
$615,000.    Of   that  amount,  $194,000  was  paid  to O.H.
Materials  for emptying and crushing drums and  loading the
waste on  to  trucks,  and  $417,000  to  CECOS  Internat ional
for  transporting and  disposing of the waste  in  its  Niagara
Falls landfill.   Transportation cost $246,000  for 205
truckloads or $1,200  per  load.   The distance  transported
aas  approximately 440 miles  (708  km).   Disposal costs were
$171,000,  or $40 per ton ($44/Mt).   Based  on these fig-
ures, the unit  costs of  the removal  action were $45 per
ton  ($50/Mt)  for bulking  and loading;  $57  per ton ($63/Mt)
for  transportation  or  17.8 i  per toa  per  mile (10.1  il
*t/km),  and  $40 per ton  ($44/Mt)  for disposal.    Total
per-ton  cost for  removal and  disposal was  $142 per ton
($156/Mt).   Transportation  and  disposal  of  12  drums of
 PCBs by  Rollins Environmental  Services in  Bridgeport, N.J.
 :ost $4,100,  or $341 per  drum.
                                      11-28
-------
 Sampling and  Analysis--
      Chemical analysis  of samples performed off-site cost
 $150,000.   The  cost of drilling  51  monitoring wells was
 $24,127.  No  costs  are available  for  resistivity testing.

 Other Expenses—
      The DEP  hired  security guards from the Plumsted Town-
 ship Police  Department  to guard  the site full-time from
 April 1981'  through January  1982.   Security  cost  about
 $1,500 per week,  totalling $58,371.

      The electric power  cost  for both the  initial clean-up
 activities from August  1980  to April 1981,  and the waste
 removal  activities  from November 1981  to  January  1982,
 totalled  $19,260.   Miscellaneous  expenses totalled
 $12,123.
 PERFORMANCE EVALUATION

      It  is evident  from  the preceding  case  history that
 thorough  planning  is essential to the successful technical
 and  financial conduct  of  response  actions  at  hazardous
 waste  sites.  Protocol  for  planning site response has been
 made  available  through the  development  of  the  National
 Contingency Plan.  At the time of the Goose Farm clean-up,
 no such protocol existed and  guidance from past experience
 was  minimal.   These  facts  must be  considered in  a just
 evaluation of the  response  at the Goose Farm site.

     The  initial intent of  the  clean-up,  as*mentioned in
 the  section  on Selection of Site  Response, was  to elim-
 inate  the discharge of contaminated  ground water  to the
 stream and also  to provide  additional  treatment  of ground
 water  as  required.  No monitoring data was  available to
 ascertain  whether  the  discharge to the stream .has been
 eliminated.   The other  major  objective of  the  site
 clean-up was to achieve some  level of ground water quality
 at and adjacent to  the site.  The established  criterion
 required  that  the  average  ground water- TOC level be less
 than  100  mg/1.   Again, no  monitoring data  were  available
 to determine whether this criterion had been met.

     Additionally,  it   appears  that  there  may have been
 some degree of uncertainty concerning  the extent  of ground
water  contamination  at  the  site,  due  to  the  limited
monitoring well  data.   There also seemed to be a climate
of urgency related  to  the   site  clean-up  resulting  from
public concern  in  the  area,  and due  to these  emergency
response requirements and availability  of funds, design of
the  wellpoint  system  was  based  on  the  limited data
available at  the time.

                                    11-29
-------
     It should  also  be pointed out  that  available ground
water remediation technology at the time of the Goose Farm
clean-up was not broadly used or developed, thus adding to
the difficulty of site clean-up efforts.

     As mentioned  earlier,  preliminary data  from resis-
tivity  studies  suggested  that  the contaminant  plume may
have  reached  a  depth of  60 feet  (18  m) .   From limited
monitoring  well data,  OHM  concluded  that   ground  water
contamination  was  limited  to  36  feet   (11 m) .    They
designed their weilpoints  (System A)  for plume containment
with a  screen depth  of  approximately 17 to 22 feet (5.2 -
6.7 m)  to key  into an aquitard.   There is some suggestion
in the  OHM literature that the weilpoints were supposed to
be lowered at a  later date to take care of deeper contam-
ination,  presumably   to 36  feet  (11  m) .    However, the
System  A wellpoint network was shut down in  February 1981
during  the operation  of System B.  The  System A wellpoints
were  never  lowered  to  a  greater depth  to collect deeper
ground  water  contamination  (the reason  for  not  lowering
System  A  wellpoints   is  not  known).   In any case,  it is
evident from the documentation that  ground water  treatment
objectives were  initially  not well defined and were  being
modified as the  clean-up proceeded.

     Another  occurrence at  the  Goose  Farm  site  was  that
ground  water  pumping,  treatment,  and  recharge operations
were  carried  out  during  the  winter.   Winter operations
required  that  piping systems be insulated by wooden  snake
barns  and that  process buildings  be  constructed  around
treatment  plant  unit  operations.    The  construction of
shelters  for these components  resulted  in  significant time
delays  and  additional  costs.    Also,  winter  operation
caused  operational  problems that  were described  in  the
previous  section.   The expense of winter  operation  should
be  considered  in the future in the  design and  planning  of
responses for uncontrolled hazardous waste sites.

      Proper  planning  relative to  the  timely  removal  of
waste  materials  staged  on-site is  also  an important  aspect
of  site  response.    At  the  Goose  Farm site,  a  delay  in
transporting  staged   wastes  off-site caused  a  degradation
of  temporary containment provisions, and may have resulted
 in  recontamination of previously cleaned soils.

      At present, the  documentation suggests  that  contam-
 ination of  the lower  ground water  regions  has  not  been
 thoroughly  removed and may still pose a significant threat
 to  drinking  water  wells.   Remediation  relative to this
 problem may be  necessary.   A report has  been  prepared by
 Weston Consultants   (Weston),  West  Chester, Pennsylvania
 detailing additional sampling  and  analytical requirements

                                      11-30
-------
for adequately defining the lower aquifer contamination at
the Goose  Farm site.   These  include the  installation  of
multi-level cluster wells,  a  piezometric survey, monitor-
ing wells  for  EPA  priority  pollutants,  pumping  tests  on a
minimum of  two wells  on-site,  contaminated  soil analysis
and  detailed   mapping  of   the  extent  of  contamination.
Also, in the report, a number of alternatives for cleaning
up the  remaining  ground  water  contamination  are assessed
in terms of technical  feasibility and costs, including the
installation  of a  slurry   trench,  french drains,  radial
wells,  deep  well  ground   water  pumping,  and  alternate
aqueous treatment  scenarios.    Weston concluded  that  the
best  clean-up  option  would  be  one  similar  to the  OHM
system, but would  be designed  using  more detailed data on
contamination.

     Temporary measures to  control site  discharges  can be
implemented at uncontrolled hazardous waste sites to allow
time  for  proper program planning prior  to  initiation  of
extensive  site  clean-up  activities.   Thus, more efficient
and effective remediation techniques can be identified and
implemented.  An alternative response which may have given
greater flexibility at the Goose Farm site would have been
to  install  one  of the  temporary  containment actions
described  in   the   section  of  this   case study  entitled
Selection  of   Site  Response.    Thus, a  cut-off  drain  or
pumping just  to contain  the plume could  have been used on
a  temporary basis, while   a  detailed  engineering  report
could be prepared  which would  provide an adequate assess-
ment  of existing  data,  further  monitoring  requirements,
and  a  detailed  analysis   of   long-term  remedial  action
alternatives.
                                     11-31
-------
                                 BIBLIOGRAPHY


Chapin, Richard W.,  November  11,  1980  to  April  23,  1980.   "Weekly  Summaries of
Events for "311 Action at Goose Farm."  TAT II, Princeton Aqua Science,  Inc.,
New Brunswick, N.J.

Chapin, Richard W. ,  October  20,  1980 to  April 16, 1981.   "Daily Log of 311
Action at  Goose  Farm Uncontrolled Hazardous Waste  Site."  TAT II, Princeton
Aqua Science, Inc.,  New Brunswick, N.J.

Chapin, Richard W.,  August  18,  1981.   "A  Preliminary Assessment of the Hazards
Associated with the Goose Farm Hazardous  Waste  Site, Plumsted Township,  N.J."
TAT II, Princeton Aqua Science,  New Brunswick,  N.J.

Cook, Michael  B., September  1981.  "Continuation of  Removal  Activities Beyond
$1  million  at  the  Goose   Farm  Hazardous  Waste  Site  in  Plurasted,  N. J."
Memorandum to  Christopher J. Capper,  Acting Assistant  Administrator  for  Solid
Waste and  Emergency  Response,  U.S.   Environmental   Protection  Agency,
Washington, D.C.

Dalton,  Richard,  July  1982.   Personal  communications, N.J.  Department  of
Environmental Protection, Bureau of Groundwater Management,  Trenton,  N.J.

Dewling,  Richard, T., Acting Regional Administrator, US  EPA Region II, Letter
of February  2, 1982 regarding Weston report on Goose Farm, to John D.  Dingell,
Chairman,  Subcommittee  on  Oversight  and  Investigations, Committee on Energy
and Commerce,  U.S. House of  Representatives, Washington, D.C.

Giardina,  Paul  A.,  February  8,  1982.   "Goose  Farm Status Review," Memorandum
to  George  Tyler,  Assistant  Commissioner, N.J.  Department  of  Environmental
Protection,  Trenton,  N.J.

Giardina,  Paul  A.,  Assistant   to  the   Assistant  Commissioner,  June  1982.
Personal  Communications.   N.J. Department  of  Environmental  Protection,
Trenton,  N.J.

Humphrey,  Allen,  July,  1982.   Personal  communications.   Emergency   Response
Division,  Office  of  Emergency  and  Remedial  Response, U.S.  Environmental
Protection Agency,  Washington, D.C.

Jaffe, Herb, January 21, 1982.   "Toxic  Cleanup Practices Blasted  in Memo  to
DEP," Newark Star-Ledger, Newark, N.J.

Lavache,  Lt.  Mark,  June  1982.    Personal communications.   U.S.  Coast  Guard,
Third district,  Governors Island, N.Y.

Moore, Richard, June 1982.   Personal communication.   U.S.  Coast Guard, Third
 District, Governor's Island, N.Y.

                                      11-32
-------
                           BIBLIOGRAPHY (Continued)


N.J.  Department  of  Environmental  Protection, May  11,   1981.    "Final
Remediation:  Goose Farm, Plurasted Township.   Trenton, N.J.

O.H.  Materials,  Inc.,  November  17,  1980.   "Sampling and  Analysis  Protocol,
Goose Farm Suite."  O.H. Materials Inc., Findlay, Ohio.

O.H.  Materials,  Inc.,  January 3,  1981.   "Summary Report,  Goose Farm  Site."
O.H. Materials Inc., Findlay, Ohio.

Ohneck, Robert J., Letter of March 22,  1982. to  Fred Rubel,  U.S.  Environmental
Protection  Agency,  Region II, Edison,  N.J., responding  to Weston  Report  on
Goose Farm.  O.H. Materials Co.,  Findlay, Ohio.

Panning,  Robert,  July  1982.   Personal  communications.   O.H. Materials  Co.,
Findlay, Ohio.

Pine lands  Commission,   June   1980.    N.J.  Pine lands:    Draft  Comprehensive
Management Plan.  State of New Jersey.   Pinelands Commission,  New Lisbon,  N.J.

Polito, Michael  V., June,  July  1982.    Personal  communications.   Emergency
Response  and  Hazardous  Materials  Inspection Branch,  U.S. Environmental
Protection Agency, Edison, N.J.

Reger,  David,  June  1982.   Personal  communication.   N.J.  Deputy  Attorney
General's Office, Trenton, N.J.

Rubel, Fred  N.,  Chief,  Emergency Response and Hazardous  Materials  Inspection
Branch USEPA Region  II,  February 19, 1981.    "Use  of  Section  311(k)  Revolving
Fund  for  Chemical incidents,  Goose  Farm."    Memorandum  to Michael  B. Cook,
Deputy Assistant  Administrator  for  Office  of  Hazardous  Emergency  Response,
U.S. Environmental Protection Agency, Washington, D.C.

Soil  Conservation  Service.   April,  1980.  Soil  Survey of  Ocean County, New
Jersey.  U.S. Department of Agriculture,  Washington, D.C.

U.S.  Environmental  Protection  Agency.    July  16, 1982.    National  Oil  and
Hazardous  Substances Contingency Plan.    Federal  Register,  Vol.  47, No.  137,
Washington,  D.C.

Weston, Inc., December  1981.   "A Cost-Effectiveness  Study  of Water and  Soil
Decontamination at the Goose Farm Uncontrolled Hazardous  Waste Site, Plumsted
Township,  Ocean  County,  N.J.    Prepared  for U.S.   Coast  Guard, Governor's
Island,  N.Y.
                                     11-33
-------
-------
                               H & M DRUM COMPANY

                            DARTMOUTH,  MASSACHUSETTS
 INTRODUCTION

      Hazardous  wastes  were  stored  and  disposed  at  a  former
 gravel raining site  in North Dartmouth, Massachusetts
 between  iate   1978  and  early  1979.     Contamination  of
 ground  water and  surface  waters  resulted from corroding
 drums buried in  a backfilled disposal  pit  that had  been
 excavated below  the  water  table  during  previous  mining
 operations.   A municipal well located approximately 1,400
 feet  (427 ra) downgradient  from  the  drum disposal  pit was
 closed  under state order due  to the likelihood that  con-
 taminated ground water  from the  disposal  pit would migrate
 towards the  well.  1,1,1 trichloroethane  trichloroethylene
 and other volatile,  chlorinated  organics were detected  in
 an  observation well  located  700  feet  (213  ra)  from the
 municipal well.   The  concentration of  1,1,1   trichloro-
 ethane  exceeded 1  mg/1.

 Background

      The  H & M Drum site is  situated on a  150-acre (61 ha)
 tract of  land immediately south of  Route 6  in  Dartmouth,
 Massachusetts.  The  property had been  previously used for
 gravel  mining  operations  before  being   leased  to  Harold
 Mathews,  president and owner  of H & M  Drum  Company, for
 use as  a  refuse   yard.   in  1978, Mathews began  storing
 drums of  hazardous waste  in  a  warehouse located on the
 property.   Discovery of  this  site  resulted  from a local
 police  investigation   into  hazardous  waste  disposal by
 H & M Drum in the nearby town of  Freetown,  Massachusetts
 in April  1979.  Investigation of the Freetown incident led
 the  Massachusetts  Department  of  Environmental  Quality
 Engineering (DEQE)  to  investigate the  Dartmouth site
 shortly thereafter.

     At  the time of discovery by  DEQE,  the Dartmouth  prop-
erty contained a warehouse  with  approximately 1,000  drums
of waste,  a trailer  with  100 drums,  and  four  earthen-
covered  disposal   pits used for  disposal of   drums.  The
primary disposal pit  contained approximately  300 corroding
and leaking  drums  of  waste mixed with  metal debris  and
 NCP Reference
300.63(a)(4)
discovery
300.64(a)(2)
preliminary
assessment
                                     12-1
-------
tires.  Direct  discharge  of contaminants into the ground-
water occurred because rusting  and  Leaking  drums of waste
burined in the  pit  lay  partially submerged  in the ground-
water.  The other three pits contained fewer than 20 drums
in total.   Figure 1 presents a layout of the site.

Synopsis' of Site Response

     Following site discovery, DEQE sampled a small number
of drums  from the warehouse  and found  them  to  contain a
wide  range  of  organics.   Based  on   their  preliminary
assessment of the site  conditions and the contents of  the
drums,  DEQE  directed the  town  of  Dartmouth to close  the
downgradient  municipal  well  because   of  the  potential
threat to public health.    The   town has had  to  purchase
additional  water from New  Bedford in order to meet their
needs.  A limited  hydrogeologic  investigation was subse-
quently  initiated.  The results  indicated that there were
high  levels  of  volatile  organics  in the  shallow ground
water  in  the area of  the main  disposal pit  and that  the
contaminants were migrating towards the  Route 6 well.

     Response action  to clean up the site was carried  out
in  two phases  due  to a  time  lapse  in  funding  from  the
state  legislature.    The  first  appropriation  of $223,000
for the-Dartmouth site paid for  the majority of  the clean-
up,  undertaken  from  November  11,   1979 to  February  19,
1980.   This  initial  clean-up  effort  included  excavation
and  removal of  320 tons  (290 Mt) of heavily  contaminated
soil mixed  with crushed  drums,  use of  sorbents  to remove
non-miscible  organics from  ground water, construction of
an  interceptor  trench,  and aeration  of slightly contami-
nated  soils.   Because  of  the  funding  constraints,  DEQE
focused on preventing  further contamination of the ground
water by removing the source  of  pollution and did not seek
to decontaminate the ground water.

     Phase  II of the cleanup began upon receipt of  addi-
t iona 1  fund ing  from  the   legislature  a  year and  a ha 1 f
later  and  occurred  from  September  23  through October 9,
1981.   A private firm under  contract to DEQE removed  the
remaining  738  segregated  drums  and  50 tons  (45  Mt)  of
contaminated  soil.   Stockpiled tires  and  metal   scraps
excavated  from  the  disposal pit were not removed,  and  the
ground water  remains  contaminated.

      In the   Spring of  1982,  the town of Dartmouth   funded
a detailed   hydrogeologic  study to  determine  the   extent
of   contamination   and  potential  remedial   measures  for
300.65(a)(2)
contamination of
drinking water
supply

300.65(b)(2)
alternative
water supplies
300.65(b)
immediate
removal
 300.68(f)
 sampling and
 monitoring
                                      12-2
-------
                                         :OP.TH
                                     DISPOSAL VREA
                                        ro -;ELL
                                                         1«
ayout of  the H&M Drum  Site, Dartmouth, Massachusetts



                            (not  to  scale)
                    12-3
-------
restoring the  well or identifying  alternative water sup-
plies.  As  of  November 1982,  this  study  had  not  yet
started.
300.68(d)(l)
scope of
 emedial actions
SITE DESCRIPTION

Surface Characteristics

     The H & M Drum  Disposal  site, is  located in  Dart-
mouth,  Massachusetts in  the  southern  part  of  Bristol
County.  The  site is  situated  just  south  of  Route 6,
approximately  1500 feet (500 m) east of the  intersection
of  Route 6 and  Reed Road.  This is an area of mixed com-
mercial, light industrial and residential use but the area
immediately  surrounding the site is  sparsely  populated.
The major  concern  with  regards to the  location of  the
H & M Drum  site is the  presence of the Route 6 municipal
well approximately  1400  feet (427 m) south  of  the  site.
This well  has  a capacity of 0.5  MGD,  sufficient  to serve
about  65  percent  of  Dartmouth's population.   Figure  2
shows the  location of the H & M Drum site.

     The local  climate of Bristol  County is continental,
experiencing  significant  seasonal, daily  and day-to-day
fluctuations.   The  average  winter  temperature  is 31 °F
(-0.6°C)  and  the  average  daily  minimum temperature  is
23°F  (-5°C).   In summer,  the  average  temperature  is 70°F
(21°C)  and  the  average daily maximum  temperature  is 80°F
(27°C).    Total  annual  precipitation  in  the area  is  42
inches  (107 cm).  Of this, 21 inches (53 cm) or 50 percent
usually  falls  in April  through  September.   In 2 years out
of  10,  the rainfall during this  period  is  only 16  inches
(41 cm).   Average  seasonal snowfall  is 36 inches (91 cm).
The prevailing wind  is  from the southwest.   Average wind-
speed is highest, 12 miles per hour (19 km/hr) in March.

     The   natural  topography in  the  vicinity of  the dis-
posal site was  formed when  sand  and  gravel  from  glacial
outwash  were deposited along the  edges of a  retreating ice
mass.   These  delta  kames,  as  they are  called, were left
behind  as  flat  topped hills which  are  often exploited as
sand  and gravel  pits.   Such was the case in  the immediate
area  of the  H & M Drum  site.   Depth of excavation  varied
but the water table is  at  or  near the surface in most of
the area immediately surrounding  the site.   There  are also
outcrops of  bedrock in the immediate area, as a result of
the excavation  of gravel  pits.   Infiltration in the area
is  high and runoff  is  low.  Lack of  soil material makes
the area unsuitable  for  most uses.
300.68(e)(2)(i)
(A)
population at
risk
300.68(e)(2)(i)
(E)
climate
300.68(e)(2)(i)-
(D)
hydrogeological
factors
                                      12-4
-------
                                                        N
              1 INCH = 2100 FT

Figure 2.  Location of the H&M Drum Site,
           Dartmouth, Massachusetts
                     12-5
-------
     The Route  6 welL  lies  on  the  west bank  of  a swamp
adjacent to the  abandoned  sand  and  gravel pits.  The area
is level, and consists  of  deep,  very poorly drained soil.
The soil is  classified  as  Swansea muck  and  was formed in
highly decomposed  organic  material  underlain  by sand and
gravel.  The  soil  has a high  water  table at  or near the
surface  most  of the  year.   Permeability is  moderate or
moderately rapid in the organic material  and very rapid in
the substratum.  The  area  is  mainly woodland and the high
water makes it poorly suited for most other uses.

Hydrogeology

     No detailed  studies have been  published  on the  sub-
surface geology  in the area of the H & M  Disposal site and
the Route 6 well.  However, limited  geological  mapping was
performed during installation of the Route 6 well in 1962.
Figure 3 shows the geological cross  section  in  the  area of
the well.   Medium  to coarse  sand  with some coarse gravel
was encountered  at depths  of  about 17  to 35 feet (5-11 tn)
below  the  surface.   Such  sand  and  gravel deposits of the
outwash  plains  are typically  an excellent source of  large
supplies  of  water.    Pumping tests have shown that the
Route  6  well  can sustain a safe  yield  of  about  350  gallons
(1325  1) per  minute or 0.5 x  10  gallons  (1.9  x 10  L) per
day.   At a  depth of  35 feet  (10.7  m)  a  strata  of  uniform
fine  sand  was encountered and  refusal was encountered at
37 feet  (11.3 m).

     The natural ground water  flow in  the area follows the
general  topography, flowing in a north to northwest direc-
tion.    However, the  Route 6  well, during  its  operation
from  1976   through  April  1979,  created  a drawdown  which
caused ground water beneath the  site to flow south  towards
the well.   This has  been verified by  sampling  of  observa-
tion  wells  located 700 and 250 feet  (213  and  76  m)  from
the  well which  showed  movement of  the  contaminant  plume
from  the H & M Drum site  towards  the well.    The  ground
water  sampling  will be  discussed further  below.
300.68(e)(2)(i)-
(D)
hydrogeological
factors
 WASTE  DISPOSAL HISTORY

     On April 8,  1979, the Freetown,  Massachusetts police,
 acting on a  complaint,  encountered two  individuals at an
 old   sand  and  gravel pit in  Freetown.   The  individuals
 admitted to emptying the  contents of the drums taken from
 a truck marked H & M Drum Company Incorporated.  The truck
 registration  was  subsequently  traced to Harold Mathews,
 the  owner and  operator of H & M  Drum  Company.  The  EPA
 300.63(a)
 discovery  of
 release
                                      12-6
-------
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Figure  3.   Geological  Cross-Section and Details of the Route 6 Well

                     (Source:   Fay,  Spofford and Thorndike,  1962)
                                  12-7
-------
Regional  Office in Lexington (Regional) and the DEQE were
informed  of the  incident.  Mr. Mathews was  subsequently
questioned regarding his disposal practices.  He agreed to
accompany  DEQE  to  his  leased  warehouse off Route 6 in
Dartmouth.  Approximately  1000 drums were estimated to be
stored at the site.

     It was learned from limited drum  sampling which fol-
lowed, and  from an  investigation  of  Mathew1s  disposal
practices, that many of the drums contained still bottoms,
paint sludges and  other organic residues.   Specific com-
pounds which were  identified  from drums included toluene,
ethyl benzene,  trichloroethylene, methyl  ethyl ketone and
xylene.  In addition to drums in the warehouse, drums were
found  in a  trailer,  in  an  abandoned  gravel  pit  and  in
three smaller disposal areas in the rear of the warehouse.
Disposal  in  the abandoned gravel pit  raised  the greatest
concern  because the  pit  had been  excavated down  to the
level  of  ground  water  during  previous  gravel  mining
activities and  the drums were backfilled haphazardly along
with metal debris and tires, causing the drums to rust and
rupture.

     It was these investigations and inquiries that led to
the State  ordered  closure of  the Route 6 well on April 20
and  the  eventual  cleanup of   the  North  Dartmouth site.
However,  storage of  drums at  the  Route  6  warehouse was
known  to EPA prior to  April  1979 but  apparently was not
considered hazardous.   An investigation  of the warehouse
by  the Region  I EPA,  Hazardous Waste  Section  in July,
1978,  revealed   the  presence  of  300 to  400 drums.   New
England  Testing  Laboratory  conducted  air  sampling  for
volatile  organics  in  the  warehouse  in  early  October.
Sample analyses  were made using a gas chromatograph with  a
thermal  conductivity detector and a gas chromatograph with
a  flame  ionization detector.   None of the 4 samples  taken
revealed  concentrations  in excess of 50 ppm.  An odor was
reported  by  the testing laboratory but  was attributed to
the  former  use of  the  facility  as a  cheese warehouse.
Apparently no  further action was taken  at the site until
the April  1979  investigation.

     Ledge Incorporated was  the owner of the property off
Route  6,  which  was rented to  H & M Drum  Company  or Harold
Mathews.   Neither  Ledge, Incorporated,  nor  Cecil  Smith,
president  of Ledge had applied for  or received a  license
to  operate  a  hazardous  waste  storage  or disposal  site.
Mr. Mathews  and H & M  Drum  Company were  licensed  in 1978
to  transport  hazardous  waste  but  they  had  never been
licensed  to  store  or dispose  of hazardous  wastes in the
State.   Independent  of its  knowledge of  H & M1 s  illegal
disposal  operations,  the DEQE  had  revoked Harold  Mathews
300.64(a)(l)
preliminary
assessment

300.68(c)(2)(i)-
(B)
amount and form
of substance
present
                                      12-8
-------
license in March  1979,  for  noncorapliance  with administra-
tive  regulations  regarding State  hazardous  waste  trans-
port at ion report ing requirements.

     The  State  currently has a  lawsuit   against  the
property  owner  to  recover  the costs  of  cleaning  up  the
site.   The  Massachusetts  Attorney General's  Office  is
handling  this  case,   which  has  not  been   tried  as  of
September  1982.    In  April 1979,  the  state sued  Harold
Mathews,  the  d isposer,  for  violations   of  Massachusetts
criminal  statutes pertaining  to hazardous waste.   After a
trial  in  September 1979,  Mathews was  convicted of  four
counts of  illegal transportation and  storage of hazardous
waste.  He received an 18 month sentence,  served 12 months
and was re leased, and  declared  bankruptcy.   No  fines were
imposed and no money  recovered  to  reimburse  the state for
its clean-up costs.
DESCRIPTION OF CONTAMINATION

     On April 19,  1979,  approximately  one  week after site
d iscovery, DEQE  procured samples from  three  drums stored
in the  warehouse.   These samples were  analyzed  for vola-
tile organics by  EPA*s  Regional  Laboratory in Lexington,
Massachusetts.     Identified  chemicals  included  2-ethyl
hexanal,  toluene,  ethyl benzene, methyl  isobutyl ketone,
trlchloroethylene,  xylene  and  raethylene  chloride.    The
following day DEQE inspected the primary disposal pit area
and col lee ted waste samples.  Based on visual observations
of  contamination,  DEQE  gave a verbal  directive  to the
Dartmouth  Department of  Public  Works to  close down the
Route 6 municipal well.

     On  April 25, 1979,  DEQE and  Coastal  Service, from
East Boston, MA, the  sole source  contractor hired by the
State to respond to waste emergencies, conducted a limited
hydrogeologic  investigation.    Sha How  test  pits,  which
ranged  in depth  from less than  1  foot to  7  feet (0.3-2.
1m) , were excavated  us ing  a backhoe and  hand  shovels.   A
Century Organic Vapor  Analyzer  was used  to determine the
levels of volatile organics at various depths  in the pits.
Figure  4  shows  the  locations  of the  test pits  and the
levels  of volatile organics.    The  concentration of vola-
tile organics were generally found to be 500-1000 ppm at a
depth of 5 feet (1.5 m)  in the major disposal pit.

     In August 1980, nearly 16 months after closure of the
we 11, and 6 months  after the  Phase I cleanup  effort had
been  completed, DEQE  collected and  analyzed groundwater
samples  from  observation wells  located 700  feet  (213 m)
and  250  feet  (76 m)   from  the  Route  6  raunic ipal  we 11.
300.65(a)(2)
contamination of
drinking water
300.65(b)(5)
measuring and
sampling
300.68(f)
sampling and
monitoring
                                     12-9
-------
        4'(2)
                 5' (01
                            3'CO)
                                             7T(2)
                2'C1SO)    • 6'(800)
                5'C400)
                    GU L'(1000)1
                   5'(0)  •
  GW 0.5' (1000)




    • 5'  (5)


GW 3'  (I)
                                   | DISPOSAL AREA  2J

                                             05'(1000)
 •  Location of  sampling pts,

( ) Concentrations (ppra)
X*  Depth at which samples  were
    taken
                                NORTH
                                                       DISPOSAL
                                            I,DISPOSAL AREA- --4
                                             0'(  10)
                                                                 I
                                      O'(O)
                                      5'(Q)

                                       O'(5001
                                       1'CO)
                                         (0)
                                                                 TO  WELL
                                                                    i
Figure 4.   Results of  April  25,1979 Sampling  of Shallow Test Pits
                                  (Not  to Scale)
                                   12-10
-------
 Samples  were   analyzed  for  a  number of  volatile   organics.
 The   results  are   summarized  in  Table  1.   As  the  results
 indicate,  dichloroethane,  tetrachloroethylene   and   tri-
 chloroethylene  were  present  in   the   ppb   range  in   the
 observation well  located  700  feet  (210  ra)  from the  munici-
 pal  well  and  the concentration of  1,1,1  trichloroethane
 exceeded 1 ppm.   These  results  confirmed the  suspicion
 that   the  contaminants  had  migrated  towards  the well.
 Further  migration towards the well was likely to occur  if
 pumping  was  re-established  and  the  City  of   Dartmouth
 ordered  that  the  well remain  closed.

      Dartmouth  Departments of  Public  Health and  Public
 Works  have  decided to  keep the well  closed  until  further
 study  of the  extent of ground  water contamination can  be
 made.    In the  spring  of  1982,  the   Board  of  Selectmen
 designated $40,000 of  the town's  annual  budget  to fund  a
 detailed hydro logic  study of  the  site  to be  performed  by
 Fay,  Spofford  and Thorndike  engineers  from Boston, Mass.
 As of  November  1982,  the  study had not yet  started due  to
 difficulty in  obtaining easement.   The study  will  include
 installation  of  monitoring wells  to  determine  extent  of
 contamination,  aquifer  characteristics (such as  storage
 coefficients  and   flow  velocities),  extent of contaminant
 migration,  the effect  of  the  Route   6  well  pumping  on
 contaminant  transport,  and  an  evaluation  of   potential
 treatment  and  remedial  alternatives.   The  town has stated
 that  it  will  reopen the  well only if  the results of  the
 study  show that no public health  threat  would be  created
 by putting the  well on  line again.
300.68(e)(2)(ii)
extent of
raigrat ion of
substances
300.68(f)
sampling and
monitoring
SITE RESPONSE

Initiation of Response

     The site response  at  H &  M Drum was triggered by  the
April 1979  discovery  of  contaminated  ground water   and
soil  within  1400 feet  (427 m) of the  Route 6  municipal
well.  Due to the  nature of the  threat to the  municipal
well, immediate cleanup  was needed.   However, funding  was
not  available  until  September 13,  1979,  when  the State
made a  supplemental  appropriation to DEQE to  pay  for  the
cleanup.

Selection of Response Technologies

     Following site  discovery in the spring of 1979, DEQE
planned clean-up  measures for the site  based on the pre-
liminary site  investigation  conducted by DEQE and Coastal
300.65(a)(2)
contamination of
drinking water
300.65
immed iate
removal
                                     12-11
-------
            TABLE  1.  TEST RESULTS FOR ORGANIC CHEMICAL SOLVENTS

                         Intermediate  Monitoring  Wells
                   Route  #6 Well  -  Dartmouth,  Massachusetts
                           Conducted  July  28,  1980
Chemical
Compound
Methylene Chloride
Dichloroe thane
Trichloroethylene
Chloroform
Trichloroethane
Carbon Tetrachloride
Trichloroethylene
Dibromoe thane
Bromoform
Tetrachloroethylene
Total Organic Carbon
Test
Parts
250'*
N.D.
N.D.
N.D.
N.D.
3.5
N.D.
2.1
N.D.
N.D.
1.7
500
Results in
Per Billion
700'*
N.D.
66.5
0.9
N.D.
1250
N.D.
540
N.D.
N.D.
140
700
*Distance of Test Well from Town Well

N.D. = Not Detectable
                                     12-12
-------
Services.   DEQE's  proposed  site   clean-up  had   originally
consisted  of the  following measures:

     1.   Site preparation for  removal  and offsite  disposal
         of contaminated soil;

     2.   Excavation,  aeration, and  treatment of  slightly
         contaminated soils;

     3.   Transport and disposal of contaminated  wastes  and
         soils at an  approved  disposal facility;

     4.   Analysis,  segregation,   bulking,   crushing,   and
         disposal of  drums.

         Pumping   of  contaminated  ground water;  sampling;
         and installation of monitoring wells;  and

         Activated   carbon   treatment of  contaminated
         ground water.
     5.
     6.
                                      approximately $1.246
                                      cost of  cleaning  up
                                      for  requesting  $2.5
                                       However, as  stated
                                      for both  sites,  and
The estimated cost of these measures,
million,  combined  with  the estimated
the Freetown  site, was DEQE1s  basis
million  from  the  State  legislature.
earlier,  DEQE  received  only $500,000
approximately  $223,000  for the  Dartmouth  site  alone.
Thus, due to this  fund ing constraint from the legislature,
DEQE  was forced  to  reconsider   clean-up options.   With
about $223,000  to  address  the  contamination  problem,  DEQE
abandoned  its  original plan,  which  included  groundwater
decontamination  (activities  5  and  6)   and  targeted  the
majority  of  the   funds  to  reduc ing  the  source  of  con-
tamination  and  the  likelihood  of  further  ground  water
contamination.    Accordingly,  the  remedial  measures
selected  for the site were primarily drum removal and soil
excavation and removal (activities 1-4,  above).

Extent of Response

     Given the  constraint of limited funding,  DEQE sought
primarily to remove  the source of  contamination  and not
to  decontaminate the  ground water.  This goal appears to
have been achieved.  All drums  have been removed from the
site.    Approximately 370  tons  (336 Mt)  of heavily  con-
taminated  soil were  removed,  and slightly  contaminated
soil was  aerated  to lower  the  level  of  contamination  to
1-5  ppm.   Treatment  of  contaminated   ground  water  was
limited to application of  sorbents  to remove non miscible
contaminants.    The  extent of remaining  ground water  con-
tamination cannot be precisely described in the absence of
hydrogeological data  on  the  site.   The shutdown  of  the
                                                              300.66
                                                              evaluation and
                                                              determination of
                                                              appropriate
                                                              response
                                                              300.65(c)
                                                              completion  of
                                                              immediate
                                                              removal
                                     12-13
-------
municipal welL  in April of  1979  caused  Che town to lose a
major portion of its water  supply.   Replacement water has
since been purchased from the nearby  town of New Bedford,
but the town of Dartmouth would like to  resume use of the
municipal  well and  has  authorized a  $40,000  hydrogeo-
logical  assessment of the site in  order to determine the
feasibility of  future  remedial work to  decontaminate the
ground water.  DEQE does not plan further work, on the site
because of the competition for limited state funding posed
by more  immediate  public health  threats caused  by other
sites in the State.
300.65(b)(2)
providing alter-
nate water
supplies

300.68(k)
balancing
DESIGN AND EXECUTION OF SITE RESPONSE

     The response actions at the H & M Drum site were con-
ducted  in  two  phases.  Phase I  consisted mainly  of con-
struction  of  an  interceptor  trench along the  toe of the
main disposal pit,  use  of  sorbents  to remove non-miscible
organics  in ground  water,  excavation and  segregation of
debris , wastes  and contaminated  soils,   aeration  of
slightly  contaminated  soils  and segregation of  drums in
the warehouse with  removal of most of the  liquid wastes.
At  that  time  funds  ran out  and  the rest of  the drums had
to be stored in  the  warehouse  for  about  a year and  a half
until  additional funds  became  available.  Phase  II con-
sisted  of  the  removal  of  the  remaining drums  and con-
taminated  soils.
Phase I

Excavation of Disposal Areas
     The excavation operation was primarily  focused on  the
main disposal  pit where about 300 drums, metal debris  and
tires had been  backfilled.  The surface  area of  the dis-
posal pit measured approximately 160 feet by 90 feet (49 m
by 27 m)  and was about 15 feet (5 m) deep (See Figure  1).
In order to minimize  the impact of the cleanup  operation
on the ground water quality, an interceptor  trench was  dug
along the toe of the  disposal pit.  The  trench   measured
approximately  60 to  80 feet  (18-24 m)  long and  about 4
feet  (1.2  m)  deep.   It  extended between 0.5  to  2.5 feet
(0.2-0.8 m) into the ground water.  Several  time-s  through-
out  the  cleanup operation,  sorbent pi Hows  were  used to
remove a non-raiscible organic layer.  The objective was to
prevent  this  non-miscible layer  from  moving downgradient
and towards the well.

     Excavation of the disposal area was  a slow and selec-
tive process.  The drums had been haphazardly  disposed of
along with metal debris  and tires  and  the   soils  had been
300.65(b)(4)
controlling  the
source of
release
 300.65(b)(6)
 removing hazard-
 ous  substances
                                      12-14
-------
compacted.   Because  of these disposal  practices,  many of
the drums were badly damaged  or  void  of contents.   Equip-
ment  used  in the  excavation  included a backhoe,  a front
end  loader  and  a  bobcat.    Slings  and  other  attachments
were  used with the backhoe  for  lifting  drums.   Some drums
ruptured  during  the  excavation  operation  and  pumps  were
used  to  clean up  the  spilled  material.   The  front  end
loader was also used as a temporary receptacle for  leaking
drum  contents.   Approximately 300 drums along with debris
and  contaminated  soils  were  segregated  over  a   23  day
period.   The slow  rate of  progress was  attributed to the
haphazard disposal,  the  poor  condition  of  the  drums and
the cold weather.

      Because of the large quantities  of  contaminated soils
and  the  limited  funds available  for  disposal, a  decision
was  made to  segregate  heavily contaminated  and  slightly
contaminated soils.  Heavily  contaminated  soils were those
with  an  organic  vapor  concentration  in  excess of  500  ppm,
the   concentration  at  which  the  soils  were  considered
saturated.   These  soils,  along with empty, crushed drums,
were  stockpiled  in an  18  inch  (46   cm) high  bermed  area
with  a  polyethylene  liner  and diamtomaceous earth  used  to
absorb  seepage.    Approximately  320  tons  (290  Mt) of the
heavily  contaminated  soils were  stockpiled  and later
transported  to  CECOS's secure  landfill  in Niagara Falls,
New York towards the end of Phase I.

      Slightly  contaminated  soils,  defined  as  having  an
organic  vapor  concentration of 1-500  ppra, were  landspread
and  treated  on site by  aeration.   The  contaminated  soils
were  spread   across the   sandy,  native   soils  in 6  inch
(15  cm)  lifts and aerated  using  a  rototiller.  The  soils
were  aerated several  times over a two  week period  until
monitoring detected an  organic  vapor  concentration of  only
1-5  ppra.  Continued passes across  the   soil  allowed  semi-
liquid  ocganics  and solids  to be  pulled  up to the  surface.
This material  was  then   raked  up  and  stockpiled   with
heavily contaminated  soils  for  removal  to  CECOS.

      Air pollution  from the  landspreading operation  was
not   a  major concern.   There  were   no  residences in  the
 immediate area  and exposure of field  personnel was minimal
since the operation was performed  in December  and January
when cold temperatures  kept the vapor pressures  low.

      The piles  of metal debris and tires  which  were  exca-
vated from the  disposal pit  were not considered  hazardous
by DEQE and the town  of Dartmouth was  directed  to remove
them.   However, the  Department  of Pub Iic Works  felt  that
 these  materials   would  contaminate  the  local  municipal
 sanitary land fill.  Furthermore, the town did  not want  to
                                      12-15
-------
 spend public  money to  remove  the  solid  wastes from  the
 private   property  and  the  town  instructed  the property
 owner to remove  the  wastes.  To  date  no action has been
 taken.

 Drum Segregation
      Under  Phase  I, drums  in the warehouse and  the trailer
 were identified and   segregated, leaky drums were repacked
 and  most of the   liquid   wastes were  pumped into  vacuum
 trucks and  hauled  off  site for incineration.

      Many of the drums were  badly rusted and the source of
 the wastes   could  not  be  identified.   It  was  determined,
 however,  that most  of the  wastes  were  solvent recovery
 still bottoms, paint sludges  and other organic  residues.

      Testing criteria were developed which could segregate
 the wastes   for final disposal.  Based  on test procedures
 which included  viscosity,  water  solubility, specific
 gravity  and  pH, the drums  were segregated into  the follow-
 ing categories:

               17   Acids
              302   Water Insoluble Flammabies
              120   Water Soluble Flammabies
              121   Flaramables with Resins/Sludges
              358   Sludges, Organic Paint
              82   Chlorinated Fuels
              54   Oils - Soluble and Insoluble
              36  Miscellaneous

             1090 TOTAL

      Approximately  19,250  gallons  (72,860  1)  of  highly
 flammable liquids  were  pumped from  drums  and  transported
 to  Recycling Industries,   Inc., of  Braintree,   Mass.,  for
 incineration.  The miscellaneous drummed  wastes including
 16  drums  containing acids,  15 containing  gels  and 5  con-
 taining   ammonia   were also  transported  to  Recycling
 Industries.    1250 gallons  (4730  I)  of chlorinated  oils
were  pumped  and   transported to  Rollins Environmental
Services  in  New Jersey because Recycling's  incinerator did
not  have  the  capability  to  incinerate   chlorinated
solvents.

     Most of the  remaining  drums   contained  sludges  of
various  consistencies.  Sawdust  was mixed into  the drums
until  the   consistency  was  considered  suitable  for
acceptance by  a  landfill.    When Phase  I  was terminated,
738 solidified drums remained in the warehouse.
300.65(b)(6)
removing
hazardous
substances
                                     12-16
-------
 Demobilization
      Equipment used during  Phase I was  decontaminated  on
 site  using  hot  rinse  water which  was collected  for
 disposal.    The  disposal  areas  were  regraded  to  their
 original topographical contours.   There was no  follow  up
 monitoring done at the site.

 Phase II
      In September  1981,  approximately a  year  and  a  half
 after completion of Phase  I,  additional  funds  were appro-
 priated to  complete   the  cleanup of  the Dartmouth  site.
 The Phase  II effort was completed over a  6-week period and
 consisted  of removal  of  738  drums  and 50 tons (45  Mt)  of
 contaminated soils and debris.

      Most  of  the  Phase II effort was  devoted  to  further
 sampling and segregation of  the  drummed  wastes  to  prepare
 them for acceptance  in the  SCA  Chemical Services  secure
 landfill in  Model City,  New  York.    During  the  interim
 between Phase  I  and  Phase II, RCRA  regulations had  been
 promulgated  requiring  that  additional  sampling  and  record-
 ing be  undertaken  prior  to  transport  and disposal.    An
 initial random  sampling  of  5 percent of the  drums was
 undertaken  to  establish  waste disposal   codes  and  cate-
 gories.   Based on the results of the  random sampling,  the
 following  5  categories were assigned by Model City  to  the
 project  wastes.
   Disposal Category                               Type
   Chlorinated Organic Residues                    Drums
   General Organic Residues                        Drums
   Low Flash Organic Residues                      Drums
   Empty Crushed Drums and Contaminated Soils      Bulk
   Contaminated Sand, Soil and Sawdust             Bulk
     Flash point (using the closed cup tester) and organic
chlorine/sulfite testing were done on all samples.  Compo-
sites from 25 drums were prepared and shipped off-site for
PCB analysis.   The Model  City  secure landfill  could not
accept drums  of  residue having a  flashpoint  of  -Less than
70 F (21*C).   The  flashpoint  was  raised,  when necessary,
by adding  reclaimed  freon TMC, a  flashpoint  suppressant.
Liquid comprised only 2-5% of the  contents  of most of the
                                     12-17
-------
drums.   It  apparently  rose  to the  top as  the  absorbent
added during  Phase  I settled.   Additional  absorbent  was
added to solidify the drums.

     Ten loads of drums were labelled  and  shipped  in  box
trailers to Model  City.   Front  end  loaders were  used  to
load  dump  trailers  with  contaminated   soils,  sawdust  and
crushed drums.  Contaminated soils around the drum loading
dock were excavated and removed along with the bulk loads.

     Decontamination of the warehouse proceeded throughout
the  project.   Consolidated  floor sweepings  were  drummed
and  removed  under  the  appropriate  code.    The  warehouse
floor  and  the equipment  used  for cleanup  were  rinsed  at
completion of the project.
COST AND FUNDING

Source of Funding

     Upon  determining  that  ground  water  and  soil  were
contaminated,  the DEQE  requested  funding  from  the State
legislature  for  cleaning  up  both  the  Dartmouth  and
Freetown  sites  because  the  department  lacked  funds .
Private  funding was  unavailable and  the  state planned  to
bring criminal  actions against Harold Mathews.  Due to the
nature  of  the  threat  to the  municipal  well,   immediate
clean-up  was  needed.  DEQE  requested $2.5 million, which
would  have  funded  actions  at  both  sites  that   included
establishing  a  well  point  system, dewatering,  ground water
treatment,  treatment of  contaminated soils, drum  removal,
and  soil  excavation.

     On  September  13,  1979,  the  state   legislature made a     300.62U)
supplemental  appropriation for DEQE  to  pay  for cleaning  up     State  funded
both the  Dartmouth and   Freetown sites.   Although  the DEQE     response
had  requested  $2.5  million, the legislature  appropriated
only $500,000,  to be divided  between  the Dartmouth  and
Freetown  sites.  Dartmouth's allocation was $223,000.

     The  remedial action  was  conducted  in two phases  due
to a time  lapse  in  funding.  The first  phase of  clean  up
began  on November 11,  1979  and ended  February 19,  1980.
The  majority of  remedial work  conducted on the  site  was
undertaken during Phase  I.    However,  the  supplemental
 funding  provided  by the  legislature  ran out before  work
was  completed, so DEQE  had  to go back  to  the legislature
with a  request for   additional  funding.   It  took over a
 year to obtain this  second  appropriation, which  was  made
 in September 1981.  Over the course  of the next  year  and a
half,  DEQE and the  town  of Dartmouth  actively  sought  to


                                      12-18
-------
 persuade the  State  Legislature  to  allocate  funds  to
 complete the site  cleanup.   On August 27,  1981, DEQE  was
 notified  that  additional  funding  for  completion  of  the
 Dartmouth  site  had  been  secured  from  the  legislature.
 Phase II of the  project cost $105,234.

 Selection of Contractors

      Four separate contractors conducted  work on  the  H  & M
 site.   These  contractors,  in chronological order of work
 performed were:   Coastal Services  (initial site assess-
 ment),  Black Gold  Industries/Jetline (Phase I clean-up),
 A.D.  Little  Management  Consulting   (management  of   Phase
 II), and Recycling Industries (Phase  II  clean-up).

      Coastal Services  performed  the  initial site assess-
 ment in cooperation with DEQE  from  the  date of  site dis-
 covery on April 11,  1979  through June 30,  1979.   Coastal
 Services was selected by DEQE to perform  the  initial site
 assessment  because the  firm  was  under contract  with DEQE
 at the time.  The  contractual arrangement  was made accord-
 ing  to  the  State  Water Pollution Revolving  Fund,   which
 requires DEQE to designate a private  firm every  two  years
 as  the   sole  source  contractor  to  respond   to  waste
 emergenc ies.

      When Coastal  Service's  contract expired  on July   1,
 1979,  Black Gold Industries/Jetline  from  Stoughton,
 Massachusetts, was  hired as  the  State emergency response
 contractor   for  the  next  two  years.   When  funding  for
 clean-up was appropriated  by the  legislature on  September
 13,  1979,   Black  Gold  Industries/Jetline  was in the
 position to  respond  immediately  to  the  Dartmouth   and
 Freetown sites.     Subsequently,  DEQE  amended the  Black
 Go Id/Jet line  contract  to  include clean-up  responsibility
 for Dartmouth  and Freetown.   DEQE opted  for an  amendment
 to the  existing  State-wide  emergency  response  contract
 with  Black Gold/Jetline rather than  requesting  proposals
 in a  competitive bidding process  because of  the urgency of
 the  clean-up situation  and  the  fact  that securing  State
 funding  had  already taken six months.

      Black Gold subcontracted with Recycling Industries, a
 subsidiary of SCA, of Braintree, Massachusetts for assist-
 ance  in  the  work performed  on the site and for use of the
 latter's  incinerator  for  liquid  waste  disposal.   Black
Gold/Jetline also entered  into  an agreement  with  Chemical
and Environmental Conservation  Systems  (CECOS)  of Niagara
Falls, New  York  for  use  of  its  approved  secure  landfill
for waste disposal and with Rollins Environmental  Services
in  Logan  Township,   New  Jersey  for  incineration  of
chlorinated oils.
                                     12-19
-------
     Black  Gold/Jetline began cLean-up operations  on
November 11,  1979.   Work  continued  through February  19,
1980, when  funding was exhausted.  Funding  from the  State
legislature to  complete  the clean-up  was not  secured  by
DEQE until a year and a half later.   During  this time DEQE
was  in the  process of hiring a  management consulting firm
to  provide assistance  in managing  the  clean-up  of
hazardous waste sites throughout the  state.   This involved
a  time  consuming selection  process  based on  competitive
bidding.   Ultimately, on June  5, 1981, A.D. Little, Inc.
(ADL) Cambridge, MA,  was awarded the  management contract
with DEQE.  ADL's period of performance extended from June
6,  1981  through October  29,   1982,  with   a  ceiling  of
$467,108.   When  DEQE secured additional  legislative  fund-
ing  to  complete  the  H & M  clean-up, ADL  managed the con-
tractor selection process for Phase II of the clean-up.

     On August  14,  1981, Recycling  Industries,  Inc.,  was
selected  to  complete  the  H  &  M   clean-up.    Recycling
Industries  had  been  a  subcontractor  to Black Gold/Jetline
under the  first phase of clean-up.  Selection of Recycling
was  based  on a  competitive bidding  process.   Four  firms
submitted  bids  for  the  H & M clean-up; however, only two
firms,  Recycling and another firm, were  judged  by ADL to
have the technical capability to complete the work.  Black
Gold/Jetline, although  still  under contract with DEQE as
emergency   response  contractor   when  bid proposals  were
taken  for  phase  II, did  not   submit  a  bid because DEQE
believed that awarding another  contract to that  firm would
be  considered  favoritism.   The  choice of Recycling  rather
than the  other  firm was  based  on DEQE's evaluation that
Recycling  had superior technical capabilities and a better
contingency plan.  Estimated costs of work to be  performed
were not a  major factor of  selection because there was not
a  large variance between  bids   in  terms  of  total  costs.
Recycling's contract  with  DEQE was  based  on  time  and
materials  with  a ceiling  of $162,000.    Work  on the site
began  on  September  11,  1981, and  was  completed  under
budget  three  weeks later on October 9, 1981.

Pro j ect Co s t^

     Although the  remedial action conducted  at  the Dart-
mouth  site  was a  rather  straightforward  excavation  and
removal  operation, it  was,   in effect,  two  separate
operations due  to the  funding problem.

     The   summary  of cost  information shown  in  Table  2
reflects  the difference between  the  two  phases  as  far  as
can be  determined  from  available information.   The Phase I
expenditure was  in  one  lump   sum of  $148,000,  excluding
                                      12-20
-------
                      TABLE  2.    SUMMARY OF  COST  INFORMATION  FOR  H&M Drum  -  DARTMOUTH,  MASSACHUSETTS
NJ
 I
tsj
T.i*k
rh4.e i
Start-up 10 11 and

l)Upo»l

Transportation
480 ajllci
(771 kn)
Hhai* 1 tubtotal
Fhase II
Star I -up*- labor,
equipment.
n.ilcrlatilb)
ni.p.,.1

Trannportatlon
teif.JI.iubtatil...
TOTAL
Ouanlltt

o 120 ton* -bull
cruvhrd drum
•nd null
o 20,500 f,\
(77.600 1)
1 Iquled watte
fro* 1)0 druBi
Stmv •* above

17 load* or
(110 tons/ 190 Ht)




o 7)8 drum
sol] 4 cnntnmln.itc
debrlt
o 7]fl drmm
o JO tons (4) Ht)

















)l,3*6,oqn
(c)
Actual

*1 41,000

$ 2 ; , ooo
25,000
$51.000
$11,000
$111.000

$50.852

$17.859

$15.929
.HSi.tiS
$117.640


NA


($4.16/1)
$l,15)/1i..id or
($/9/Hl)
{SO.IO/Hl/Ki*)


HA

NA

NA




St.ite n(

State of

State of
H.isiarhuaet t*


Stair of

State of

St.ite of




11/11/79-
2/11/BO
11/11/79-

11/11/79-
1/19/RO
ll/79-l/BO

9/11/81-

9/1J/81-

10/9/Bl
a/ai.jnfgj
ll/H/79-
10/9/B1
                                                 HA : Not Applicable
                                         (•) Alto Include* drui* ie|re|atlon,
                                            •etJtton ind land*pte.idlng ol
                                            • Ultlitlr conca»Inat*d soil.
                                            Th* timt and ii.ilrrl.it Invoice*
                                            *ade the irparatIon nf the
                                            coat* of the conponrnti
                                            lupofglblc.
 (h) There mill cilut pflci of
    wct.il drbrli .ind tltc» en-
    cauntcd fro* the prln.iry
    dltpn*nl pit.

(c)  EKtlm.)te IncluJei cosU of
    ground ujtrr drcontamlnltlon.
-------
transportation and disposal of liquid waste from the ware-
house and  contaminated  soil from  the  disposal pit.   The
lump  sum  included:   start-up costs,  segregation  and
repacking  of drums  in  the  warehouse,   pumping  out  the
flammable  liquids, soil  and drum excavation from the dis-
posal pit  and land spreading of  the  slightly contaminated
soil.    Another  $75,000  was  spent  on  the disposal  and
transportation  of  the   materials.    Liquid  wastes  were
incinerated  at  Recycling Industries and  Rollins Environ-
mental  Services  at an  average cost of $1.22  per  gallon
($4.62/1)  and  the bulk waste was  transported  to CECOS at
$72/ton  ($79/Mt).   The  Phase  I operation  was terminated
for lack of  funding after 320 tons (290 Mt) and 20,500 gal
(77,600  1) of  liquid wastes were removed.  There remained
783  drums, mostly   containing solid wastes,  and  50 tons
(45 Mt)  of excavated contaminated  soil.

     From  the  standpoint of  cost,  Phase  II was conducted
more cautiously than Phase  I.  Phase II employed a written
request  for  bids,  an evaluation of bids and a  system that
tracked  the  progress of  the  remedial action.  The Phase II
effort  was  completed  at  a  cost  of  $104,640  which was
$57,360  lower than expected.

     The costs  incurred during  Phase  II  included $15,929
for  transportation and  $37,859  for  disposal of drums and
contaminated soils at  the  SCA  secure landfill  in Model
City, New York.

     Another aspect  of  the cost of the response action  is
the  alternative  supply  of water  which the town of  Dart-
mouth  had to obtain when its municipal  well  was  closed.
Before  its  shutdown, the  well  supplied 15% of  the  town's
water  and had the potential  for serving  up to 65%  of  the
population.   To  replace the lost water,  the  town had  to
increase its share of water purchased  from the nearby town
of New  Bedford.   Total cost  of  the  water  from 1979  to
March  1982  was  $98,262.  Operation costs  saved from  the
well  shutdown  were  $27,812,  producing   a  net  cost  of
$70,450 to the town.  Since the well  probably will  remain
closed   for  some  time,   the  net  cost of  alternative  water
 supplies will increase  at this rate.
 PERFORMANCE EVALUATION

      The effectiveness of  the  overall  response activities
 at the H  & M Drum site must be  evaluated  in terms of the
 constraints of limited funding.  While originally the goal
 planned by DEQE  was  for  both removal  of  the  source  of
 pollution  and  decontamination  of ground  water,  lack  of
 adequate  funding  forced  DEQE  to  redefine   its  cleanup
                                      12-22
-------
goals.   DEQE  eventually sought only to  reduce  the  source
of contamination  to  the extent possible with  the  limited
funding.  The  emergency cleanup  activities  appear  to have
been  successful   insofar  as   the  drums  and  the  bulk  of
contaminated  soils  were  removed  from  the  site,  an
alternate source  of water  supply was  made  available  to
residents formerly  supplied  by  the  Route 6 well and the
immediate public health threat was eliminated.

     However, due to insufficient funds, there has  been no
follow-up monitoring to determine the effectiveness  of the
cleanup  or   the   extent  of  ground  water  contamination.
Efforts taken to date have not been effective in restoring
the high yield municipal  well.  This has  forced the town
of Dartmouth  to  incur   expenses  in  excess of  $70,000 for
buying  replacement  water since  the  well closed in  April
1979.

     The possibility of future remedial work on the  ground
water  is  speculative   from   both  a  cost  and  technical
perspective.   Dartmouth's  position  is  that  a detailed
hydrogeological  assessment   is  needed before they can
assess  the  cost   and  feasibility of  restoring  the  well.
The town has  funded  this  assessment  which  was expected to
begin late in 1982.
                                     12-23
-------
                                  REFERENCES


Al-Momen, M.,  Arthur D.  Little Program Systems Management Company,  Cambridge,
     MA..  October 13, 1981, and October 20,  1981.   Written Communication to
     William Simmons, DEQE.

Anderson, P. T.  DEQE, Lakeville, MA.   April 27,  1979.   Written Communication
     to M. Branco, Dartmouth Department of Public  Works, April 27,  1979.

Branco, Manuel, Department of Public Works.   March 28,  1980.   Written
     Communication to Lawrence Cameron, Board of  Selectmen, South Dartmouth,
     MA.

Branco, Manuel, Department of Public Works.   October 15, 1980.  Written
     Communication to H. Kaltenthaler, MA Legislative Commission on Water
     Supply.

Commonwealth of Massachusetts.  1980.   "Commonwealth of Massachusetts vs.
     Ledge Inc., Cecil Smith, H&M Drum Co. and Harold Mathews."  Superior
     Court, Department of the Trial Court Civil Action.

Carson, D., Recycling Industries, Inc., Braintree, MA.   September 13, 1981,
     September 25, 1981, September 29, 1981, October 7, 1981, October 14,
     1981.  "Memoranda to Project File."

Connelly, J.  DEQE, Lakesville, MA.  July 28, 1980.  "Report of Analytical
     Results from Observation Wells."

Correia, J.  DEQE.  May 14, 1979.  Memorandum to J. Gould.

Correia, J.  DEQE, November 6, 1979 - April 15, 1980.  Memorandum to W.
     Marhoffer, DEQE.

Correia, J., DEQE, Stoughton, MA.  Personal Communication, November 3,  1982.

Davey,  John, Jetline, Stoughton, MA.  Personal Communication, May 20 and
     November 2,  1982.

Fay, Spofford and Thorndike, Inc.  1962.  "Pump Test of Gravel - Wall Well  at
     Route  6 Site."

Fay, Spofford and Thorndike, Inc.  Boston, MA.  October 22,  1981.  Written
     Communication to Manuel Branco, Dartmouth Department of Public Works.
                                     12-24
-------
Gidley, Philip T., Gidley Laboratories, Inc., Fairhaven, MA.  May 21, 1979.
     Written Communication to Manuel Branco, Dartmouth Department of Public
     Works.

Gidley, Philip T., Gidley Laboratories, Inc., Fairhaven, MA.  July 30, 1979.
     Written Communication to Charles D. W. Thornton, Office of Environmental
     Affairs, Boston, MA.

Gilbert, Edgar A., Arthur D. Little Program Systems Management Company,
     Cambridge, MA.  October 6, 1981.  Written Communication to William
     Simmons, DEQE.

Mansfield, Clifford S.,  Fay, Spofford & Thorndike, Inc., Engineers, Boston
     MA.  October 22, 1981.  Written Communication to M. Branco, Dartmouth
     Department of Public Works.

Mansfield, Clifford S., Fay, Spofford & Thorndike Inc., Boston, MA.  Personal
     Communication, October 18, 1982.

McMahon, Thomas C., Water Resources Commission, Boston, MA.  March 18, 1980.
     Written Communication to Dartmouth Board of Selectmen, South Dartmouth
     MA.

McMahon, Thomas C., Water Resources Commission, Boston, MA.  April 30, 1979.
     Written Communication to Thomas McLoughlin, Acting Commissioner.

O'Brien, L.  New England Analytical Testing Laboratory, Natick, MA.  October
     2, 1978.  "Report of Analysis" to Attorney John Hountin.   Boston, MA.

O'Brien, John J.   DEQE, Boston, MA.  August 17, 1981.   Memorandum to William
     Simmons, DEQE.

Purington,  J.H.,  Recycling Industries,  Inc.,  Braintree, MA.  November 30,
     1981.   Written Communication to W.  Simmons, DEQE,  Boston,  MA.

Soil Conservation Service.   1979.   "Soil Survey of Bristol  County
     Massachusetts,  Southern Part."  United States Department  of Agriculture,
     and Massachusetts Agricultural Experiment  Station.
                                     12-25
-------
-------
                           HOUSTON  CHEMICAL  COMPANY

                                HOUSTON,  MISSOURI
 INTRODUCTION

      The  Houston Chemical  Company plant  is  located in  a
 rural area  in  southern Missouri.    On  June  14,  1979,  a
 storage  tank  at the  site  collapsed and  spilled  15,000
 gallons  (56,800  1)  of  diesel  oil  containing  5%  penta-
 chlorophenol  (PGP)  down a  hillside  and  into a farm  pond,
 kill ing aquat ic  1 if e  in the pond.  The pond  threatened  to
 overflow   into  a  tributary  of  the  Big  Piney  River,   a
 valuable  wildlife  and  aquatic  life  habitat.    When  it
 became apparent  that the plant  owner  was not  taking  action
 to   remove  the oil, the  caretaker  of the   pond   property
 informed the Missouri  Department  of Conservation  about  the
 spill.  After  inspecting the site and noting a total  fish
 kill  in  the pond, the Department of  Conservation  informed
 the U.S. Environmental Protection  Agency Region VII  office
 (EPA) in Kansas  City,  Kansas  of the spill.

 ISackground

      The  Houston Chemical  Company  plant  (also  known  as
 Cairo Wood  Treatment)   is   located  in  Texas  County,
 Missouri,  about   three miles  south of  the  small  town  of
 Houston,  in a lightly populated  area of farms and  woods.
 At  the  time of the spill  in  June 1979, the  plant was  in
 the business  of  mixing 95% diesel oil  and 5% PGP for use
 as a  wood  preservative.  PCP  is considered toxic  to  humans
 and animal  life.

      On June  14, 1979 a 21,000  gallon  (79,500  1)   steel
 storage tank  at  the  plant  buckled,   sheared  off  a valve,
 and  spilled approximately  15,000 gallons  (56,800  1)   of
oil/PCP mixture.  There was not a dike around the  tank for
 spill containment.    The oil/PCP  mixture   flowed approx-
 imately  300  yards   (274  m)   down a hillside,   along   a
roadside drainage ditch, through culverts under two roads,
and after  pooling in  a dry depression,  flowed underground
for 100  feet (30  m) into a  0.7 acre  (2,835 m2) farm pond.
The oil/PCP covered the  pond surface in a  layer  1/4 inch
to  1 inch (0.64  to  2.54 cm) thick (see Figure 1).
NCP Reference
300.63(a)(4)
discovery
                                     13-1
-------
                                   Hwy. 63
                                                 . —
                                            A  |  Chemical  Plant
                                                  '
        Subsurface Flow
                79-7020
                                                          Church Well

                                                   truck tank traier
   Storage Tanks

Ruptured Tank

      F!ow °* ^il
                                   Haney  Trailer Park Well
Figure  1.   Houston Chemical  Co.  Spill Site  and Sampling  Locations
                                13-2
-------
      An   intermittent   stream  linked  the  pond  with  Hog
 Creek,  a  tributary  of the  Big  Piney River,  which  flows
 into  the  Gasconade River  and then  into the  Missouri  River.
 Hog  Creek at the intermittent stream and the  Big  Piney at
 the   mouth  of  Hog  Creek   are  officially  designated  by
 Missouri  for protection of  livestock, wildlife, and  aqua-
 tic  life.   In addition,  the  Big  Piney is  a  navigable  water
 of  the  United  States.   At the time  of the  spill,  the pond
 surface was a few inches below  its  spillway,  and the  oil
 did  not travel  beyond  the pond.

 Synopsis  of Site  Response

      On June 19,  1979  the EPA on-scene coordinator  (OSC),
 acting  under   section  311(k)  of  the  Clean  Water  Act,
 engaged  0,H. Materials Co.  (OHM),   of  Findlay,  Ohio  to
 undertake  an emergency cleanup of the pond  and  pill  path.
 Over  the  next  six weeks, OHM removed approximately  10,000
 gallons (37,900  1) of  oil/PCP  from the pond and  spill path
 using skimmers  and  a  vacuum  pump;  drained the pond  and
 filtered  the water with  a  mobile carbon filtration  unit;
 flushed  the spill path surface  with water; and  excavated
 contaminated soil from the  spill path, pond banks,  and
 pond  bottom.  O.K. Materials  returned  the  recovered  oil/
 PCP  to a  secure  tank in the  Houston  Chemical Co.  plant  and
 transported 2,636 cubic yards (2,015 m )  of  contaminated
 soil  to  a  licensed  hazardous  waste landfill  in  Wright
 City, Missouri.

      During the  final  two weeks  of the cleanup,  OHM  intro-
 duced  nutrients  and  freeze-dried cultured bacteria  into
 the  refilled pond in  an attempt  to biologically degrade
 the  remaining PCP.   O.H.  Materials ended work at  the  site
 on August  6, 1979, at  which  time  sample  analysis indicated
 that  the  PCP level  in  the pond was below the  target  level
 of 10 ug/1.

      Over  the next two months, PCP levels in the pond  rose
 to 200 ug/1 as  small  amounts of  oil/PCP continued to  seep
 from  underground  into  the  pond.    In  October 1979, the  OSC
 purchased  nutrients  and  freeze-dried cultured  bacteria,
 introduced  them  into   the   pond,  and aerated  the   pond.
 Final  sampling  of  the pond in  November 1979,  after  all
 cleanup activity  ceased,  indicated approximately 400 ug/1
 of PCP.  In  December 1979, eight barrels of  absorbent pads
were removed from the  site and  taken to  a  landfill.  This
was  the  last work  done  at  the  site.   According  to  the
Missouri  Department  of Conservation,  in the  three  years
 since the  spill  the pond  has returned to a healthy condi-
 tion,  based  on  visual  inspection.    Aquatic  life   has
 returned and effects of the  spill  are not apparent.
                                     13-3
-------
     Litigation  is  ongoing  against
Chemical  Co.  to  recover  federal
cleanup.
the owners  of
 funds  spent
Houston
in  the
SITE DESCRIPTION

     The  Houston  PCP  oil  spill  site  is  located  near  a
saddle  at  S  1/2,  NW  1/4,  Section 30, Township  30 north,
Range  9 west,  south  of  the  town  of Houston,  Missouri.
Figure  2  shows  the  spill site's  location on  a  portion of
the  Houston  topographic quadrangle.   Numerous  dwe 11 ings
exist  near  the site, the  closest being a church approx-
imately 250 ft. (76 ra)  north of  the  site,  and a  trailer
park approximately 900 ft. (274 ra) southwest of site.

     The  plant  site  itself  consists  of  a mixing  plant
building  with  attached  block penta vat,  two  cylindrical
storage tanks  for  the PCP/oi  1 mixture, a holding  pond to
contain spills  from the plant, a  truck  tank  trailer, and
an area for solid, block penta storage.

Surf ace Cjiatract eristics

     The   local climate  of the area,  as well as the State
of  Missouri, is  classified  as  continental.  Large sea-
sonal and daily temperature fluctuations are not uncommon.
The  average   annual   temperature  at the  site  is  approx-
imately 59°F  (15°C).    Daily  maximum   and  minimum temper-
atures  during  July  are  90*F  (32°C)   and 68°F  (20°O,
respectively; while  during January the  daily  maximum and
ininLmum  temperatures  are  45°F  (7°C)   and 24°F  C-4°C) ,
respectively.   Temperature  extremes recorded  in the  state
are 115°F (46°C> and -22°F (-30°C).

     Average annual   precipitation for the  spill  site  is
42  inches  (107  cm), with  approximately  42  percent of the
precipitation  occurring during the  period  of  May to
August, inclusive.   The period of highest  rainfall occurs
from  March  to  June  and  the period   of  lowest   rainfall
occurs  from  November  to  February.   Mean  annual  snowfalL
for the area  is approximately 14  inches  (36 cm),  with the
average annual  number of days with snow cover being  about
35 days.

     Annual  prevailing winds  are  from the  south  at  about
10  mph (16  kra/hr) .   Prevailing  wind  direction and  speed
throughout the  year does not  vary significantly  from the
annual  values.  Wind  speeds as high as 66  mph  (106  km/hr)
have  been  recorded  nearby and  these  were   associated  with
winds  from the  west.
                          300.68(e)(2)(i)
                          (A)
                          population at
                          risk
                          300.68(e)(2)(i)
                          (E)
                          climate
                                      13-4
-------
Figure 2.  Location of Houston Chemical Co. Site
                         13-5
-------
     Soils  in  the  area surrounding the  site  are  classi-
fied  as  ClarksvilLe Gravelly  Loams.   These  soils   were
formed  from the weathering of cherty to moderately cherty
limestones.   In  character, these  soils  vary from gravelly
to moderately gravelly soils, gray to brown  in  color,  and
from friable red clay through gravelly and stoney clays to
hardpan subsoils.  The content of  chert  gravel  varies form
almost zero  to seventy-five percent,  and usually increases
with depth.   Perraeabilites vary from high  to low depending
upon  the  stone  content  of  the  soil.    These  soils  are
naturally low in nitrogen and phosphorus.   Vegetation sup-
ported by the soils locally are pasture  land and forests.

     Drainage  from  the  plant  site  is  westward  towards  a
spring  fed   farm pond  (Figure 1).   Discharge from  the
0.7-acre (2835  ra2)  farm  pond extension eaters  an  unnamed
intermittent  tributary   to  Hog Creek.    Hog Creek  flows
northwest to  Big Piney  River.  Average annual  runoff for
the spill area  is approximately 14 inches  (36 cm).

     The use of  surface  water  in  the  area is varied.  The
farm  pond  is  stocked with numerous  species of  game fish
(e.g. , bass) .   Local streams are  known for  their  recrea-
tional use  including  fishing,  boating,  and swimming.
Stream  water  is also  utilized  for  watering  livestock.
WiIdlife are  also dependent  on local streams  as watering
sources.

Hyd rogeology

     The  Houston  spiII   site  is located   in  the  Salem
Plateau sub-province  of  the Ozarks physiography province.
Physiographically,  the Ozarks  are an  enlongated dome that
extends  across  Missouri  from  the  Mississippi River  to
northeastern   Oklahoma  and  northern  Arkansas.    The
surficial  geology  is  largely Cambrian and  Ordovician
Rocks,  although  some later  Paleozoic  age rock  remain.
Drainage  patterns are more or  less  radial.   Streams have
destroyed much  of the Salem Plateau  and developed  valleys
many  hundreds of  feet deep.
     The  geology  of  the  spill
 rocks  from the Canadian  Series
 The  major  formations  present
                                 site  consists  mainly  of
                                of the  Ordovician  System.
                                 are  the  Jefferson City
Formation and  the  Roubidoux Formation.   A thin layer  of
Pennsylvania Sandstone  is  also  present as  a  cap  rock  at
the site (i.e.,  as  described  by the State  Geologist) .   A
brief description  of the major  formations are  presented
below (Howe, 1961):

          Jefferson  City  format ion.   -  The
          Jefferson  City  formation is  composed
                                                             300.68(e)(2)(i)
                                                             (D)
                                                             hydrogeologic
                                                             factors
                                      13-6
-------
          principally of  light  brown  to  brown,
          medium to  finely  crystalline dolomite
          and argillaceous dolomite.  Tbe thick-
          ness of the Jefferson City ranges from
          125  to  350  feet  (38  to  107 m);  its
          average thickness is 200 feet (61 m).

          Roubidoux  formation.  - The  Roubidoux
          formation  consists   of  sandstone,
          do lornit ic   sandstone,   and   cherty
          dolomite.   The    thickness  of  the
          Roubidoux  ranges  from  100 to 250 feet
          (20  to   76  m) .     The  formation's
          greatest  thickness  is  at the  south-
          western part  of  the  Ozarks, and  its
          least  thickness   is  along the  north-
          eastern part of the area.

          Gasconade  formation.  - The  Gasconade
          is  predominantly a light  brownish-
          gray, cherty dolomite.   The  formation
          contains  a persistent   sandstone  unit
          in   its    lowermost   part  that   is
          designated the Gunter member.   In the
          central  Ozark  region,  the average
          thickness  of the Gasconade is 300 feet
          (92  m).    Data  from  wells  in  south-
          eastern Missouri  indicate   a  maximum
          thickness  of 700  feet  (214 m)  for the
          Gasconade in that  area.

     The Ozark  area of Missouri  is the  most  extensively
developed,  fresh ground water supply source  in  the  state.
The  ground  water  reservoir  in  this  area  consists of  a
section of more  than 2,000 feet  (610  m)  of  Cambrian  and
Ordovician dolomite  and sandstone, overlain in the eastern
sections by Mississippian  limestone.  Because of the wide-
spread development  of the  Ozarks  and  the great  depth  of
weathering that  has occurred, pollutants  can migrate  to
considerable  depth.    In order  to  safeguard  water supplies
from  pollutants,  wells  are  locally  cased  to  a  dense
stratum below the  surface  and   cemented.    Considerable
casing depth  is  sometimes  required  because  the  depth  of
weathering  is great.  For example,  at  West  Plains,  Howell
County (next  County, south of site), 1,000 feet  (305 m)  of
casing is  set, at Springfield  250 to 400  feet (76 -  122  m)
is  set, and  Rolla  about  400  feet  (122  ra)  of   casing  is
required.

     The five  principal fresh-water  aquifers in  the  Ozarks
that are likely to  yield dependable  ground  water supplies
are the Laraotte Sandstone, Potosi Dolomite,  Gunter  Member

                                     13-7
-------
of the Gasonade Dolomite, Roubidoux Formation, and the St.
Peter Sandstone.   The  aquifers present at  the  spill site
area  are  the  Jefferson  City Formation,  Roubidoux Forma-
tion,  and  the Gasconade  Formation  of  greater  depths.
Specific  capacities of  wells  in  this  area range  from
approximately 2 to 10 gallons per minute per  foot at down-
drawn (25 to 125 liter per minute per meter of drawdown).

     Ground water  usage  in the  area  surround ing  the spi 11
site  is high because of  the  remoteness  of the Location  to
pub lie  supplies.   Approx imately  30  wells  are  Located   in
the  vicinity  of   the  spill  site  and  these are  either
utilized  for  domestic supplies or  livestock water.    Of
most  concern  were  three we L Ls  located in  the  iramed iate
vicinity  of  the spill site; one  on  the plant  site,  one
northeast of  the  site  at  a  church,  and  one  southwest   of
the site used  as a  water supply source  for  a trailer park
(refer to Figure 1 for Locations).  Most wells are drilled
to depths of 200 to 250  feet (61  to  76  m).   However, some
of these wells  are  cased only  in  the upper  40 feet (12  m)
which could  make  them susceptible  to  contaminants.   The
aquifer utiL ized by  these  wells is probabLy the Roubidoux
Formation (based on State Geologist description).

     Numerous  springs  occur  in the  area  surrounding  the
spill site.   Of most  importance  are  the  springs that fed
the   farm   pond  located  west   of   the   site  (refer  to
Figure  1).   These  springs are  located below the surface
water  level  of the  pond.   Ground  water  discharged   by
springs  in  the area appears to originate  at  or  slightly
below the Jefferson City - Roubidoux Formation contact.
WASTE DISPOSAL HISTORY

     The case  study differs  from  other  studies  presented
in  this  document  in  that  the  response  actions  performed
were  in  response  to an emergency  spill  situation,  rather
than  a  waste  disposal  problem.    Therefore,  a detailed
waste disposal history at the site is not warranted.

     The  Houston  Chemical  Company  mixes   solid   penta-     300.68(c)(2)(i)(B)
chlorophenol  with  oil  for  use  as a wood  preservative.     amount  and form of
Solid  PCP  is stored  at the  site in containers.   Mixing     substance  present
operations  occur  in  the  plant  and  the  5%  pentachloro-
phenol/oi1 mixture  (PCP/oiI)  is  normally stored  in  one of
two  storage  tanks  located  behind  the  plant.   These  two
cylindrical  storage  tanks can  hold  a  total   of  36,000
gallons  (136,300  1) of  PCP/oil;  i.e.,  15,000  and  21,000
gallons  (56,800 - 79,500 1).
                                      13-8
-------
      PCP  has been  used  as a  wood  preservative since  the
 1940's  when  it  was introduced  as  an  alternative  to  the
 more  commonly used  creosote.    Other  applications  of  PCP
 are  as  fungicides,  biocides  and herbicides.   During  the
 production  of  PCP  numerous  toxic  impurities  can be
 introduced  which are more toxic than the PCP itself.   For
 example,  the  elevated  temperatures  required  during  the
 latter  stages  of  chlorination favors  the  formation of
 polychlorinated  dibenzo-p-dioxins  (PCDD)  and  polychlor-
 inated  dibenzofurans  (PCDF).     A  chemical  analysis of
 different grades of  pentachlorophenol is given  in Table 1.
 Analyses  performed on various  brands and  samples  of  PCP
 showed  that  the   hexachlorodioxin   and  octachlorodioxin
 concentrations  can  vary greatly;  i.e.,  hexachlorodioxin
 <2  ppm  to   21  ppm,   octachlorodioxin <1 ppm to 3600  ppra.
 These  contaminants  in  PCP are  considerably  more   toxic
 than  the  PCP itself.  The toxicity  of PCP to  terrestrial
 mammals  and  aquatic  biota   is  shown   in  Table  2.   The
 effect of  PCP on  humans is  not well documented,  but  the
 reported oral lowest lethal dose is 29 mg/kg, and the  oral
 lowest toxic dose  is 196 mg/kg  (i.e., affected  the  central
 nervous  system).    Toxicologists   point  out   that   these
 results may  not  be  fully  attributable  to the  PCP  but in
 part to its contaminants (i.e., dioxins).
300.65(a)(l)
exposure to
acutely toxic
substances
DESCRIPTION OF CONTAMINATION

     On  the  night  of  14  June  1979,  an above ground,
21,000 gallon  (79,500 1), steel, horizontal  storage tank
collapsed,  shearing-off  the   drain  control  valve  and
piping.  This  action allowed the contents  of  the tank to
spill  onto  the   ground.     An  estimated   15,000  gallons
(56,800  1)  and  a  5%  solution  of PCP  in  diesel  oil  was
released.   The  probable reasons  for  the tank  failure  as
described by  a Technical Assistance  Team  member  on site
are:
300.64(a)(2)
source and nature
of release
     •  Saddle support blocks were not  sufficient  to sup-
        port the weight of the tank and its contents; both
        in spacing and number

     •  Tank  was  weakened  by  heavy  corrosion  and  past
        abuse

     •  Saddle support blocks were  not engineered  to  fit
        the  curvature  of  the  tank

     •  Drain  pipe  and  valve  should  not  have  been
        installed  at the underside of  the  tank where they
        are   subject  to damage   in  the  event  of  a  tank
        collapse.
                                     13-9
-------
              TABLE 1.  CHEMICAL ANALYSIS OF PENTACHLOROPHENOL
                        (Excerpted from Jones, 1981)

Compound
Pen tachloro phenol
Tetrachloro phenol
ttexachlorodibenzo-p-dioxin
Heptachlororadibenzo-£-dioxin
Actachlorod ibenzo-p_-dioxin
Tetrachlorodibenzofuran
Pentachlorodibenzofuran
Hexachlorodibenzofuran
Heptachlorod ibenzofuran
Actachlorodibenzofuran

Technical
84.6%
3%
8 ppm
520 ppm
1,380 ppm
<4 ppm
40 ppm
90 ppm
400 ppm
260 ppm
Concentration
Commercial3
88.4%
4.4%
<0.1%
<6.2%
2,500 ppm
125 ppm
4 ppm
80 ppm
80 ppm
30 ppm

Improved
89.8%
10.1%
<0.1%
-
15.0 ppm
6.5 ppm
1.0 ppm
<1 ppm
1 . 8 ppm
<1 ppm
a Dowicide 7

 Dowicide EC-7
                                      13-10
-------
TABLE 2.  TOXICITY OF PENTACHLOROPHENOL REPORTED IN THE LITERATURE

Species
Rat
Mice
Rabbit
Guinea pig
Dog
Sheep
CaLf
BluegUl
Goldfish
Catfish (fingerling)
Fathead minnow
Crayfish
Sheepshead minnow
Rainbow trout
Shrimp
Reported Toxicity Range
LD50
(mg/kg-bw)
27-330
120-140

100
150-200
120
140








LD
(mg/kg-bw)


40-350












LC5Q
(ppm)







0.02- 0.05
0.05- 0.27
0.12- 0.14
0.06- 8.00
9.00-53.00
0.22- 0.44
0.13
3.3
                              13-11
-------
     The  spilled PCP/oil mixture was  not adequately con-
tained  on the  Houston Chemical Company  property because
suitable  dikes   had  not  been  constructed  around  the
storage  tanks.  Approximately  5% of PCP/oil  mixture was
contained on-site in an overflow pit adjacent to the plant
(Figure  1).    The  remaining  95% of  the PCP/oil  mixture
bypassed  the  overflow pit  and  flowed  in  a  southwesterly
direction for 75 yards (69 m)  into  a roadside  ditch.  The
PCP/oil  flowed  in a  southerly direction in  this ditch for
approximately  125 yards  (114 ra)  to a  road  culvert  under
old  U.S.  Highway 63  (i.e.,  service  road).    The  PCP/oil
continued flowing  in a  westerly  direction overland  to  a
culvert  located under  new  U.S.  Highway 63.    From this
point the PCP/oil flowed  into a manmade catch  basin where
it  was  temporarily  detained.    Eventually   the  mixture
infiItrated  through  the  basin1s   bottom  and  reappeared
approximately 125 feet (58 m) below the basin.   From there
the  PCP/oil  flowed  into a  0.7-acre (2835 m )  farm pond.
The  farm pond  acted  as  a retention  structure to  prevent
further  spreading of the PCP/oil.

     A  spill  report  was  not  received by EPA until 18 June
1979,  four  days after  the  spill  occurred.    The  initial
report  by plant personnel  was  that  approximately  10,000
gallons  (37,900  1) of PGP and P-9 oil mixture  had  spilled,
and  that  it  was contained in a  dike and being removed by
vacuum  truck.   Emergency spill  response  actions were not
initiated  at  the  time  because   EPA  was  assured that
problems  did not exist  in  the cleanup  effort  and that
local waterways were not threatened by  the PCP/oil.

     A  subsequent visit  to  the site  on 18 June 1979 by  a
Conservation  Officer with the Missouri Department of Con-
servation  revealed  that  approximately 95% of the spilled
material had  escaped and now covered a 0.7-acre farm pond
(1835  m2);  approximately  1.5 x  10  gallons   (5.7  x 10
liters);  with a 1-inch  (2.5 era)  layer of  PCP/oil.  The
Conservation  Officer  also  reported  that a total fish kill
had  occurred  at  the  pond which included more  than 82 game
fish (e.g., bass, catfish).

     Although  the PGP/oil  was temporarily detained  in the
farm  pond,  the  situation  was deemed serious  because near
overflow conditions  existed in  the pond.    If  rainfall
occurred, PCP/oil  would likely  have been discharged over
the  spillway  into a  tributary to Hog Creek.

     Samples  of  soil, water, and oil and water were taken
to   aid in   characterizing   the  site.   Figure  I shows the
location of  these   samples  and  Table  3  gives the results
of  the  EPA  laboratory  analysis.  The concentrations  of PGP
in  the  drainageways  above  the  farm pond's spillway were
300.64(a)(l)
evaluation of
magnitude of
hazard
 300.65(a)(l)
 exposure  to
 acutely toxic
 substances
 300.65(a)(5)
 measuring and
 sampling
                                      13-12
-------
          TABLE 3.  PENTACHLOROPHENOL SAMPLE ANALYSIS,  19 JUNE  1979
Sample Identification
Number
EG 0301
EG 0304
79-7017
79-7018
79-7019
79-7020
79-7021
79-7022
Sample
Type
Water
Water
Oil
Oil
Soil
Oil
Oil & Water
Oil & Water
Pentachlorophenol
Concentration
0.30 ug/1
3.0 mg/1
38,000 mg/1
36,000 mg/1
2,928 ppma
36,000 mg/1
43,000 mg/1
34,000 mg/1
ppm in this case indicates mg/g of soil
                                  13-13
-------
extremely  high  aod  would  be  considered  toxic  to  most
organisms.   PGP  concentrations below  the  farm  pond  were
Low  (0.30  ug/1)  and  probably  would   not  be  considered
toxic.   Concentrations of  PCP in the well  located  at the
plant  site  were  elevated  (3.0  mg/1)   and  would be  con-
sidered toxic.

     An analysis of one of the  soil  samples (79-7022) was
also  performed to determine  the  level  of dioxin (2,3,7,8-
tetrachlorodibenzodioxin)  in  the PCP.   Analysis  by multi-
ple ion detection GC/MS indicated that  if 2,3,7,8-TCDD was
present,  its  concentration  was less  than 20 ug/1  in the
PGP/oil  (22  ng/g  on  a  weight  basis) .    The   choice  of
analyzing  for 2,3,7,8,-TCDD was  made  because  this  was
thought  to  provide the best indicator  of  dioxin  contam-
ination  since  this  isoraer of dioxin  is  usually present in
highest concentrations.
PLANNING THE SITE RESPONSE

Initiation of Site Response

     On  June  19,   1979,  the  On-Scene  Coordinator   (OSC)
decided  that the oil/PCP spill  constituted  an  immediate
threat  to  navigable waters  of the U.S.  Further,  the  OSC
decided  that a  cleanup  should begin  immediately.   These
decisions  were  based on  the   toxic nature  of   PCP,  and on
the  likelihood  of  contaminaton  spreading  if was  not con-
tained  and  removed at  once.  While the  spill  had not  yet
travelled  beyond the  farm  pond,  a  heavy  rain would have
been  sufficient to cause the  pond to  overflow and carry
oil/PCP into Hog Creek.
     An  additional  concern of the OSC and of officials  at
 the  Missouri   Division  of  Health was  the   possibility  of
 contamination  of  drinking water  wells  in  the area.   There
 were 30   such  wells  within a 1 mile  (1.6 km)  radius  of the
 site.

 Selection of Response  Technologies

     Because the  PGP/oil spill posed an  imminent  threat  of
 discharge of  a hazardous  substance and  oil   into  United
 States  waters, and  the  spiller  was not  able  to  mitigate
 the  situation, a  Regional Response  Team (RRT)  meeting was
 convened in Houston,  Missouri,  on  June 19, 1979.   Atten-
 dees of  the  RRT meeting  included representatives  from U.S.
 Environmental  Protection Agency,  U.S.  Department  of Trans-
 portation,  U.S. Coast Guard, U.S.  Food and Drug  Adminis-
 tration, Occupational  Safety and   Health  Administration,
300.65UX1)
exposure to
acutely toxic
substances

300.68(e)(l)
(vii)
weather

300.65(a)(2)
contamination of
a drinking water
supply
                                      13-14
-------
U.S.  Corps  of Engineers, Missouri  Departments  of Natural
Resources, Health Conservation,  and  Highways,  Ecology and
Environment  Inc.,  O.H.  Materials   Inc.,  U.S.  Senator's
Office, and Houston  Chemical  Company.   The  purpose of the
meeting  was  to  assess  the  problem at  the  spill  site,
clarify  clean-up  resources,  and  implement  clean-up
actions.

     The  initial clean-up actions determined necessary at
the RRT meeting were to:

     •  Skim floating PCP/oil  from the pond's surface and
        removed it with a vacuum truck
     •  Remove PCP/oil from the catch basin above the farm
        pond with a vacuum truck

     •  Excavate and remove contaminated soils from around
        the plant and along the spill path to the pond

     •  Recirculate pond water through a carbon filtration
        system until PCP concentrations  are  below 10 ug/1
        and  then  release  filtered  water  to receiving
        stream
     •  Construct  diversions  around  the  pond  so
        rainfall would not enter and overtop pond.
that
O.H. Materials of  Findlay,  Ohio  was  contracted to perform
all  clean-up activities.   The  clean-up  was  done  under
contract to  the U.S.  Coast  Guard and monitoring  of activ-
ities were  performed by  an EPA Region  VII OSC  with  the
assistance of the U.S. Coast Guard Gulf Strike Team.

     After initial clean-up operations were undertaken, it
became evident  that  further activities  were  necessary to
adequately clean  up  the spill  site.   These  activities
were:

     •  Excavating contaminated pond  sediments
     •  Sealing the well on the plant site to deter ground
        water contamination

     •   Flushing  of drainageways to  aid  in  removing  and
        leaching of PCP/oil
        300.65(b)(6)
        moving hazardous
        substances off-
        site
300.65(b)(7)
physical
barriers
        300.65(b)(6)
        moving  hazardous
        substances
        off-site
                                     13-15
-------
     •  Inoculating the  refilled  pond  with microorganisms
        to maintain  PCP levels below  10  ug/1  because of
        leaching contaminants.

     The  selection  of the  clean-up  activities  were  per-
formed on site  based  primarily  on best engineering judge-
ments  to  quickly  and  effectively  eliminate   the  hazard
posed at the spill site.

Extent of Response

     On July 19, 1979 the  Missouri  Department of Conser-
vation  conducted  bio-assays  on  bluegill  for PCP,  and
reviewed  U.S.  Fish  and  Wildlife  Service  data on  PCP
effects on  fish,  in order to determine  a clean-up target
level.  According  to  the studies, all test  bluegill died
in  less  than  30  minutes  at  a PCP  concentration  of 2.5
rag/1.   In pond water containing  32  ug/1  PCP,  50%  of the
test  bluegill  died within  96  hours.  Water  samples from
the pond at Houston contained 59 rag/1 PCP.  The Department
of  Conservation concluded  on   July  19  that  10  ug/1 PCP
would  be  a  safe  level,  and  the  Regional  Response  Team
agreed to set that level as the cleanup target.

     When OHM completed  introduction of bacteria on August
6 pond  samples  contained less  than 10  ug/1 PCP.  However,
the  Coast  Guard continued  funding  for a  small amount of
additional  work on  the  site  until  the  end  of October.
During  that  period,  an  aerator remained  operating  on the
pond  to  facilitate bacterial action.   Also,  EPA periodi-
cally  took water, samples,  and  a local  contractor  occa-
sionally  replaced  sorbent  pads  on seeps  of oil/PCP at the
site .

     When  EPA  and the  Coast Guard  ended  funding for work
at  the  site on October  30, pond  samples  averaged 200 ug/1
PCP,  substantially  higher  than   the  target  level   of 10
ug/1.  The  aerator was  removed because  it did not appear
to  be  controlling  the contamination,  since  the PCP  level
in  the pond had been  rising since raid-August.   By December
1979,  while  some  oil/PCP  seepage continued and  pond
samples contained  400 ug/1 PCP, the Coast Guard concluded
that  there was   nothing further that could be  done at the
site.  Based on the Missouri  Department  of Conservation's
report  that  the pond has  since returned to normal and  is
supporting  aquatic  life, it appears that  the  final  remedy
occurred  through natural dissipation of  the  remaining PCP.
300.68(b)(5)
measuring and
sampling
300.65(c)
completion of
immediate removal
actions
                                      13-16
-------
DESIGN AND EXECUTION OF SITE RESPONSE

     The following section describes  the  different clean-
up actions  taken at the  Houston  oil spill  site.   Actual
clean-up operations  at the site  started  on 20  June  1979
and  lasted  through October 30,  1979.  The  main clean-up
operations performed at the site were:

     •  Skimming  and  vacuuming floating  PCP/oil  from the
        catch basin and pond

     •  Excavating and removing contaminated soil  from the
        PCP/oil  spill  path and from the farm pond bottom

     •  Recirculating  and  treat ing  farm pond water with a
        carbon adsorption unit

     •  Constructing  surface  water  diversions  around the
        farm pond

     •  Sealing  of the well at plant  site

     •  Inoculating  the  refilled  farm pond  with micro-
        organisms  in order to degrade PCP/oil.

Location of equipment  set-up at the  site by  O.K. Materials
is shown in Figure 3.

Skimming and Vacuuming jJperations^

     Concentrated  PCP/oil  was   removed   from   the   catch
basin (leaking pond) and   farm pond   using  skimmers   and  a
vacuum  truck.   The catch basin contained  nearly pure PGP/
oil,  while  the  farm pond  had   an approximately 1-inch
(2.54 cm) layer  of  floating PCP/oil.  PCP/oil was  vacuumed
directly  from  the catch basin,   and was skimmed and
vacuumed  from  the  pond   surface.    Approximately 10,000
gallons  (37,900  1)  of PCP/oil  was  recovered  during the
vacuum  operations.   Recovered PCP/oil  was  trucked to the
wood  treating  plant and  stored  in  an  inside storage tank
that  was  deemed safe.  The  skimming and vacuuming opera-
tions  started  on  June 20, 1979  and continued until June
21,  1979.
     Excavation Qperat ions
     The  soil excavation  operations  were  carried  out  in
 two  phases:   spill  path excavation  and  pond bottom  excava-
 tion.   Excavation  of  the  spill path  was  initiated  first
 using  backhoes ,    Contaminated soils  were excavated  from
 around  the   plant   site   initially  and  then  proceeded
 westerly  along the  spill  path to  Highway 63.   Excavated

                                      13-17
300.65(b)(6)
moving hazardous
substances off-
site
-------
                                      Hwy. 63
   Spillway
                                                   r
                                                .  I   Chemical Plant
                                                •* •   /
    ® Church Well



truck tank traiar
cartoon flttratton
                                         on-arta lab


                                         command poat

                                         kttchwi
     Storage Tanks



   Ruptured Tank




   Main Row of Oil
                                      Haney Trailer Park Well
          Figure 3.   Houston  Chemical Co.  Response  Actions
                                   13-18
-------
 soils  were  loaded  and  trucked  to  Bob's Home  Service,  Inc.,
 (closest  approved  hazardous   waste  landfill)  located  in
 Wright City,  Missouri,  approximately 170  (272 km)  miles
 away Trucks used  for hauling of the  contaminated  soil were
 lined  with plastic  to  avoid leakage-during transport.
 Approximately  942  cubic  yards  (720 m  )  of  contaminated
 soils  were  removed  along the spill path  and  transported  to
 the landfill.

     As  soil  excavation proceeded  along  the  spill  path,
 on-scene  personnel  determined  that  some  PCP/oil  still
 remained  in the  soil  and was   leaching out.  To abate this
 problem,  the drainageways  were flushed with water.   Three
 8-inch (20  cm) plastic pipes  were  placed through  Highway
 63  to  divert   flushing  water into  a  carbon  filter box
 before it entered the pond.   Flushing  water was  obtained
 from the  well  on-site  or was   carried from Hog  Creek  using
 a vacuum  truck.

     Excavation of  the farm pond  bottom  started as  soon  as
 the pond's  water level  was  lowered sufficiently to  allow
 equipment   access.   Approximately  4  to   6 inches  (10  -
 15 cm) of the  pond's  bottom sediments were removed.   Saw-
 dust had  to be mixed  with the sediments  to control  it's
 consistency and  satisfy  the state's landfill  regulations.
 Excavation  operations  eventually outpaced hauling opera-
 tions,  requiring  brief  storage  of  contaminated  sediments
 on higher ground within  the   pond.   Stockpiled  sediments
 were placed on plastic  to  prevent  the recontamination  of
 underlying  soils.   Approximatley 1,694  cubic yards  (1296
 m ) of the pond sediments  (some  mixed  with sawdust)  were
 hauled to the  Wright City landfill.

     During  the  pond excavation  operations,  numerous wet
 weather springs or  seeps were  noticed in the floor of the
 pond.  These springs were found to be heavily contaminated
 with PCP/oil (3100  ug/1  of  PGP).   In order to  remedy this
 problem,  sorbent  pads  were   placed  around  the  springs.
 When flow could not be contained  by the sorbent pads, the
 contaminated  water  was  vacuumed  and   pumped through   a
 carbon filtration system.

     After  the excavation  operations were  completed, the
 drainage  ways  and  pond  area  were  regraded  and  restored
 (includes  reseeding  and  landscaping).   Contaminated
vegetative  material  and  sorbent  pads  were  hauled  to the
 landfill  for  disposal.   A total of 2,635.9  cubic  yards
 (2016  mq)  of contaminated soil were excavated and disposed
of from the  spill  site.  Excavation  operations started on
June 20,  1979  near the  plant  area  and  ended  on  July 20,
 1979  with  the removal of the last loads of pond sediments.
                                     13-19
-------
Treatment of Pond Water

     While  the  skimming  and  vacuuming  operations  were
occurring at the farm pond to remove the floating PGP/oil,
the contaminated pond water was being circulated through a
carbon filtration system.   The filtration system consisted
of  a mix-media  prefilter  (pea  gravel/limestone)  and  a
three-stage  carbon  filter.    Total  charge  of  carbon  was
2400 pounds (10,896 kg).  Two pumps were utilized with the
unit, a  3-inch (7.6  cm) electric pump  and  a  4-inch (10.2
cm) diesel trash pump.  The intake pipe was floated in the
pond in a boomed-off  area with  the actual  intake 2 to 4
feet  (0.6  to  1.2  m)  below  the  surface.   This prevented
highly concentrated PGP/oil from entering the system.  The
carbon filtration unit was operated 24-hours per day until
the water in the pond was completely removed.

     The  initial  plan was  to  recirculate  the  pond water
back to  the  pond  after  filtration until the PCP level was
less than 10 ug/1.  This plan was changed to filtering the
pond  water  and  releasing   it  to Hog  Creek when  the  PCP
concentrations  were   reduced  to below  10  ug/1.    At  the
onset  of filtering  the pond  water,  it  was  recirculated
back  to  the pond because  OHM did not  have their  on-site
laboratory operational  and  the contaminant  level could not
be  checked.    Carbon  filtration and  recycling  started on
June 20,  1979  and  lasted  until June 25, 1979 when  on-site
laboratory  was  made  operational.   After  this  date,
filtered  pond  water  was  released  to a  tributary  of Hog
Creek.   Complete filtration and  removal of original  pond
water  was  completed  on  July  8,  1979.    Approximately
700,000  gallons  (2.6 x 106  1)  of water had been released
to  drain the pond completely.   The  total amount of water
filtered  by the carbon  filtration system was  nearly  2  x
106  gallons (7.6  x  106  O because the water  had to be
recycled  for the first six  days until an on-site  lab was
operational, allowing OHM to determine  that treated water
was  below 10  ug/1.   During the  treating  and draining of
the  farm pond,  the  carbon  filtration unit was  recharged
once.    Spent  carbon was disposed  of  in  the  Wright  City
landfill.

     The  carbon  filtration  unit  was  reactivated on  July 9,
1979 because a local  rainfall  partially refilled the  pond,
and operated  intermittent ly  for  the next   ten days.
Filtering  and   releasing  the water  from the rainfall  and
wet weather springs  in the pond was accomplished  by  July
 18, 1979.   The  carbon filtration unit  was deactivated  on
 this date.   Carbon  filtration units were  completely
 removed  from site on August 2, 1979.
                                      13-20
-------
Diversion Construction

     Because  the  level  of  water  in the  pond was near
overflow, a trench  and sandbag diversion  was constructed
at  the  site  to  divert  surface  runoff around the pond.
Location of the trench and  sandbags is shown in Figure 3.
Construction of the runoff  diversions  began on  June 20,
1979 and  was  completed on June 21, 1979.  The  diversion
structures remained in place until July 18, 1979 when they
were  removed.  During  the  time the  structures  were in
place the  pond  did not overflow the  spillway  and release
water.

Sealing of Plant Well

     An  investigation  was  performed at the  plant  site to
determine  if  the  plant  well  was  acting  as  a  route for
aquifer  contamination.   Initial  investigations made  by
obtaining a water  sample at  an outside tap showed that an
oily  film was  present  in  the  water, probably PCP/oil.
Sampling  revealed  that  the  concentration  of  PGP  in the
well was  3 rag/1.   Further  investigations  showed  that  an
old buried water line  that was not sealed was the cause of
the PCP/oil  intrusion.  To  prevent contamination  of the
underlying  aquifers,  the   plant  well was  purged  until
contamination  was  not  observed.    Samples taken  at this
time showed PGP levels to be less than 0.50 ug/1.  The OSC
determined  at  the  time that  the  plant  well   should  be
sealed to  prevent  any further contamination  of the local
aquifers.   This was  deemed  necessary because  the  plant
well was  improperly cased  and the potential  for contam-
ination was great.   On June 27, 1979 the components of the
plant well  were removed  and  the  well sealed  by pouring
cement throughout its drilled length.

Bioreclamation of Refilled Pond

     Because  of  the  potentially  long term  leaching of
PCP/oil  into the  pond from  bottom  seeps and  the large
amount of  soil that would   need  to be excavated to elim-
inate the  leaching,  the OSC decided  to   allow  the farm
pond  to   refill  and   then   introduce  more  organisms  to
degrade  any  newly  leached   PCP.    The type of  organisms
chosen were pseudomonas  bacteria (Bio-Pac  Sybron culture
DC  1007  pp)  originally developed  for  degradation  of
phenols.    PCP  is more difficult  to degrade  than phenols
but  it  was  believed that  80%  degradation  could  be
accomplished.   Microorganisms were shipped freeze-dried to
the site  where they were acclimated in a holding pool with
300.65(b)(7)
physical
barriers to
deter spread

300.70(b)(l)
(ii)-(B)(l)
dikes and berms
                                     13-21
-------
controlled nutrient, temperature, and oxygen levels.  Once
acclimated, the  organisms were  added to the pond.  Self-
contained  electric  aerators were floated on the  pond to
help maintain oxygen levels above 2 mg/1.

     The  first batch of organisms were  added  to the pond
on July  28,  1979  and successive batches  were  added until
August 4,  1979.  A total  of approximately 100 pounds (220
kg)  of  organisms  were  added  to  the   pond  during  this
period.  Microorganism concentrations in the pond for part
of this  time  period  are  shown in Table  4.  Bioreclamation
operations were discontinued after October  30,  1979 when
the aerator was removed and the spill clean-up terminated.

     Two  problems  arose during  the  bioreclamation opera-
tions:   excessive  die-off  of organisms  and overtopping of
the  spillway  caused  by  heavy rain.  The excessive die-off
of  organism  in  the  pond  was  apparently  caused  by  the
property  caretaker turning off  the  aerators  in the pond.
Once this  was discovered the  problem ended.

     During  the  bioreclamation  operation  heavy rains
occurred  twice causing  the pond to discharge contaminated
water  through the spillway.   Carbon filter dams  (primary
and  secondary) had been built on the spillway to minimize
contaminant  releases.   Despite the damage incurred to the
dams during  the second  overflow,  a fish kill or  extensive
damage did not occur in  local receiving  waters.

     In  early October,  the OSC attempted to reintroduce  a
bacteria population in  to the pond and  ordered  100 pounds
(45  kg)  of  freeze-dried  bacteria from  Sybron,  Inc.   The
OSC  was  not  optimistic  that  the  attempt  would  succeed, but
believed that the  relatively small  investment  of $1,000
for  the  bacteria and nutrients  was justified by  the chance
that  they might  work.    Subsequent  sampling  of the  pond
indicated that the  new batch of bacteria had no  apparent
effect.    The  aerator was turned  off  on October  30.    In
November, the last  pond  sample taken contained  about 400
ppb  PGP.
300.70(b)(2)(ii)
(A)(2)
aerated lagoon
 COST AND FUNDING

 Source of Funding

      On June 19, 1979 EPA and Coast Guard officials sought
 an agreement from  representatives of Houston Chemical Co.
 to  pay  for  the clean-up.   When the  effort  failed, the
 only  other   available  source  of  funds  was  the  section
 311(k) Revolving Fund.  The  OSC obtained  an initial spend-
 ing authorization  of $50,000 from the 2nd  Coast  District
 300.68(c)
 responsible
 party
                                      13-22
-------
TABLE 4.  MICRO-ORGANISM CONCENTRATIONS
Date
(1979)
30 July
31 July
1 August
2 August
Micro-organism Count (organism/ml)
Incubation Batch
1.3 x 106
1.2 x 107


Pool Sample
1.1 x 107
4.8 x 106
6.0 x 10*j
1.1 x 106

Upper Pond
5.2 x 105
8.0 x 104
4.0 x 104
1.5 x 104
Lower Pond
4 x 103
8.4 x 104
1.9 x 10^
1.7 x 10
1.5 x 10^
1.4 x 10
                13-23
-------
office  in  St.  Louis,  Missouri.  The  Coast  Guard periodi-
cally raised the spending authorization during the cleanup
as the  OSC requested more  funds.   The OSC initially esti-
mated that the  cleanup would  take  30  days to complete and
would cost about $500,000.

Selection of Contractors

     On June 19, the OSC contacted O.H. Materials, Inc. of
Findlay,  Ohio,  and engaged   the  firm  to   begin  cleanup
operations as  soon as  possible.  The  first  OHM personnel
arrived at the  site that afternoon.  According to the OSC,
OHM was chosen  to  do the  work because, at that time, they
were  one  of  only  two  firms  in  the  U.S.   qualified  to
respond quickly and effectively to  chemical  spills.   O.H.
Materials  was  chosen  over   the  other  firm  because  EPA
Region  VII recently had used  the other  firm  in a different
clean-up and believed  it  was  equitable to use OHM for the
spill at Houston.   The OSC,  acting as agent for the Coast
Guard,  contracted  with  OHM on a time-and-materials basis,
using an  OHM  price list  for  labor  and equipment that EPA
already had  on  file.   The  contract  did not  specify the
tasks  that OHM was  to   perform,  leaving  the  OSC  broad
discretion to define the nature and scope of work.

     At the request of the OSC, on June 20  the EPA Region
VII  office contracted with  a  dispoal  facility in Wright
City, Missouri, approximatley 170  miles (274 km) from the
site,  and made  arrangements  for  disposal of  contaminated
soil that  was  removed during  the cleanup.  The facility,  a
landfill  called  Bob's  Home  Service,  Inc. was  chosen
because it was the closest  facility  available  that was
licensed  to accept hazardous wastes.   Initial plans had
called  for removal of both contaminated soil and  recovered
oil/PCP.   However, the OSC decided  that the oil could be
transferred  safely to a  secure  tank  inside  a building at
the  Houston  Chemical Co.  plant,  saving the  expense of
transporting  and disposing of  the  oil.  Houston Chemical
Co.  officials  consented  to  the  OSC's  decision.    EPA's
initial estimate of the  quantity of  soil to  be disposed of
was  800 cubic  yards (612  m  ).   The actual  amount of  soil
taken  to  Bob's Home   Service  was   2,636   cubic   yards
(2015 m3).

Project Costs

      The  total cost of  the  Houston Chemical  Co.  cleanup,
 from June  18,  1979  to  December  29,  1979,  was  $709,427.
All  monies came from  the section  311 (k) Revolving  Fund.
Most of the expenditures  occurred during the  49  days from
June 19  to August 6  when the initial  cleanup,  soil  dis-
posal ,  and biological treatment  took  place.   The  total

                                      13-24
-------
 spent  during   this  period was  about $704,000.    The
 remainder of the  expenditures  occurred  from  August 7  to
 December 29 for a small amount  of  follow-up work.   A total
 of $3,370 was  spent  on grading and  reseeding to  restore
 the site, and  for  replacing the sorbent pads  placed over
 oil seeps on a  weekly basis for six weeks.   Another $1,111
 was spent  on  freeze-dried bacteria  and nutrients  in  the
 attempt  to  reintroduce a bacteria  culture  in  the pond
 during October  1979.

      The EPA's  original estimate of the  cleanup cost, made
 two weeks after work at the site began,  was approximately
 $500,000 for the  whole job.   The cleanup cost  $209,000
 more  than anticipated  for three  reasons.   First,  EPA  had
 not expected to have to  excavate  and remove  contaminated
 soil  from the pond  bottom.  When the  pond bottom was found
 to be  contaminated,  the  amount  of  soil that had to  be
 removed and disposed of  tripled  the  original  estimate  of
 800 cubic yards  (612  mj).  Second,  heavy  rains   in  early
 July  delayed excavation work and necessitated  reactivation
 of the carbon filtration system.  Third,  EPA initially  had
 not intended to employ biological  treatment,   which  added
 about  $60,000 to the  total clean-up cost.   Table  5  summa-
 rizes  the cost  breakdown by operations.

 Soil  Excavation, Vacuuming,  and Carbon Filtration
      The  bulk  of   expenditures,  approximately $459,000,
 occurred  during the   initial 32 days of the cleanup, from
 June   19  to July  20.  During  this  period,  OHM built
 surface  water  diversion structures; excavated  all  contam-
 inated  soil  from the  spill path and pond; vacuumed  10,000
 gallons (561,800 1) of oil/PCP; and  began   restoration  of
 the carbon site.  Because  many of the tasks  were performed
 concurrently,  and because  OHM billing  for time-and-
 materials  did   not  break  down  charges   on  a  task-by-task
 basis,  it  is not possible  to calculate  accurate costs  for
 each  task performed.   However, average daily costs  for
 different  phases of the cleanup  give some  indication   of
 the relative costs of various tasks.

     Daily  costs were  highest  for  the  first   11  days   of
 work,  averaging  about  $20,000.   During  this period, 17-20
 workers were on site,  setting  up and beginning operation
 of  the carbon  filtration   system,  mobile  and analytical
 lab,  and vacuum  truck, and  excavating  the  spill  path.
 Skimming  and vacuuming  were completed during this  period.
Daily  costs  from the  12th day to  the  32nd day  averaged
$12,000.   Costs  during this  period  were   lower  because
containment, set-up and vacuuming  were  already complete.
Twelve  to 15 workers   were  on  site  during this  period,
300.65(b)(6)
moving hazardous
substances off-
site
                                     13-25
-------
                         TABLE 5.  SUMMARY  OF  COST  INFORMATION-HOUSTON CHEMICAL CO..  HOUSTON,  MO.
I
ro
Li-id
V.ituniiiin'j "II /
I'M1
Carbon fl Itni-
t Urn Of pond
ioil i-xt.iv.i-
tlm
Soil Uii|'0$al-
UiiJIJll
Sull lrai)',portii
Uoii-UU mi
l!»7J km)
iiloluijicdl
IlCiltlM'tlt
l.l'ft (UT-iomiel
,111(1 tliiVI.'l
Cu.ist liuaril
iVriottiiel
.111(1 tl'ilVCl
HL'slQi'jUon and
fu11ow-u|)
word
MUc«l laiK-uus
Ox^i-TlJi lui'es
lotal
Estimated
quantity


lawi cu.y.l^.
612 cu. ra, )
IUM) cu.ytls.
161? cu. m.)
l«)i) cu.yds.
(612 cu.n)






Actual
Oujritlty
1(1,000 t|Al.
161.775 1)
2 mil Him f].il.
7W6 million 1)
?,(,V.> eu.yiW.
;2ni5 cu. >n. )
J.dK tu.yd'J.
(illl5 cu. ffl.)
Z.&J'j cy.ytls.
(?015 cu.m)

-til) douri
HGO linurs



Estimated
Exjinmlituro



$3.1.600 (?]
ji6,nnn (zi
t?o.ooo




jwjo.noo (3)
Actual
txpoixllture


H5H,'tM(U
(110,70(1
ir.2,646
Kil.Ui!
* ?,2I'»
ti(>.n?6
t 3.3M
t t,r.?j
$704,471
Variance



i;/,ioB
(.??'j,:|
$36.646
(i??9?)
it-Id, 1111
(*2iisr.i




1*201,4?;
1.41/1
Unit Cn*t



J1^/cu. yd.
(I1lj/cu.in)
$?n/cu.yil. or
ll.7
-------
 completing soil excavation and removal,  carbon filtration,
 site restoration,  and equipment breakdown.

 Biological Treatment

      The  second  phase  of  the cleanup,  introduction  of
 bacteria and nutrients  to the pond, lasted  13  days,  from
 July 25 to August 6,  and  cost $61,181.   Daily  costs  were
 biological about $4,700.   Two to four OHM  personnel  were
 on site during this  period.   The original  OHM  cost  esti-
 mate for  the biological  treatment  was  $20,000,  or  one-
 third of the actual  cost.

 Transportation  and Disposal

      A total of 2,636 cubic yards  (2,015  m )  of  contam-
 inated  soil, vegetation,  absorbent  pads and  spent  filter
 carbon  were  disposed  of  at  Bob's  Home  Service,  Inc.,  a
 licensed  hazardous  waste  landfill  in  Wright  City,
 Missouri.   The  disposal  cost  for all materials was  $42 per
 cubic yard ($48/m  ),  or  a  total of $110,708.  The material
 was  transported in  130  truckloads  at $355  per  load.   An
 OHM  subcontractor carried 122 of the  loads, which  added
 15%  to  the cost per  load.   Eight  loads were  contracted for
 directly by  the  Coast Guard.   The  total  cost  of  trans-
 portation  was $52,610, or  $19.96 per  cubic  yard ($26  per
 cubic meter)  of soil  or  11.7  cents per cubic yard per  mile
 (15.3 cents/in /km).

 Administrative Costs

      Costs  to EPA for salaries, transportation,  and  per
 diems  associated with the cleanup totalled  $7,218.  Seven
 different  EPA  personnel   were  on site  at  various times
 during  the  clean-up  working a total  of 440  hours.  Wages,
 including  overtime,  totalled $5,305.   Transportation  and
 per  diems  totalled $1,913.   These amounts  do not  include
 sample  analysis  and  administrative  work  performed  at  the
 EPA Region VII offices.

     Costs to the Coast Guard for salaries,  per  diems,  and
 transportation  totalled  $10,825.  Three  Coast Guard  per-
 sonnel  worked a total  of 860  hours on  clean-up  related
 duties,  at  a  cost  of $4,524  in salaries.   Per diems  cost
 $5,759, and transportation cost $542.

Miscellaneous Expenditures

     Miscellaneous expenditures totalled $4,523.   Included
 in this  figure  are  $1,211 for  telephone  service,  $1,111
for additional bacteria, and  a  number  of  smaller expendi-
tures on such items as chartered airplanes to send samples

                                     13-27
-------
to Kansas City,  film,  and rental of  a  motel room for use
as a command post.
PERFORMANCE EVALUATION

     An  assessment  of  the  performance  of  the  types  of
clean-up actions  taken  at the Houston  Company spill site
must  consider  the  nature  of  response.    This  clean-up
effort was  performed  at an  emergency  spill  response, not
as  a  planned  remedial action.   The actions  taken  at the
site were  done  to prevent the  spread  of  PGP and cleanup
the site as quickly as  possible.   The  decisions made were
often based on  insufficient  data  and time constraints did
not  allow   for  the  development  of  extensive  studies  to
determine  the "best"  or the most  cost  effective clean-up
action.

     The intent  of  the clean-up  effort was  to eliminate
the hazard  posed  by  the PCP/oil spilled  at  the site.  As
part of  this, a  target  level of less than 10 ug/1  of PCP
in  the local  surface waters  was to be  attained to prevent
potential  toxic  effects  to  the   ecosystems.    The  only
standard to determine if the clean-up actions taken at the
site were  effective  in  eliminating the PCP hazard  is the
water quality monitoring data.

     Ground water quality  data  available  for  the site is
shown  in Table  6.   These  data  indicate that  the   local
ground water  had not  been  significantly affected  as  of
June 26, 1979.  The high concentration of PCP found in the
plant  well  on June  19,  1979 was  caused  by  contaminants
that leaked into the water lines that carried water to the
plant  building.   Sealing of  the  well  was  an  appropriate
action because  the possibility  for contamination was
great.   Extensive monitoring of wells  in the area did not
indicate  that  the  PCP/oil  had  migrated  into  the  deep
underlying aquifers.  Depending upon the permeability and
velocity of these aquifers,  the  contaminants may have not
traveled far  enough  to be detected by the end of opera-
tions  in December.

     Surface water quality data for the  site is shown in
Table 7.  At the end of operations on October 30, 1979 the
farm pond had a PCP concentration  ranging  from  250 ug/1 to
400  ug/1,   a  concentration  greater  than  ten  times the
target  level.    Based  upon data,  it is  evident that the
clean-up operations  at  the  site did not completely accom-
plish  their goals for  reduction in  surface  water contam-
ination.  The main reason for this  is that the  bulk of the
clean-up operations at site  (i.e.,  soil excavation, carbon
filtration, and  skimming  and vacuuming)  were  designed to

                                     13-28
-------
TABLE 6.  GROUND WATER SAMPLES
Date
(1979)
June 19
June 24
June 26
Sample No.
EG 0304
EG 0322
EG 0323
EG 0324
EG 0325
EG 0326
EA 0405
EA 0406
EA 0407
EA 0408
Description
Well at plant
Well at church
Well at plant
Well at Haney trailer park
Well at Jaus farm
Well at Fisher junkyard
Well at plant
Well at plant
Well at trailer park
Well at trailer park
Concentration
3.0 rag/1
<0.1 ug/1
1.2 ug/1
0.7 ug/1
<0.1 ug/1
<0.1 ug/1
0.20 ug/1
<0.05 ug/1
<0.05 ug/1
<0.05 ug/1
            13-29
-------
TABLE 7.  SURFACE WATER SAMPLES
Date
June 19
June 24
June 25
June 26
June 29

July 8
July 9
July 16

July 28
July 30
July 31
Aug 1
Aug 2
Aug 5
Aug 6
Sample No.
79-7017
79-7018
79-7020
79-7021
79-7022
EG 0315
EG 0316
EG 0317
EG 0318
EA 0402
EA 0403
EA 0404














Description
Along spill path near plant - oil
Along spill path east of Hwy 63 - oil
Catch basin above farm pond - oil
East end of farm pond - oil/water
Near spillway of farm pond
Tributary to Hog Creek below farm pond
Tributary to Hog Creek above 400 yds
before confluence
Confluence at Hog Creek
On Hog Creek about 25 yards above
confluence
Tributary to Hog Creek below farm pond
Tributary to Hog Creek above confluence
Hog Creek below confluence
Pond water
Pond water

Pond pumped dry
Pond water (after rainfall)
Springs into pond
•
Bioreclamat ion started
Pond spillway water (after heavy
rain)
Hog Creek
Pond water (composite)
Pond spillway
Pond spillway
Batch tank (pOOl)
Pond water
Pond water
Concentration
38,000 mg/1
36,000 mg/1
36,000 mg/1
43,000 mg/1
34,000 mg/1
0.74 ug/1
0.40 ug/1
0.17 ug/1
0.27 ug/1
0.7 ug/1
0.2 ug/1
0.4 ug/1
20,600 ug/1
16,500 ug/1


1,167 ug/1
3,100 ug/1


1,440 ug/1
3 ug/1
20 ug/1
<10 ug/1
<10 ug/1
<10 ug/1
<10 ug/1
<10 ug/1
                                        (continued)
             13-30
-------
TABLE 7.   (continued)
Date
Aug 14
Aug 20
Aug 29
Sept 7
Oct 5
Oct 30
Nov 2
Nov 6
Dec 11
Sample No.









Description
Pond water
Pond water
Pond water
Pond water
Pond water
All operation stopped
Pond water (4 samples)
low
mean
high
Pond water
Pond water
Concentration
<10 ug/1
153 ug/1
60 ug/1
80-90 ug/1
>100 ug/l


250 ug/1
>300 ug/1
400 ug/1
200 ug/1
400 ug/1
                  13-31
-------
eliminate  known "visible"  contamination  (e.g.,  floating
PGP/oil, contaminated soils, contaminated  pond  water)  not
PCP/oil which seeped into the shallow aquifers.

     An  unknown amount  o f  PGP/ oil  had  in f i 11 rated  be low
the depth of soil excavation and  possibly into the shallow
ground water table.  This is evidenced by the high concen-
tration of PCP  in  the  springs  found  in  the  pond's  bottom
(3100  ug/1)  after  complete water  removal.    The  method
chosen to control  the PCP  seeps  was  bioreclamation  of the
pond  water  after  the  pond  refilled.    Early  indications
were  that  the  bioreclamation  was performing as  expected
because the PCP concentrations were  reduced  below 10 ug/1
between  August  1,  1979  and  August  14,  1979.    However,
after  this date  the PCP   concentrations  approached  400
ug/1, after clean-up operation  termination.

     A factor that may have  contributed  to the  failure of
the  bioreclamation  efforts at   the  site was   that  the
property caretaker  was   turning  off  the  aeration  pumps.
However,  other  uncontrollable  factors  such  as  weather
conditions, water chemistry, and  natural nutrient loading
could  have  also  had  an   effect  on  the  bioreclamation
effort.  Based  on  information  provided by  the  bioreclama-
tion  manufacturer,  the  oxygen  concentrations in  the pond
needed to  be  maintained  above  2  mg/1  to ensure viability
of  the  organisms.   Oxygen  levels  less than  this  would
cause excess die-off of organisms.   However,  hard data is
not available to conclusively show what caused the failure
of the bioreclamation operations  at the site.

      In  retrospect,  it  appears  that  the  clean-up  opera-
tions at the  site  were performed in  an appropriate  manner
to minimize the hazard posed.  The  reason  for  not obtain-
ing  the  goal  of less than 10  ug/1  of PCP in  the surface
water  was  the  inadequacy  of  the  plan  to deal  with  the
heavily contaminated springs in  the  pond bottom.   Whether
or  not  the  bioreclamation procedures  would  have  been
completely successful  in eliminating  this  problem is
unknown because sufficient data were not available.
                                     13-32
-------
                                 BIBLIOGRAPHY


 Barnett,  Dewey  A.  June 29, 1979.  "Trip Report:  Oil Pollution Project No.
      190030  in  Houston, Mo.".  Second Coast Guard District, St. Louis,
      Missouri.

 Bob's Home Service,  Inc.  July 31, 1979.   Invoice to U.S. Coast Guard Re:
      contract DOT-CG02-3132-21902815.  Wright City, Missouri.

 Buchanan, Jim.  June  19,  1979.  "Regional  Response Team Meeting Summary".  TAT
      VII, Ecology  and Environment, Inc., Kansas City, Kansas.

 Buchanan, Jim.  undated.  "Summary, TAT Response, Houston Chemical Company,
      Houston, Missouri".  TAT VII, Ecology and Environment, Inc., Kansas City,
      Kansas.

 Burris, James A.,  P.E.  September, 1982.   Personal communication.  Missouri
      Department of Natural Resources, Poplar Bluff, Missouri.

 Duley, William.  June 25, 1979.  "Engineering Geologic Report on Houston
      Chemical Spill, Texas County, Missouri".  Missouri Geology and Land
      Survey, Columbia, Missouri.

 F&S Trucking Co.   July 24, 1979.  Invoice  5091 to U.S. Coast Guard.  F&S
      Trucking Co., Blue Springs, Missouri.

 Gilmer, Harry.  July 9, 1979.  "Houston, Missouri, Pentachlorophenol Fact
      Sheet, Draft".  U.S. Environmental Protection Agency, Kansas City,
      Kansas.

 Harrington, Richard.  June 25, 1979.  "Report on Causation of Tank Failure,
      Region VII".   TAT VII,  Ecology and Environment Inc., Kansas City, Kansas.

Hoopes, Lt. Patrick T.  September, 1982.  Personal communication.  U.S. Coast
     Guard, Gulf Strike Team, Bay St. Louis,  Mississippi.

Hoopes, Lt. Patrick T.  December 11, 1979.  Record of telephone call to Gary
     Snodgrass,  OSC, re:   Houston Chemical Co.  Spill.   U.S.  Coast Guard, Gulf
     Strike Team,  Bay St.  Louis,  Mississippi.

Hoopes, Lt.  Patrick T.  July 19,  1979.   "Trip Report," re:   Houston Chemical
     Co.  Spill.   U.S. Coast  Guard,  Gulf Strike  Team,  Bay St.  Louis,
     Mississippi.
                                     13-33
-------
Keffer, William J. et al.   June 19,  1979 to October 10,  1979.   "Spill  Report:
     Houston Chemical Company".  U.S.  Environmental Protection Agency, Kansas
     City, Kansas.

Leyland, Daniel.  July 26, 1979.  "Report of Investigation of  Pentachloro-
     phenol/Oil Spill, Houston, Missouri".   Missouri Department of Natural
     Resources, Poplar Bluff, Missouri.

O.K. Materials Inc.  June 28, 1979 to August 28, 1979.  Invoices to U.S.  Coast
     Guard re:  contract DOT-CG02-3130-21902695.  O.H. Materials, Inc.,
     Findlay, Ohio.

Panning, Robert.  September, 1982.  Personal communication.  O.H. Materials
     Co., Findlay, Ohio.

Reese Excavating Co.  August 4, 1979 to December 29, 1979.  Invoices to USEPA,
     Kansas City, Kansas.  Reese Excavating Co., Houston, Missouri.

Reynolds, Jeffrey.  June 23, 1979.  Inspection Report, case file R5949-150100,
     O.H. Materials Co., Houston, Missouri.  U.S. Occupational Safety and
     Health Administration, St. Louis, Missouri.

Snodgrass, Gary B.  August, September, 1982.  Personal communications.  U.S.
     Environmental Protection Agency, Kansas City, Kansas.

Snodgrass, Gary B.  October 10, 1979.  Memorandum re:  status of Houston spill
     site to Billy J. Fairless, Deputy Director, SVAN.  U.S. Environmental
     Protection Agency, Kansas City, Kansas.

U.S. Coast Guard.  June 21, 1979  to October 9,  1979.  "Pollution Reports,
     Number One through 20".   St. Louis, Missouri.

U.S. Coast Guard.  January  13,  1981.   "Billing  for  Sale of Material or
     Services  to  Warren Wise,  Inc.".   St. Louis, Missouri.

U.S. Environmental Protection  Agency,   undated  report. "Houston, Missouri
     Oil-Pentachlorophenol  Spill  Incident".  Emergency Response  Section,
     Technical  Services Branch, Surveillance and Analysis Division.   U.S.
     Environmental Protection  Agency Laboratory, Kansas City, Kansas.

Wickland, John C.  January  6,  1981.  Letter to  Commander,  Second Coast Guard
     District,  Re:   Administrative  Costs of Houston Cleanup.  Management
     Division,  U.S.  Environmental Protection Agency,  Kansas City,  Missouri.
                                      13-34
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                                   HOWE,  INC.

                           BROOKLYN CENTER,  MINNESOTA
 INTRODUCTION

      Howe,   Inc.,   formulates   and  stores   agricultural
 chemicals  at  a   small   facility  in  Brooklyn   Center,
 Minnesota,   a   residential   suburb  of   Minneapolis.     In
 January  1979, a  warehouse at  the site,  containing  a
 variety of  pesticides,  fertilizers, and  explosives,  was
 consumed  by fire.   Water  used  to  extinguish  the fire
 carried pesticides  into  a  nearby stream bed  and  infil-
 trated  into  the   soil.     Sampling  by  state   officials
 revealed  hazardous  levels  of   pesticides  on  the  ground
 surface,  in soil,  and  in ground  water.

 Background

      Howe,  Inc. occupied five buildings  on a 5.3  acre (2.1
 ha)  parcel  in  Brooklyn Center,  immediately west  of  the
 Minneapolis city  limits  (see  Figure  1 ) .   The  site  is
 located in  a  smal1 area  of  industrial  buildings  in   an
 otherwise   residential  neighborhood  of  detached   single-
 family homes.  At   the  time  of   the  fire,  Howe's north
 building    contained   about   100 different  pesticides,
 totalling   80  tons  (73 Mt) of  active  ingredients.   The
 predominant  active  ingredients  were two  organic  herbi-
 cides:   atrazine,  known  commercially  as  Aatrex  4L,   and
 alachlor, known commercially as  Lasso.

      Fire  broke  out in the  north  building on  January   6,
 1979  (see Figure 2).  In the course of the six-hour effort
 to extinguish  the  fire,  the Brooklyn Center  Fire Depart-
 meigt   sprayed   more than  a   half-million gallons (1.9 x
 10   1) of  water  on  the building.   Some  of the  water
 collected in shallow ponds on  the  Howe  property,  but most
 of the  water flowed through a culvert and  emptied  into  the
 dry bed of  a small intermittent stream  named  Ryan Creek,
 which  runs   immediately south  and  east  of  the  site   and
 drains  into  the  Mississippi   River,   about   two  miles
 (3.2  km)  to the  east.   The  pesticide-laden  water flooded
 an area of  the stream  bed  about  900 feet  long by  15 feet
wide  (275 x 5 m).   The flooded area lay within the City of
Minneapolis on property owned by the Soo Line Railroad.
NCP Reference
300.68(e)(2)
amount and form
of substances
                                     14-1
-------
Figure 1.  Howe, Inc. Location
     (Barr Engineering,  1980)
                    mr*
     HOWE, INC. SITE fT^t-.
              14-2
-------
                                     Figure 2. Howe,  Inc.  Site Map
                                        (Barr Engineering, 1980)
HOWE, INC.
PROPERTY  0 i
LIMITS     B '
                                                                                      Location of soil boring only

                                                                                      Location of monitoring well and
                                                                                      soil boring

                                                                                   'CB Catch Basin
-------
Synopsis of Site Response
     This case study describes  the  actions  carried out in
response  to  contamination  left in  the  aftermath  of  the
fire,  and  does  not  include  the  actual  firef ighting
efforts.  A  number  of  government agencies participated in
the  Howe clean-up, including  the Minnesota Pollution
Control Agency  (MPCA),  the Minnesota Department  of Agri-
culture (MDA),  the  Minnesota Department  of  Health (MDH),
and  the  cities  of  Minneapolis  and Brooklyn Center.   The
major elements of the  clean-up were:   emergency  response
actions; provision  of  alternative  water supplies, removal
of contaminated ice,  snow,  and soil; removal  of  building
and  other  fire debris;  a  hydrogeological  investigation;
and ground water  recovery.  Most of the clean-up  occurred
from January 1979 to November 1979.

     The  response  began  on  January 6, 1978, the day of
the fire, when the City of Minneapolis built two temporary
sand  dams  on  Ryan  Creek,  east  of the Soo Line Access
Road,  to  contain  the  contaminated  water.  During  the
following seven  days, after  most of  the water  had been
absorbed into  the  stream bed  and  the water  remaining on
the  surface had  frozen, a  contractor hired by MPCA con-
structed a diked,   plastic-lined containment  area on  the
Soo Line property and placed the contaminated ice and snow
from the stream bed and the Howe property  in  the initial
containment area.   The City of Minneapolis erected a fence
around the containment area.

     Meanwhile,  state and Minneapolis officials  were con-
cerned that air emissions from the fire might have contam-
inated snow down-wind of the  site.   Although sampling  did
not  detect  significant  snow   contamination,  Minneapolis
officials  closed  a  nearby area  to  sledding  and  posted
signs around  the  industrial  area  east  of the  site which
read "Hazardous  Materials,  Keep Out."

     Ten days after the  fire,  the  MDH ordered 11 nearby
residents  to  discontinue   use  of  their  drinking water
wells.   The  City  of  Brooklyn  Center subsequently con-
nected  these  houses  to  the municipal water system.   On
the  same date,  the MDH  contracted with  Barr  Engineering
Co.,   an  engineering  consulting firm,  to investigate  the
level and  extent  of soil  and  ground water contamination
and to evaluate remedial alternatives.

     State  officials  spent  one month seeking a means of
disposing  of  the contaminated ice and  soil, encountering
strong   citizen  opposition  as  each  proposed  disposal
alternative  was  made  public.   In  early  March   1979,  a
contractor  hired   by   MPCA  excavated  1,000  cubic yards
300.65(b)(7)
physical
barriers to
deter spread of
release

300.70(b)(l)
dikes and berms

300.65(b)(3)
security
300.70(d)(2)
provision of
alternative
water supply

300.68(f)
remedial
inve s t igation

300.68(e)(2)
source control
removal
                                     14-4
-------
 (765 cu. m) of contaminated soil from Ryan Creek and lined
 the stream  bed with  sand and  plastic to  prevent spring
 runoff from carrying the remaining contaminants downstream
 or deeper  into the  soil.   The  excavated soil  and  1,600
 cubic yards (1,220 cu. m)  of  ice  and  snow were trucked to
 a  farm  in Martin  County,  Minnesota,   140  miles  (225  km)
 from Brooklyn Center.   The ice and snow  were  placed  in a
 plastic-lined  pit  and  the soil  was  piled  nearby.    Two
 months  later, the  melted  ice  and  snow was sprayed  over
 74 acres  (30 ha)  and  planted  with  corn.   In  September
 1979,  the  contaminated  soil  was  spread over 2.5 acres
 (1 ha) and mixed  with manure to enhance  microbial  break-
 down of the pesticides.

      During the spring  of  1979,  Howe,  Inc. and  owners  of
 some  of the  stored  pesticides removed the remaining
 chemicals and fire debris.

      In  June  1979,   Barr   Engineering installed  four 35
 foot   deep (10.6 m)  ground  water recovery  wells along a
 1,200-foot  (366 m)  section of Ryan  Creek.  Over the  next
 five   months,   almost   90 million gallons  (340  x 10   1)  of
 water were  pumped  from the  wells into  the  Minneapolis
 sanitary sewer system.   The ground water  recovery  system
 was shut down for  the winter in November  1979.   In  August
 1980,  after reviewing ground water sampling data, the  MDH
 concluded that  it  was  not necessary to  resume pumping.

      Currently,  the  State  of Minnesota   is  suing Howe,
 Inc.,  to  recover clean-up costs.
300.70(b)(l)
(ii)(A)
surface seals
300.70(b)(l)
ground water
pumping
 SITE DESCRIPTION

     The  Howe,  Inc. site  occupies  5.3 acres  (2.1  ha)  in
 the  southern  portion of Brooklyn Center, Minnesota,  imme-
 diately west  and  north of the  city  limits  of Minneapolis
 and  Robbinsdale,  respectively.   Figure 1 shows the site's
 location and prominent  surface features  in the  site
 vicinity.   The  following discussions of regional and site
 surface  characteristics and  hydrogeology are  based  upon
 information  presented  in  a  report  by  Barr  Engineer ine
 (1980).                                                  6

 Surface Characteristics

     The most prominent  natural  feature within a one-half
mile  (0.8 km)  radius   of  the  site  is  Ryan  Lake  to the
 south; Crystal Lake to the south, Twin Lakes  to  the  west
 and the Mississippi River to the east are within two miles
 (3.2 km)  of  the  site.   Other nearby  water  bodies  include
Ryan Creek to the east which flows  into  County  Ditch No.
                                     14-5
-------
13 and thence to  the  Mississippi  River.   In general, with
the  exception  of the  Howe site  itself  and  adjacent  Soo
Line  Railroad  properties,  the  dominant  land use  in  the
area  is  residential,   including both single  and  multiple
family dwellings.  The most prominent man-made features of
this  area,  though, are Brooklyn  Boulevard,  a  four-lane
state highway, the  Soo Line Railroad tracks  south  of  the
site, and  the  Soo Line  Railroad's  Humboldt  Yard  east of
Brooklyn  Boulevard.    The  area  of  greatest  potential
contamination  immediately  surrounding  the   fire  site
consisted of  about  60 acres  (24  ha) encompassing  all of
the  Howe property as well  as some  Soo  Line Railroad
property, and  crossed  by  the  Soo  Line  tracks,  Brooklyn
Boulevard  and  Ryan  Creek  (see  Figure  2).    Brooklyn
Boulevard conveniently divides  this  area  into eastern  and
western sections for purposes of further discussion.

     As Figure 2 shows, the western portion of the area of
most  concern  includes the  Howe property,  containing  two
large  fertilizer manufacturing buildings,   the  pesticide
storage building  and  an office building.   The  pesticide
storage building (north building), a one-story wood-framed
structure, was  the  building destroyed by the fire.   The
ground near these buildings slopes gradually from north to
south with a maximum relief of about four to six feet (1.2
to 1.8m).   The lowest  spots  on this western section  are
three storm water catch  basins  eventually draining nearly
all  runoff  north of  the railroad  tracks,  south  of 49th
Avenue North  and west  of  Brooklyn Boulevard  (see Figure
2).   The  southeast and  southwest  catch basins,  in turn,
are hydraulically  connected with  an  underground  concrete
culvert installed to divert overflow  from Ryan Lake under
the  Soo  Line  tracks,  Brooklyn Boulevard,   and  Soo  Line
access road to Ryan Creek.  The western  catch basin does
not  seem to  have an outlet.   As  Figure  2 indicates,
asphalt covers a  limited area around the Howe buildings;
the asphalt extends only to the western catch basin.

     The eastern  section of the  area  of most  concern is
dominated by Ryan Creek, a stream flowing infrequently and
only during heavy rainfall or  runoff.   Ryan  Creek flows
northeastward from the underground culvert  outlet  on  the
east side of the Soo Line access road to 49th Avenue North
and  Russell  Avenue.   At  this intersection, the  stream
flows back  into  another  culvert  paralleling  49th  Avenue
North and reemerges at  Oliver Avenue  and  flows eventually
into County Ditch No.  13.   Otherwise the eastern portion
of the  area in  the  immediate vicinity of the  site is
generally  featureless,   being  flat,  undeveloped,   and
covered with grasses and small brush.
                                     14-6
-------
  Hydrogeology

       Surficial  Geology
       The  surficial  geology of  the  Twin  Cities  area  is
  characterized  mainly by  glacial deposits  of Pleistocene
  age,  in particular  by  those resulting  from the  Superior
  and Des Moines  ice  lobes which covered the area during  the
  late  Wisconsin  phase  of  glaciation.     Both   ice   lobes
  advanced  from the northwest, the Superior  first depositing
  a  sandy  non-calcareous till  and  the  Des   Moines   later
  covering  and  modifying  the Superior  with  a  silty  and
  clayey  calcareous  drift.   Sand-laden meltwater  from  the
  retreating  Des  Moines later formed  a series of coalescing
  outwash plains  called the Anoka Sand  Plain.  After retreat
  of  theses  Moines  lobe, the Mississippi River cut through
  the drift deposits,  forming the present river  valley  and
  leaving  the Mississippi Valley  Outwash deposits.    As a
  result  of these events, the metropolitan  area  is covered
  by  a  surficial  sand and  gravel aquifer,  and  soils  are
  generally sandy  and  well  drained.   The  underlying uncon-
  solidated glacial  deposits  are  an  average 40 to 70 feet
  (12 to 21 m) thick.

      Information  from  soil  borings taken  during  site
  clean-up confirm the site  is covered by a  surficial sand
 and gravel  aquifer  resulting from  the Mississippi  River
 Outwash  and possibly  the  Anoka  Sand Plain.   Below the
 surface of  the  western  portion  of the area,  the  sand and
 gravel  outwash generally  overlies a number  of  dis-
 continuous  fine  organic  swamp  and lacustrine deposits  of
 varying  or   unknown, but  generally  significant,  thick-
 nesses.   The  uppermost  layers are  topsoil  and  miscella-
 neous  fill,   including primarily  silty  sand,  as  well  as
 silty  loam,  debris,  and  trace organics  and gravel.   East
 of  Brooklyn  Boulevard,  the  surficial  geology is  dominated
 by  deposits   consisting  of  clean,  well-sorted  medium  to
 coarse sand,  and some  gravel.   One  isolated deposit  of
 clayey silt  was  discovered  midway along 49th  Avenue North.

     Bedrock Geology
     The  bedrock  geology  of  the   Twin  Cities   area  is
 dominated  by a  sequence of  Ordovician-age  sandstone  and
 dolomite  formations.   The  St.  Peter  Sandstone,   directly
 underlying the  drift  deposits,  averages 150  feet  (45.7  m)
 but varies greatly  in thickness due to  erosion  by inter-
 glacial  and  post-glacial streams.   Some  of these  ancient
 streams  cut  valleys  up to  150 feet  (45.7 m)  deep  through
 the  St.  Peter  Sandstone  and  into  the  Prairie-du-Chien
 dolomites  and sandstones below.   In  general,  the thick-
 nesses  and  elevations of all of the  major  surficial and
bedrock units in the  area vary greatly.  Logs of two wells
within two and  three  miles  (3.2 to 4.8 km)  and northeast

                                     14-7
-------
and east of  the Howe  site,  respectively,   show  thickness
variations of 20, 85,  and  135 feet (6.1,  25.9 and 4.1. m)
for  the  glacial  sediments,  St. Peter  Sandstone  and
Prairie-du-Chien Group, respectively.

     Borings taken  in the  immediate vicinity  of the Howe
site unfortunately  were not  sufficiently  deep to confirm
the presence of these bedrock units.

     Ground Water Hydrology
     The  regional  ground  water  table  in  the  surficial
aquifer  moves   on  a   gradient  of  0.38%  in  an easterly
direction, originating  at Twin  Lakes  and  discharging into
the Mississippi  River.  Wells  near  the  Howe site confirm
the easterly direction  of  flow, but on a gradient of less
than 0.25%.   The depth  of  the ground water table ranges
from  12 to  18  feet  (3.7  to  5.5  m) west  of Brooklyn
Boulevard  and  from 5 to 14  feet  (1.5 to  4.3 m)  east of
Brooklyn Boulevard near the site.

     Generally shallow  (less  than  25 feet,  or  7.6 m, deep)
soil borings prevented  confirmation  of  the  presence  of
till  underneath  the  Howe  site.    Literature  reports  of
borings  taken near  the site  are also inconclusive; there-
fore,  the  degree  to  which  the  till limits vertical ground
water  flow cannot be  ascertained.   In addition,  none of
the  clay seams discovered  in  wells near  Ryan Creek have
been  found to  be continuous and  thus are  not effective
barriers to  vertical  ground  water movement.   If till were
present,  its  70  foot_  (21   m)  thickness   and  hydraulic
conductivity of 3 x 10   cm/sec would make  it  a  relatively
effective  barrier.   Even if  the  till  were absent and  the
surficial  aquifer was hydrologically connected to the  St.
Peter  Sandstone,  the majority  of  ground water  would
probably  flow  horizontally  through  the  more  permeable
outwash  deposits.
WASTE DISPOSAL HISTORY

     No hazardous waste  disposal,  as  such,  occurred  at  the
Howe, Inc.  site.   Rather,  fire  debris  and the water used
to  put  the fire out  became contaminated by the  chemicals
stored  in  the building  and,  in turn,  became  potential
sources  of  surface water,  ground   water,  and  soil
contamination.

     The  fire  started  at  the  east  end  of  Howe's  north
building  on  the morning of  January  6,  1979,   following  a
small explosion due  to a faulty  acetylene  torch being used
in  the  building's   machine  shop.    An inventory of  the
                                      14-8
-------
building's  contents  taken  four  days  prior  to  the  fire
indicated  storage  of  approximately  100 different  pesticide
products  and  six different  fertilizer  products  containing
80  tons (72.5  Mt)  of  active ingredients  (see  Table  1).
One-half  of  the active ingredients consisted  of  a  commer-
cial  product  called  Aatrex 4L,  containing  the  organic
herbicide  atrazine;  another  22 percent  could  be  accounted
for by  another  commercial  pesticide,  Lasso,  containing the
organic  herbicide  alachlor.    Other  pesticide  products
stored  in the  north  building included Furadan,  Thimet,
Lorsban,  and  Dyfonate.   These  substances   are  toxic  to
humans  and  to  certain  plants  and  animals  in  varying
degrees,  but  all  are  potentially  damaging  to  humans  as
well as plants  and animals.

     While area fire  departments  were able  to confine the
fire to the north building and extinguish it  within  a,few
hours,  an  estimated  minimum 500,000 gallons  (1.9 x 10  1)
of  water   was   applied  to  the  blaze  at a  rate  of  2,000
gallons (7,500  1)  per minute.  This  fire water mixed with
the various  pesticide  chemicals  stored inside the build-
ing, and  flowed over  the  asphalt  and frozen  soils around
the building  toward  the  three  catch basins at the site's
periphery  (see  Figure 2).   From  the southeast and south-
west catch basins,  the contaminated  fire water  flowed via
the underground concrete  culvert  to Ryan Creek,  which was
dry at  the time.   The  fire water  ponded  at the  western
catch  basin.    To  prevent  additional  runoff  from  flowing
any  further  along  the  creek,  officials  constructed  an
earthen   dike  across   Ryan  Creek  about 80-100 feet  (24 -
30  m)   downstream  of  the  culvert   outlet.    To  prevent
flooding  of  the Soo  Line  access  road behind  this  dike, a
second  dike  was  built further  downstream  and  the  first
dike was  intentionally breached.  At  day's  end,  the ponded
fire water was  up  to  two  feet (0.6 m)  deep  along  the creek
bed, although  it never actually  reached the  second  dike,
and up  to three  feet  (1  m) deep  near the  southeast  and
southwest  catch basins.   On  the next  day, January 7,  offi-
cials  observed  that  90  percent  of  the water  previously
ponded  in  the   creek  and  near the  three catch basins  had
infiltrated through the soil, leaving 10 percent  frozen on
the surface.
DESCRIPTION OF CONTAMINATION

     As  a  result of the  fire and  the  manner in  which  it
was extinguished,  a great  variety of  sources and  avenues
of  contamination  by  hazardous  substances  was  created.
These are  discussed in the following  in order of  most  to
least  imminent  threat  posed  to  human  health  and  the
environment.

                                      14-9
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                       TABLE 1.   KQWE, CHEMICAL CO. FIRE PARTIAL INVENTORY

                                     (Barr Engineering, 1980)
Conpany
CIBA-GEIGY
MonHanto
Dow
FHC
Dow
PMC
CIBA-GEIGT
CtBA-GBIGT
PPC
Dow
U. Carbide
Shell
American
Cyananld
Btauffer
Elanco
Dow
Stauffer
Product
Aatrex 4L
Laaao
Dow DMA-4
Fur ad an 100
Loreban 15G
Thlodan EM-2
Diaxinon
Dual
Chloro 1PC
Bexton
Bevin SON
Bladex
Thlawt 130
Dyfonate 4B
200
Treflen EC
Dow Pon H
Bradlcane 6.7E
Type
herbicide
herbicide
herbicide
inaecticide
tniecticide
inaecticide
inaecticide
herbicide
herbicide
herbicide
inaecticide
herbicide
inaecticide
inaecticide
herbicide
herbicide
herbicide
Active
Ingredient
atraxine
alachlor
2.4D
carbofuran
chlorpyrlfoa
endoaulfan
diaclnon
M to lac hi or
chloroprophan
propachlor
carbaryl
cyanaxine
phorate
fonofoe
frlflurelln
dalapon
EPIC
Amount of
Product
20,000
8,610 gal.
2,600 gal.
60,400 Iba.
24,350 Iba.
1,764 gal.
800 Iba.
227 gal.
1.500 Iba.
315 gal.
400 gal.
2,000 gal.
240 gal.
1.640 Iba.
30 Iba.
330 Iba.
210 gal.
7,000 Ib.
1,250 lb.
180 gal.
197 gal.
1,930 Iba.
115 gal.
Total Iba.
of Active
Ingredient
80,000
34,440
10,000
8,040
3,652
3,528
1,770
1,890
1,600
1,360
1,312
1,104
1,050
970
788
772
770
Fonwlatlon
liquid (EC)
liquid (EC)
liquid (Anlne
Salt)
granular
granular
liquid (EC)
granular.
WP, liquid
liquid (EC)
liquid (EC)
granular
liquid (EC)
HP
WP, liquid
(EC)
granular
granular
granular
liquid (EC)
liquid (EC)
liquid (Salt)
EC
Active
Ingredient
Acute Oral
LD50 (rata)
3,080
1,800
370
U
163
100
300
2.780
3,800
fio
500
334
3
10
10,000
970
2,000
< Source: Barr Engineering Co. draft report, Auguat 1980)
I
I—1
o
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Air Pollution/Direct  Exposure.

     The  fire  itself  involved the combustion  of  pesticide
vehicle  compounds, many  of which  were organic  solvents,
producing  a dense  smoke containing  volatilized pesticides.
Pigeons  flying through  the smoke  plume  were observed  to
fall dead  immediately,  and a great number of  pigeons  were
discovered  dead  on the Howe  site  the day after  the  fire.
In  addition,  bystanders  reported  intense  respiratory
irritation,  and  11  fire  fighters  became ill  and a  news
reporter  was  hospitalized  due  to  smoke  inhalation.
Fortunately,  the   smoke  plume moved  over a  predominantly
industrial  area  at a relatively  high altitude.   However,
some concern was  voiced over the possibility  that  fallout
from  the  smoke plume  had  contaminated  snow covering  the
off-site  areas  in the  plume's  path,  and  that   children
sledding  in these  areas  would thus be directly exposed  to
the  pesticide  contaminants.   Analysis  of  snow  samples
taken   from  these  areas,  however,  did  not  indicate
dangerous  levels of pesticides.

     Also  of concern  were  the  odoriferous  and irritating
vapors  that could  be  detected emanating  from  the  building
debris, pesticide  residues  and  ice  removal operations  from
blocks  away for  several  days  after  the  fire.    Clean-up
workers  were  not  experiencing  symptoms  at  that  time,
however, and only  the pesticides Endosulfan  I  and  II  could
be detected  in the air samples  analyzed.

     At a  later point during  the ice removal  operations,
however,  several   clean-up  crew  members  complained  of a
burning sensation  on  their  hands,  faces  and upper respi-
ratory  tracts.   These  symptoms  were  treated  successfully
with skin  cream and  respirators,  respectively.   In  addi-
tion ,  the  ice removal  crew foreman  collapsed  on  the  job
and was hospitalized  for  one  day.   The reason  for  his
collapse could not be ascertained.

Contaminated Building Debris

     The building  and other fire debris  on  the Howe  site
was categorized into three  classes:   (1)  high  level wastes
consisting  of  ruptured  pesticide containers or pieces  of
burnt  or  frozen pesticides material;  (2) heavy iron  such
as  burned  trucks; and  (3)   low  level  wastes   such  as
building  rubble.    Only  the  "high  level"  waste   category
above was considered a high priority  disposal  issue by the
state.    Table  2  contains  a  post-fire  inventory  of
chemicals recovered and removed from  the  site.

     As a  result  of the contamination  and  runoff of  fire
water,   the  state  had to  remove  a  total of  1,600 cubic

                                      14-11
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                                    TABLE 2

                                HOWE, INC. FIRE
                   CHEMICALS RECOVERED AND REMOVED FROM SITE
Company
Stauffer
Stauffer
Stauffer
CIBA-GIEGY
CIBA-GIEGY
CIBA-GIEGY
Dow
Monsanto
Product
Dyfonate 10G & 20G
Eptara, Sutan, Eradicane
Thimet 10G
Aatrex 4L
Dual 6E
Diazinon 50W
Telone II
Telone C-17
Lasso
Amount of
Product Recovered
12,225 Ibs.
105 gals.
750 Ibs.
3,425 gals.
540 gals.
900 Ibs.
4,150 gals.
700 gals.
2,520 gals.
Comments

amounts of each not
discernable



approximate


(Source:  Department of Agronomy Services memorandum, Feburary 23,  1979)
                                      14-12
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yards (1,223 cu. m) of  ice  and  snow containing 270 pounds
(123 kg) of atrazine  and 280  pounds (127  kg)  of alachlor,
and  1,000  cubic yards  (765 cu. m)  of surface  soil  con-
taining 300 pounds (136 kg)  of  atrazine  and  700 pounds
(318 kg) of alachlor.

Ground Water and Subsurface Soil Contamination

     Barr  Engineering conducted  a  study  of  ground  water
and  soil contamination  at the  Howe  site  from  January    300.65(b)(5)
through  April, 1979.    Ten soil borings were completed in    sampling
January and February, 1979,  along  Ryan  Creek  and  on the
Howe property  in  areas where  ponding  and/or infiltration
of  contaminated runoff  was  known  or  suspected  to  have
occurred (see  Figure 2).  Eighteen ground  water monitoring
wells  and  one  pumping  well  were  installed  in  the  same
areas in two separate phases  (see Figure  2).   In order to
assess  the  relative  significance of  each pesticide  in  a
sample and to  compare  the relative degree  of contamination
from one sample to  another, an artificial  parameter called
a  "control  ratio"   was  created.   For  a given  sample and
pesticide, the  control  ratio  was  the  ratio  of the concen-
tration measured  in  the  sample  to the standard  set for
that  parameter by the Minnesota  Department   of  Health
(MDH).  A  control  ratio of  less  than one,  then, indicates
that the parameter  does not exceed  the MDH standard.

     Barr  Engineering  (1980)  made  the  following obser-
vations with respect  to the soil test values:

     •  "Soil   samples  from the  borings along  Ryan  Creek
        (B-l,   2,  3,  4, 5, 7)  show  significantly higher
        concentrations  of nearly  all pesticides  under
        analysis than from  the borings near the  Howe, Inc.
        property (B-6,  7, 8, 9 and  10).

     •  "With  few   exceptions,  Thimet  and  Bladex concen-
        trations govern the  control  ratio in  Ryan  Creek
        borings,   although levels  of Atrazine, Lasso,
        Ramrod, Endo  I, Endo  II  and  Diazanon  exceed MDH
        standards  in many samples.

     •  "Bladex  tends  to   govern  the control  ratio  in
        borings near  Howe,  Inc.  property  with  levels  of
        Atrazine,   Thimet   and  Diazanon  exceeding  MDH
        standards  in a few  samples.

     •  "The highest  levels of  contamination,  as measured
        by  control  ratio,   are  from  borings  B-4  and B-5
        which  are  located  along  Ryan Creek and downstream
        from  the   culvert  outlet.   Thimet  and Bladex
                                     14-13
-------
        governs  the  control  ratio  and  results  in   the
        control ratio increasing with depth.

     •  "In borings along Ryan Creek where Bladex tends to
        govern  control   ratios  (B-l,  2,  7)  the  control
        ratio shows the tendency to decrease with depth.

     •  "Control   ratios  in  borings   near  Howe,  Inc.
        property generally  appear  to  decrease with depth.
        Below a depth of 2  to  4  feet  (0.6  to 1.2  m)  in
        borings B-8 and B-9, and 10 to 12 feet (3.0 to 3.7
        m)  to borings  B-6  and B-1Q,  control  ratios   are
        less than unity.

     •  "No obvious correlations appeared to exist between
        soil texture and levels of concentration of any of
        the  pesticides   under  analysis.   There   is  some
        tendency,   however,   for  the  finer  grained soils
        encountered near ground surface  on  the Howe, Inc.
        property  to contain  higher pesticide concentra-
        tions than  the coarser subsoils."

     Barr Engineering made  these  additional observations
with respect  to  ground   water  test values  through April,
1979:

     •  "Monitoring wells on the Howe,  Inc.  site  (P-6,  8,
        10  and  23) shows  significantly  lower concentra-
        tions of  nearly all  parameters  analyzed  in com-
        parison to  wells along  the hanks  of Ryan Creek
        (P-l, 5,  15,  16 and 17).   The  only exception to
        this condition was for Atrazine,  which exceeds MDH
        standards   in  wells  P-8 and  10,   but  in  no other
        monitoring wells within the study area.

     •  "Monitoring wells  nearest  the  culvert outlet  to
        Ryan Creek (P-l, 16, 17,  and W-l) show the highest
        control ratios   encountered  in  the   study  area.
        Bladex,  Lasso,  Ramrod  and Thimet . concentrations
        exceeded  MDH  standards in most  of   these  wells,
        with Bladex generally governing the control ratio.
        The  concentration  of  Bladex,  Ramrod  and  Lasso
        decreases   by  more   than   an  order  of  magnitude
        within the first 20 feet (6.1  m)  of water table.

     •  "Further downstream of the culvert outlet, at well
        P-5, Bladex,  Ramrod and  Thimet  concentrations
        exceed MDH  standards.  However,  the  control ratio
        in P-5 was about one-half  of the control  ratio for
        P-l or P-16.  At P-15, which  is down  gradient  of
        P-5,  only  Bladex  concentrations   exceeded  MDH
        standards.

                                     14-14
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      •   "The  monitoring  wells  south of  Ryan Creek  (P-20
         and 21) were  generally  clean except for  the Bladex
         concentrations  in P-21  which slightly exceeded MDH
         standards.

      •   "The  monitoring  wells  along  49th  Avenue  North
         (P-ll  through  14)  and  north of  Ryan Creek  (P-18
         and  19)  were also  generally clean except  for the
         Thimet  concentrations  in  P-12  which  exceeded MDH
         standards.

      •   "The  rate  and direction of the  movement  of contam-
         inants  or  changes   in  concentrations  with  time
         could  not be strictly  established  with  the  data
         available  through April ,  1979."
PLANNING THE  SITE  RESPONSE
           of Response
Alternative  Water  Supply
     On January  15,  1979,  the  MDH ordered that use  of all
drinking  water  wells  within  a   three-block radius  of the
site be discontinued .   All  houses  in Minneapolis east of
the  site  were  already connected to  municipal water,  as
were most  houses  in  Brooklyn  Center ,  north of the  site .
Consequently,  it was only  necessary to  connect 11  houses
in  Brooklyn  Center  to municipal  water to  ensure  that
residents were not  exposed  to  contaminated  drinking  water.
As  ground  water monitoring  had   not  yet  begun, the  MDH's
order  was  based  on very  limited data  on  the extent  of
contamination.   The only   sampling  data   available  at the
time of the  order was for  ice,   which was found to contain
as  much as  5,200  mg/1 of   atrazine.  The   MDH concluded
that in light of the larger  volume  of contaminated  water
that had been  absorbed  into the  highly permeable  soil,  it
was prudent  to err  on the  side of caution and  close  nearby
wells.    Later,   monitoring  revealed  that  ground   water
contamination  was   limited  to  the area  along  Ryan  Creek,
and  that   the  closed  wells   were  hydrogeologically
upgradient from  the contamination.

Ice , Snow, and Soil Removal
     The MPCA believed  it  was necessary  to  remove contam-
inated  ice  and  soil from the  site   as soon  as possible  to
prevent contamination from spreading.  If temperatures had
risen,  the ice would  have  melted and  possibly  leaked  from
its  temporary  containment  structure.    Runoff  into  Ryan
Creek would  have carried  pesticides  from the most highly
contaminated layer  of soil  near   the'  surface downstream  or
deeper into  the  ground water.  Further,  officials of  the
300.65(b)(2)
alternative
water supplies
300.65(a)(2)
contamination
of drinking
water supply
300.68(e)(2)
source control:
removal
                                      14-15
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City of Minneapolis  and of the Soo Line  Railroad  insisted
that the  State move quickly  to  remove the materials  from
the Soo Line property.

Ground Water Recovery
     In late March,  1979,   the  MDH  decided   to install  a
ground water recovery system  along  Ryan  Creek in  order to
reduce the potential for exposure of   nearby   residents to
hazardous levels of  pesticides.  Although exposure through
drinking water  was  not  a concern since all homes  near  the
site were by this time  connected to municipal  water,  there
was a possibility that  spring runoff would flood basements
along 49th  Avenue North and  carry  pesticides  into homes.
The  MDH  had  no  means  of  assessing  the health  risk to
residents if such an event  were  to  occur  and,  thus, might
have been forced  to  evacuate  any homes that flooded.  The
MDH  viewed  ground  water  pumping as  a means  of  avoiding
this problem.

     A secondary  reason for pumping  ground water  was  that
some nearby residents  used  wells  for  irrigating lawns,
which  posed a  potential  for direct   contact  exposure to
pesticides.    Finally,   there  was a  slim  possibility  that
contaminants  could   have  migrated  to  municipal  drinking
water wells miles away  from the site.

Selection of Response Technologies

     The following subsections describe the identification
and  evaluation of alternative  response   technologies  for
the Howe site.  These descriptions are based upon  informa-
tion presented  in a  comprehensive  review  of events at the
site,  particularly of decisions  made by  the state,
contained in an MPCA file document (undated).

Fire Debris Removal  and Disposal
     As described earlier,  there were three categories of
building and miscellaneous  debris  resulting from  the Howe
fire.   No alternatives  to  the  disposal  methods  outlined
below were  seriously considered  by the  state.  The  "high
level waste" containing ruptured pesticide containers and
frozen or burnt pieces of pesticide material was separated
into identifiable  and  unidentifiable  pesticide products.
Several  pesticide manufacturers  sent  representatives to
the site to identify their  products  so that they  could be
transported  out  of   state for recovery or  disposal.   The
unidentifiable,  usually mixed   pesticide  residues,  were
trucked   to  a  hazardous   waste  disposal  facility  in
Illinois,  because no such  facilities  existed  in Minnesota
and  the  RCRA  regulations   prohibited  its disposal  in  a
sanitary  landfill.   The  heavy  iron  portion  of  the  fire
debris  was  magnetically separated  on-site from  the  rest
300.70(b)(l)
(iiiXO
ground water
pumping
300.68(g)
development of
alternatives
                                     14-16
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and then  trucked  to a nearby foundry where  it  was cut up
and reclaimed  as scrap  iron.    The  remaining  "low level
waste",   mainly  wood   timbers  and  paper  sacks,  was
determined nonhazardous and therefore was disposed of in a
nearby sanitary landfill.

Ice, Snow and Surface Soil Disposal
     A  great number  of  alternatives were  proposed  and
evaluated  for  removal  and  disposal  of   the  contaminated
ice, snow and surface soils.  These are  described below in
approximate order of their consideration.

     1.   Land  Spreading  -  Elk  River Farm Site.    This
         option  involved  trucking  the   contaminated  ice,
         snow and  soil  to  a  farm  site  near   Elk  River,
         Minnesota where  it could  be applied   safely  to
         agricultural  land  like  any  other  agricultural
         chemicals.    The site was  selected above  others
         due  to  its  higher  soil organic  content,  greater
         distance from  surface  water bodies,  and  lower
         slope.    A  number  of  technical  problems  were
         raised  - and some resolved - with  this proposal.
         In any  event, a Commissioner of  Anoka  County,  the
         county  in which  the Elk River   site was  located,
         threatened  to seek  an  injunction if the waste  was
         brought  to  the  county,   thereby effectively
         killing  the  entire  plan.

    2.   Special  Area in a Sanitary Landfill.   This option
         involved  placement  of the contaminated materials
         in  a  specially  designated   area of  a  sanitary
         landfill  with  a sealed bottom.   This plan  was
         rejected  because:    (1)   the   $60,000  cost  of
         preparing the special  area was not  deemed  afford-
         able;  and (2) the MPCA  was  unwilling   to  approve
         the  idea given  that  hazardous  waste regulations
         they were   about  to  promulgate   specifically
         prohibit  such a  practice.

    3.   Sugarbeet Plant.   A  sugarbeet   plant  offered  to
        mix  the  contaminated   ice   and  soil  with  their
        plant  waste  which  was  degraded  in a  series  of
        ponds  and  then sprayed  on  grass  or  alfalfa
         fields.   Calculations  indicated  the  dilution  of
        the  ice  and  soil  in  the  system  would be so  large
        that  no  environmental  or  health   impact  would
        result.   Local  opposition,  however,  killed the
        plan.

    4.  Gasohol.  A  farmer  in  Webster,  Minnesota offered
        to apply  the  ice and  soil to 280 acres (111 ha)
        of corn fields  used solely  for  the  production of

                                    14-17
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alcohol.   While the approval  of  the Rice County
Commissioners  was  carefully sought  and obtained
prior  to  public  knowledge  of  the  plan,  the
farmer's neighbors heard  of it  and  strongly
objected.  The  farmer withdrew his offer.

Incineration  at 3M Company.   3M  Company offered
to  incincerate  the contaminated  ice  and soil at
their Twin Cities  area  facility which is used to
burn organic  wastes.   Although  the incinerator
had  an  operating  temperature  greater  than  the
1,800°F  (982°C)  needed  to  break down pesticides,
the  system's  0.1 second  retention  time  was
determined  insufficient  for  complete waste
decomposition.

Incineration  at  the King Plant.   Northern States
Power  Company  (NSP)  offered  to  incinerate  the
waste  at their  Allen  S.  King  plant on  the  St.
Croix  River.   The  plant  boiler's operating
temperature of  2,800°F  (1,538°C)  and two seconds
of  re tent ion  t ime were  more  than   adequate  to
break down the  pesticides.   A scheme was devised
involving  mixing  of  contaminated  ice  and  snow
with coal in  a 1:99 ratio such that 10 days would
be required to  burn  all of  the waste.   In addi-
tion,  certain  potential   plant  worker  health
problems related to  ventilation were  able  to be
resolved  in  advance.   However, before waste
already  transported to  the plant  could be incin-
erated,  the citizens of the local community,  Oak
Park Heights,  learned  of   the plan  through  the
news media  and  forced  a  special  meeting  of  the
City Council.    The  Council passed  a resolution
forcing NSP to  withdraw its offer to incincerate
the waste.

Out-of-State Disposal.  Failing all  of the above
disposal alternatives,  state  officials devised a
plan to  truck the wastes to a permitted hazardous
waste  disposal   facility in Illinois.   The  plan
would have  involved  two trips by a  convoy of 40
end  dump trucks.   An  emergency  disposal  permit
application for  the waste  to be  trucked was  sub-
mitted  to  the  Illinois EPA.   Before  the appli-
cation could  be reviewed,   however,  Illinois  EPA
officials  decided  not to  grant  the  emergency
permit,  preferring instead to hold  public hear-
ings as in the course of a normal  permit applica-
tion process  in Illinois.   The  minimum advance
publ ic   no t ic e  of  21   days  for  such  hear ings,
however, was  felt  by Minnesota officials to  pose

                            14-18
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          too  great  a risk of melting and leakage  from  the
          stockpiles  of  contaminated  ice  and  soil.

      8.   Land  Spreading - Robertson Farm Site.  As a last
          resort,  the state's  new Commissioner of  Agricul-
          ture  convinced a neighhoring farmer to allow  the
          waste  to be  applied to his  land  in  the spring
          after  the   ice melted.  The  Commissioner was also
          able  to  win the  approval of  local citizens.

Ground Water and  Subsurface Soil Decontamination
      To  address its  several concerns  over potential ground
water  contamination, the state  hired  Barr Engineering  to
conduct  hydrogeologic  studies of  the Howe  fire  site,   to
evaluate  alternative methods to mitigate  contamination,
and  to  recommend  and  implement  the most  promising  such
plan.   Barr assumed that contaminants  in  the subsurface
soils  would  eventually degrade  or  be washed  down to  the
water table where they  could  be controlled or removed.  As
a  result,  further  evaluation of  mitigative measures
focused   on  the  ground  water problem.   Of  the  many
mitigative  methods   evaluated,  barrier  wells,  impervious
barriers,  chemical  treatment  by injection,  and  a single,
large-diameter,  deep  well  proved  to  be  too  costly,
ineffective or  too   slow.   Three methods  were  selected  as
being  potentially most  effective,   including:    (1)  open
pumping  from ditches or sumps; (2) a shallow, low-capacity
well  point system; and  (3)  a  deep,  high capacity,  gravel-
packed well system.

     Barr Engineering  (1980)  provided the following
description of  the  basic  design,  operation,  advantages,
disadvantages and conclusions regarding the three  selected
mitigative methods:

     1)   "Open  ditches  and  sumps  —  continuous   rock  or
         gravel-lined excavations  parallel  to  Ryan  Creek
         with 2 to 1  (horizontal  to  vertical)  side slopes
         and  cut  approximately  10  feet  into  the  water
         table.   This  scheme was  found   to  be  relatively
         impractical for several reasons:

         •  Limited  depth of  intercept ing ground water

         •  High excavation costs

         •  Possibility of accidents from open excavation

         •  Exposure  of  contaminated  waters  to  environment

         •  Extensive areas  scarred  by excavation
                                     14-19
-------
    •  Increased pumping during periods of rainfall
       and runoff.

2)  "Shallow well points — multiple (5 to 10),  small
    diameter  (or  5.1  to  10.1 cm)  (2 to  4  inches),
    well  points  placed several  feet  into the  water
    table and  located  parallel and perpendicular  to
    Ryan  Creek.   This  scheme  was  found  to  be  less
    expensive  and  more  pratical  than  open-pumping,
    but still had several problems.   These were:

    •  Would  not  intercept  ground  water at  depths
       below about 10 to 15 feet (3.0  to 4.6  m)

    •  Difficult  to  control  and  monitor  individual
       well  performances if not using  individual  well
       pumps

    •  Time  required to cleanse  area  of contaminants
       could be long if wells are of low capacity

    •  Discharge piping becomes expensive

    •  High  maintenance costs.

3)  "Deep wells — 3 to 5  screened  and gravel-packed
    wells, 6  or  8  inches  (15 or 20 cm)  in diameter,
    individually  controlled  and  installed  to  some
    depth below  the  water  table  (20  to  30  feet [or
    6.1 to 9.1 m]) along Ryan Creek.  This scheme was
    found to be the most practical.  Major advantages
    were:

    •  Less  expensive  than  ditches  or  sumps —  easy
       installation

    *  Safer than ditches or sumps

    •  Greater  control over  system operation,  cost
       and duration of pumping

    •  More  flexibility  in varying vertical  and
       lateral  extent of  interception, discharge
       rates, local gradient, and drawdown

    •  The ability to  use  the wells  for  field  tests
       to determine aquifer characteristics

    •  More   easily  and  cheaply  protected   than
       numerous well points."
                                14-20
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      As  a result  of these  evaluations,  Barr  Engineering
 recommended the deep-well pump-out  system  for  the  recovery
 of contaminated ground water near Ryan  Creek.

 Extent of Response

 Soil Removal
      The MPCA's contractor excavated 1000 cubic yards  (765     300.68(j)
 cu.m) of  contaminated soil at a depth  of one  to   two  feet     extent of  remedy
 (30-60 cm) from a  900  foot  by 15 foot  (275  x  5m)  area of
 Ryan  Creek  extending  east   from Brooklyn  Boulevard.  The
 MPCA  based  the  extent  of  excavation  on  sampling   data
 available at  the  time  indicating that  the  stream  bed was
 the most  contaminated  area,  and that  soil  contamination
 was concentrated in  the  top  one  to  two feet (30-60 cm) of
 soil,  tapering  off rapidly  with increasing depth.    Soil
 borings  showed  that  the  Howe  property, which was mostly
 paved, was not  heavily  contaminated.   The  MPCA  believed
 that  spring recharge would wash  the remaining  deeper  soil
 contamination  down  to  the water  table  where  it would be
 removed  by ground  water  pumping expected to  begin  later
 that  spring.

 Ground Water Recovery
      Barr Engineering used  a hydrogeological computer
 model  to determine  the most  efficient  size  and design of
 the ground water recovery  system.  Barr analyzed the   soil
 permeability   and  ground  water  gradient   to   predict  the
 number and  spacing  of wells and   the  pumping rate   that
 would  create  sufficient  water table drawdown  to encompass
 the zone  of  significant ground  water contamination.

     The  MDH determined  the  goal of ground  water  pumping
 by establishing  "levels of concern"  for each of the pesti-
 cides  found in  the  ground  water,  intending  to continue
 pumping  until  monitoring  indicated  that  the  contamination
 was below  the  levels  of concern.   The  acceptable levels of
 pesticides  in  ground water were  se't based on  information
 from  three primary  sources:   (1)  "suggested  no adverse-
 effect levels  in drinking water"  developed  by the National
 Academy  of  Sciences;  (2)  "allowable daily  intakes" set by
 the World  Health Organization;  and  (3)  extrapolation  from
 crop  tolerance  levels  established  by  the  Environmental
 Protection Agency.   The National  Academy  of Sciences  no-
 adverse-effect  level  in  drinking water  for  a  particular
 contaminant is  derived   by  combining  the  maximum  no-
 observed-adverse-effect level  from animal studies  with an
 uncertainty factor  to calculate an acceptable daily intake
 (ADI) for humans.  The ADI is then adjusted by  a factor to
 account for a  portion of  exposure anticipated  from drink-
 ing water.   For atrazine  and alachlor,  the  predominant
contaminants,   the  uncertainty  factor is  1,000.    The

                                     14-21
-------
relatively high uncertainty  factor  for  these  two  chemicals
reflects  the paucity  of  toxicological data  on  which  to
base the ADI.

     Because  there were no  established acceptable  levels
of pesticides  in  soil,  it  was necessary to calculate  soil
levels based  on  acceptable ground water levels.  In  order
to make  this calculation,  several  assumptions were made.
First,  it  was assumed  that  the  moisture  content  of  the
soil in question was approximately  15 percent.  Second,  it
was  assumed  that  the  pesticides  in  the  soil  would  be
completely  and rapidly  leached into the ground water  with
the spring  infiltration.   Finally,  it was  assumed that the
pesticides  in the water  component of  the  soil  cannot  be
above  the   acceptable  levels  in  ground  water.   Then  by
multiplying  the moisture  content by the acceptable  ground
water  level  for  each pesticide,  an acceptable soil  level
was obtained.   It should  be noted  that  these levels  are
given  in  micrograms per   liter  of  soil  and  should  be
corrected  for the difference in the density of soil  and
water  if  comparisons are  made with  measured values  (see
Table 3).

     Ground  water  pumping  began  on June  7,  1979. The  MDH
had hoped  to complete  pumping by the  end  of  that  month;
however, contaminant  levels  had  not  been reduced  signif-
icantly by  that  time,  so pumping continued until November
14, 1979.  When pumping stopped  in  November,  the  levels of
most  contaminants in  most  of  the wells  were lower,  but
were  not  all below  the MDH  levels  of concern.   The  MDH
stopped pumping  because of  the  difficulties  of  operating
the system  during  winter,  intending  to  sample ground water
the  following  spring  and  evaluate  the  need  to  resume
pumping.

     The  final ground  water  samples  were  taken in  June
1980.    Contaminant  levels  had  dropped   further in  some
wells,  but had  risen  in  some of  the  easternmost  wells,
which  were  hydrogeologically  down-gradient.     This
suggested  that the  contamination was  migrating  with  the
flow  of  ground   water,  and  that  some  contaminants  had
probably passed  beyond  the effective zone of  influence of
the ground water recovery  system.   In August  1980,  the MDH
decided not  to resume  pumping, concluding that,  since the
ground  water  in   the  Ryan  Creek area  was  not  used  for
drinking  water,  the  levels  of  contamination  present  did
not pose  a health threat.   Further,  there was some doubt
about  whether the reductions  in  contamination  that  had
been  recorded  were even   primarily  attributable  to  the
ground  water recovery  system, or were  instead  a  result of
dilution  caused  by  spring  recharge of  the  contaminated
aquifer.

                                      14-22
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                 TABLE  3.  MINNESOTA  DEPARTMENT  OF  HEALTH LEVELS
                     OF CONCERN  FOR PESTICIDES AT HOWE,  INC.
Common and or
Trade Name
Ethoprop or Mocap
Phorate or Thimet
Diazinon
Malathion
Alachlor or Lasso
Endosulfan I and II
or Thiodan I and II
Cyanazine or Bladex
Propachlor or Ramrod
Chloropyrlfos or
Lorsban
Terbufos or Counter
Atrazine or Aatrex 4L
Chemical Name
0-ethyl S,S-dipropyl
phosphorodithioate
0,0-diethyl S-
C(ethylthio)methyl)
phosphorodithioate
0,0-diethyl 0-(2-
isopropyl-6-methyly-
4-pyrimidinyly)
phosphor othioate
diethyl mercaptosuccinate
S-ester with 0,0-
dimethyl phosphorodithioate
2-chloro-2", 6 '-diethyl-N-
( methoxymethy 1 )
acetanilide
6, 7, 8, 9, 10, 10-
hexachloro-1 , 5, 5a
6, 9, 9a-hexahydro-6,9-
methane-2, 4, 3-benzodiox-
thiepin 3-oxide
2-( (4-chloro-6-(ethylamino)-
s-triazin-2-yl)amino)-2-
methylpropionitrile
2-chloro-N-
isopropylacetanilide
0,0-diethyl 0-(3, 5, 6-
trichloro-2-pyridyl)
phosophor othioate
S-(tert-butylthio)methyl)
0,0-diethyl
phosphorodithioate
2-chloro-4-ethylamino-6-
isopropylamino-s-triazine
Acceptable
Ground Water
Levels, ug/1
1.0
0.7
14.0
160.0
700.0
50.0
2.0
700.0
11.0
2.0
150.0
Acceptable
Soil Levels,
ug/1 of Soil
0.15
0.11
2.1
24.0
105.0
7.5
0.3
105.0
1.7
0.3
22.5
(Source:   Minnesota Department of Health, 1979)

                                     14-23
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DESIGN AND EXECUTION  OF  SITE  RESPONSE

     The  two  major elements of the Howe  site  response  are
covered  in  this section;  they are:   (1) the removal  and
disposal  by  land spreading of the contaminated  ice,  snow
and  surface  soils; and  (2) the decontamination  of  ground
water by  a ground  water  pump-out  system.

Land Spreading  of  Contaminated Ice^ Sjiqw and Surface Soils

     The  following  description of  the design and  execution
of  land  spreading  the Howe site's contaminated  ice,  snow
and  surface soils  is  based  primarily on a January 1981  MDA
summary of these activities.

     A number of potential technical problems were  iden-
tified  and  some  resolved prior   to  land  spreading  the
contaminated  materials.    First,   a  special  and  unpre-
dictably  adverse   runoff   situation  might  occur  if  the
contaminated  materials  were  applied  over a  field  covered
by two feet (0.6 m) of snow.   Second,  the inhomogeneity of
the  contaminated ice  and  snow could produce  a situation in
which pesticide concentrations exceed acceptable  levels in
small  localized areas even though,  on  average,  calcula-
tions  showed  a  safe   application  rate.    Third,   the
inhomogeneity  of  the  contaminated  ice  and  show  applied
would  also  make it impossible to accurately measure  the
crops harvested for  their  suitability for  human consump-
tion.  All three of these potential  problems were resolved
simply by storing  the contaminated materials in  a holding
pit  until  both  the  snow  covering   the fields  and  the
contaminated  ice  and snow  in the  pit  melted.    After  the
contaminated  ice  and snow  melted, the resulting contami-
nated water  could  be mixed to achieve  homogeneity.   One
problem  that  was  not addressed was that  the  contaminated
materials  contained  up   to 60  compounds  in  an  unknown
mixture,   and  that  the  persistence  of  mixtures   of
pesticides in the  enviornment  is  known to be far  greater
than that of  indiv idual pestic ide  compounds.

     On  the  Jim Robertson  farm,   therefore,  a contractor
for MPCA  constructed  a 200 foot long,  20 foot wide and 5
foot (61.0 x  6.1 x 1.5  m) deep   holding pit with  bermed
sides and a bottom  lined  with two  layers  of PVC.   In  late
March,  the  contaminated   ice  and  snow  from  the   fire  site
was  transported  and placed in the pit along with  several
tanker loads  of contaminated  liquid collected at  the  fire
site.  The  contaminated   soil  was  also transported to  the
farm and  piled  in  the holding  area  along the side of  the
pit.
                                      14-24
-------
      In April  of  1979,  the  impounded  ice and  snow had
 begun  to  melt,  and  samples  were  taken  and  analyzed  to
 determine  pesticide  concentrations.   After analysis, the
 contaminated liquid  was  applied  to a  field on  the  farm
 which had been planted  with  corn.  The contaminated water
 was spread  on  the  fields on  seven  separate days  within a
 30-day period during May  and  June,  1979.   A liquid manure
 spreader with  a  2,200  gallon (8,330  1)  capacity  and  20
 foot  (6.1 m)  wide  spread pattern  was  used to  apply the
 liquid.  This equipment  was  necessary  since the pesticide
 mixture was  so dilute  as to  require the  application of a
 relatively large  volume - approximately  2,500  gallons per
 acre  (23,900   1/ha)  in   order  to  reach  pesticide  label
 application  rates.  In  all,  73.5  loads  or 161,700 gallons
 (612,000 1)  of liquid  containing an estimated  162 pounds
 (73.5 kg)  of alachlor  and 16 pounds (7.3 kg)  of atrazine
 were applied over 74 acres  (29.3  ha).   This resulted in a
 pesticide  application  rate  of 0.22  pounds  (0.1  kg)   of
 atrazine and  2.2 pounds  (1,0 kg)  of  alachlor per  acre.
 Soil samples from  this   acreage  were  taken  and  analyzed
 before and after  application of the  contaminated liquid.

      The soil  stockpiled  in  the  hold ing  area  was  also
 sampled and analyzed   for   pesticide  contaminants.     In
 September,  1979,  after  analysis,  the  soil  and  lime  (from
 the fire site containment berms)  were  spread out and mixed
 over the entire  2.5  acres  (1.0 ha) of the  holding  area,
 and large  rocks and  other debris  were  removed by hand.  To
 promote biodegradation  of  the  pesticide compounds,  this
 soil was frequently cultivated and  liquid  hog  manure was
 applied as  a source  of organic matter.   Additional  soil
 samples were taken  and analyzed   to monitor  the  breakdown
 of  the  pesticide  compounds.

      During   crop  growth,   corn  plants  were  visually
 monitored  for symptoms  of chemical  injury.  No  symptoms
 were observed;   the  seedlings grew and  developed  at  a
 normal  rate.   Good weed  control  and  higher yields  were
 observed  in  the   treated  areas.    Leaf  and  ear  tissue
 analyses for pesticides were  negative.

     At  this  writing,  the  74  acre  (29.3 ha)  liquid
 spreading  area  is  being  cultivated  and  produces  normal,
 marketable corn.   The  2.5  acre   (1.0  ha)  soil  spreading
 area,  however,  is still  being cultivated with manure  and
 is  not  used  for crop production.

Ground Water Recovery System

     The deep-well pump-out  system's purpose  was to  remove
contaminated  ground  water in  the  vicinity of Ryan Creek.
Thus,  the  planned  zone of  capture  included  49th Avenue

                                     14-25
-------
North between  Xerxes  and Russell Avenues, and extended  to
the  Soo  Line  Railroad  Yard  south  of  the  creek.   The
assumed maximum  depth of contamination to include in the
capture zone was  25 to 30  feet  (7.6 to  9.1  m).    Optimal
well locations and discharge rates  for  the planned  zone  of
capture were  determined  by computer modeling.    Several
different  well  configurations   and  discharge  rates  were
evaluated, and conservative drawdowns were predicted  along
49th Avenue North  and  the Soo  Line Railroad Yard.  Of the
various well network designs analyzed,  the one that proved
most effective  consisted of  four wells  placed  along the
north bank of Ryan Creek  about 300 feet  (91.4 m) apart and
pumping 100  gpm  (378 1/min)  if the permeability  of the
screened  strata  is 0.025  cm/sec  or 200  gpm (757 1/min)  if
permeability is  0.050 cm/sec  (see Figure 3).   State and
Minneapolis officials  agreed contamination  levels  of the
pumped  ground  water would  allow direct  discharge  to the
sanitary  sewer  system,  thereby  avoiding  the  cost   of
on-site treatment.

     Barr Engineering  obtained a temporary permit  from the
MDNR  to  dewater   the  area  for   the  purpose  of removing
contaminants.  The permit extended  from May 7 through June
30,  1979,  and  was later  extented to June  30,  1980.   The
MDH obtained approval  from  the  Metropolitan Waste  Control
Commission (MWCC)  to  discharge  contaminated  water to the
Minneapolis  sanitary  sewer  system,  which outlets  at the
MWCC Metro Plant in  Pig's  Eye,  Minnesota, for  treatment.
The  maximum  permitted pumping   rate  was 800  gallons per
minute  (3,000  1/min)  for ,all  four wells  or 1.15 x 10
gallons per day (4.35  x 10  I/day).

     The  pumped  ground water was collected via a six-inch
(15.2 cm) PVC  pipe and discharged  via  a eight-inch  (20.3
cm) PVC pipe to  a  catch  basin  at the intersection  of 49th
Avenue  North  and Upton Avenue  North,  accessing the
combined  storm  and sanitary sewer  underlying 49th Avenue
North (see Figure 3).

     The  four  wells  were installed  in May,  1979.  Each
well was  placed with a bottom screen  25 feet  (7.6 m)  below
the  water  table.     Pumping  began  in  June,   1979,  and
extended  five  months  to  November  1979.    The combined
discharge rate of  the  four  wells, as calculated from well
flow meter readings,   averaged 390  gpm  (1,480 1/min), and
for the five months, of operation totalled nearly 990  x 10
gallons (3.75 x  10   1).   Occasionally the wells were shut
down for  repairs  due  to  overheating  or  sediment build-up
inside casings, pumps  and meters.

     Ground water  was  sampled  at two- to four-week inter-
vals from the  four pump-out wells  as well as the  smaller

                                      14-26
-------
      In  April  of  1979,  the  impounded  ice  and  snow had
 begun  to melt,  and  samples  were  taken  and  analyzed  to
 determine  pesticide  concentrations.   After analysis, the
 contaminated liquid  was  applied  to a  field on  the  farm
 which had  been planted  with  corn.  The contaminated water
 was spread  on  the  fields on  seven  separate days within  a
 30-day period during May  and  June,  1979.   A  liquid manure
 spreader with  a  2,200  gallon (8,330  1)  capacity  and 20
 foot  (6.1  m) wide  spread pattern  was  used  to  apply the
 liquid.  This equipment  was  necessary  since  the pesticide
 mixture was  so dilute  as to  require the  application of  a
 relatively  large volume - approximately  2,500 gallons per
 acre  (23,900  1/ha)  in  order  to  reach  pesticide  label
 application rates.  In  all,  73.5  loads or 161,700 gallons
 (612,000 1)  of  liquid  containing an estimated  162 pounds
 (73.5 kg)  of alachlor  and 16 pounds (7.3 kg) of atrazine
 were applied over 74 acres  (29.3  ha).   This resulted in  a
 pesticide  application  rate  of 0.22  pounds  (0.1  kg)  of
 atrazine and  2.2 pounds  (1.0 kg)  of  alachlor  per  acre.
 Soil samples from  this    acreage  were  taken  and analyzed
 before and  after  application of the  contaminated liquid.

      The soil  stockpiled  in  the  holding  area was  also
 sampled  and analyzed   for   pesticide  contaminants.    In
 September,  1979,  after  analysis,  the  soil  and  lime  (from
 the fire site containment berms)  were  spread out and mixed
 over the entire  2.5  acres (1.0 ha) of the  holding  area,
 and large rocks  and  other debris  were  removed by hand.  To
 promote biodegradation  of the  pesticide compounds,  this
 soil was frequently cultivated  and  liquid  hog  manure was
 applied as  a source  of organic matter.   Additional  soil
 samples were taken  and  analyzed  to monitor  the breakdown
 of  the  pesticide  compounds.

     During  crop  growth,   corn  plants  were  visually
 monitored  for symptoms  of chemical  injury.  No symptoms
 were observed;   the  seedlings grew and  developed  at  a
 normal  rate.   Good weed  control  and  higher yields  were
 observed  in  the   treated  areas.    Leaf  and  ear  tissue
 analyses  for pesticides  were  negative.

     At  this  writing,   the   74  acre  (29,3 ha)  liquid
 spreading  area  is  being cultivated  and  produces  normal,
marketable  corn.   The  2.5 acre  (1.0  ha)  soil  spreading
 area,  however,  is still  being cultivated with manure  and
 is  not  used  for crop production.

Ground Water Recovery System

     The deep-well pump-out system's purpose  was  to remove
contaminated  ground  water in  the  vicinity of Ryan Creek.
Thus,  the  planned  zone  of  capture  included  49th Avenue

                                     14-25
-------
North between  Xerxes  and Russell Avenues, and extended  to
the  Soo  Line  Railroad  Yard  south  of  the  creek.   The
assumed maximum  depth of  contamination to include in the
capture zone was 25 to 30  feet  (7.6 to  9.1  m).    Optimal
well locations and discharge rates  for  the planned  zone  of
capture were   determined  by computer modeling.    Several
different  well  configurations  and  discharge  rates  were
evaluated, and conservative drawdowns were predicted  along
49th Avenue North  and  the Soo  Line Railroad Yard.  Of the
various well network designs analyzed,  the one that proved
most effective consisted  of  four wells  placed  along the
north bank of  Ryan Creek  about 300 feet  (91.4 m) apart and
pumping 100  gpm  (378 1/min)  if the permeability  of the
screened  strata  is 0.025  cm/sec  or 200 gpm (757 1/min)  if
permeability is  0.050 cm/sec  (see Figure 3).   State and
Minneapolis officials  agreed  contamination  levels  of the
pumped  ground  water would  allow direct  discharge  to the
sanitary  sewer  system,   thereby  avoiding  the cost  of
on-site treatment.

     Barr Engineering  obtained a temporary permit from the
MDNR  to  dewater the  area  for   the  purpose  of removing
contaminants.  The permit  extended  from May 7 through June
30,  1979,  and  was later  extented to June  30,  1980.   The
MDH obtained approval  from the Metropolitan Waste  Control
Commission (MWCC)  to   discharge  contaminated  water  to the
Minneapolis  sanitary   sewer  system,  which outlets  at the
MWCC Metro Plant in Pig's  Eye,  Minnesota, for treatment.
The  maximum  permitted  pumping  rate  was 800  gallons per
minute  (3,000  1/min)  for all  four wells  or 1.15 x 10
gallons per day (4.35  x 10  I/day).

     The  pumped  ground water was collected via a six-inch
(15.2 cm) PVC  pipe and discharged  via  a eight-inch  (20.3
cm) PVC pipe to  a  catch  basin  at the intersection  of 49th
Avenue  North  and  Upton Avenue North,  accessing the
combined  storm and sanitary sewer  underlying 49th Avenue
North (see Figure 3).

     The  four  wells were  installed  in  May,  1979.  Each
well was placed with a bottom  screen 25  feet  (7.6 m)  below
the  water  table.     Pumping   began  in  June,   1979,  and
extended  five  months  to November  1979.    The  combined
discharge rate of  the  four wells, as calculated from well
flow meter readings,  averaged 390  gpm  (1,480 1/min), and
for the five months, of operation  totalled nearly 990  x 10
gallons (3.75  x  10  1).   Occasionally the wells were shut
down for  repairs  due  to  overheating  or sediment build-up
inside casings, pumps  and meters.

     Ground water was  sampled  at two- to four-week inter-
vals from the  four pump-out wells  as well as the  smaller

                                      14-26
-------
Figure 3. Pumping Well, Discharge Line and Sanitary/Storm Sewer Locations
                         (Barr Engineering, 1980)
-------
  diameter  monitoring wells.   Water levels  inside  the well
  casings  and  selected  well points  in the  area were  also
  monitored  periodically to  ensure  that drawdowns  were  not
  excessive.

      Pumping  was  discontinued in November  until  spring as
  freezing weather  approached and  contamination levels  began
  to decline.   Low  contamination  in  further samples  taken in
 April ^ and June  of  1980  led  the  MDH to suspend  pumping
  indefinitely.


 COST AND FUNDING

 Source of Funding

      Funding  for   the  Howe,  tnc.   c lean-up  came  from  a
 number of sources, including:

 State of Minnesota        (contracting)     $335,564
                           (internal)       $ 59,294
 City  of Minneapolis                        $ 53 575
 City  of Brooklyn Center                    $ 12,000
 Howe, Inc.                                  $ 10 000
                             Total          $470,* 434


      Of  the  state funds,   the largest part was a $152,321    300.62(a)
 emergency   appropriation  from  the  Governor's  Executive    state role
 Council,  made  twelve days  after  the   fire,  after  initial
 containment  measures were complete.  The  balance  of state
 expenditures  came  from the  operating budgets  of  the MPCA,
 the MDH and  the MDA.  A summary  of  the  cost  and  funding
 for  activities  conducted   at  the  Howe Site  is  eiven  in
 Table 4.

      Of the City  of Minneapolis  expenditures, most  were
 sewer charges  for accepting  recovered ground water  into
 the municipal  sanitary  sewer treatment  system.   There  were
miscellaneous  additional  expenditures  totalling  $2,121.
The  City of  Brooklyn  Center  expenditure represents  the
cost  of connecting  eleven houses  to  the municipal water
system.

     The Howe, Inc, expenditure is  a partial  reimbursement
to  the  MPCA  for  initial  containment  work  at  the site.
Howe  did not  contribute further  to  remedial work  outside
the  firm's  property,  although the   company did spend
$215,802 to remove  fire  debris from the company premises.
This  work  is  not  included  in the  figure  for  the total
remedial expenditures.
                                     14-28
-------
       TABLE 4 .  SUMMARY OF COST INFORMATION-HOWE,  INC.,  BROOKLYN CENTER,  MINNESOTA
Task
Initial response
Alternative water supply
Soil excavation
Transportation of Ice 4 soil
(140 mi) (225 km)
Disposal of Ice and soil
Surface water removal
Ground water investigation
HUH sample analysis
Ground water recovery
Ground w.itor treatment
(POTW)
Ground water recovery
system data analysis
Administration
Miscellaneous
TOTAL
Quantity
N/A
11 houses
1,000 cu.yd
(765 cu.m)
2,600 cu.yd
(1,988 cu.m)
2,600 cu.yd.
(1,988 cu.m)
2.1 million
gal Ions
(7.9 million 1)
N/A
N/A
90 mil lion gal.
(340 million 1)
90 million j»al,
(340 million 1)
N/A
4,225 hours
N/A

Expenditure
525,290
S 12, 000
$13,881
$74,273
$49,273
$29,479
$50,000
$12,536
$62,329
$50,169
$24,719
$46,758
$19,727
$470,43'.
Unit Cost
N/A
$l,09l/house
$8/cu.yd.
($10/cu.m)
$28.56/cu.yd
20rf/ru. yd/ml.
($37.36/cu.m)
(16.6^/cu.m/km)
$7. 41-18. 95/
cu. vd.
($9. 69-24. 78/
cu.m)
.014(f/gal
(.0037(
-------
Selection of Contractors

     The first  contractor  hired  for the response at Howe,
Inc. was  Fuel Recovery Company  at  St.  Paul, Minnesota,  a
firm  experienced  in  emergency   oil  and   chemical  spill
clean-ups.  Fuel  Recovery  was first contacted by the U.S.
Environmental Protection  Agency,  and  began work  on con-
taining ice and snow the day  after  the  fire, before it was
clear who would  pay  for the work.   The MPCA,  which had  a
standing emergency response  contract  with Fuel Recovery,
agreed on the  same day to  pay for  the work, and elicited
an  agreement  from Howe,  Inc. to  pay   for  $10,000  of the
expenditures.

     All firms  that  the state subsequently hired  for the
Howe  clean-up  were  contracted   on an emergency  basis,
bypassing  normal  state procurement  requirements,  under
authority  granted  to  the  involved  agencies  by  the
Executive  Council.    All   contracts  were  for  time  and
materials.

     On  January  15,   1979,   the MDH   retained  Barr
Engineering  Company  of Minneapolis to  begin  an investi-
gation of soil and ground water  contamination at the site.
The  investigation was  estimated to cost  $50,000,  and  it
was understood that further  expenditures might be required
if the study found that remedial work was necessary.

     C.S.  McCrossan,   Inc.   of  Osseo,   Minnesota,  was   an
excavation  contractor  originally  subcontracted by  Fuel
Recovery to  excavate ice  and build the containment
structure, during  the  initial  site  response.   Five weeks
later,  the  MPCA   contracted  directly  with McCrossan   to
excavate contaminated   soil  from the  bed   of  Ryan  Creek,
line the  stream bed with  sand  and  plastic,  and load the
ice and  soil  for  transport.  The  contract was  limited  to
$15,000.

     In late January  1979, the  MPCA hired Scrap Haulers,
of  Riverdale,  Illinois,  to  secure an Illinois disposal
permit and to haul the  ice  and soil  to  an  Illinois hazard-
ous waste  landfill.   This  disposal  option was  rejected  a
few weeks later  in favor of  land spread ing, but  the state
paid  Scrap  Haulers  for some administrative  and  testing
expenditures.

     In February  1978,  the MPCA  contracted with James  F.
Robertson,  the  owner  of a  hog farm in Martin County near
Huntley, Minnesota, for the use  of approximately 77 acres
(31 ha)  for  landspreading  contaminated ice and composting
contaminated soil.  The state agreed to pay Robertson $100
per  acre  ($247/ha)  for landspreading,  and $300  for  the

                                     14-30
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 area  occupied  by a  containment  basin  and  contaminated
 soil.  The state  further promised  that  the materials  would
 not  pose  a  health  hazard,  that   the  pesticides  in  the
 melted ice would  be  spread  at  normal agricultural rates,
 that  the  state  would pruchase  Robertson's  corn if it  was
 found  to  be  contaminated,  and  that   the   crop   of  the
 following year would not be  adversely affected.  Robertson
 agreed to  spread  the water  when it  melted,  and to culti-
 vate the contaminated soil with  liquid manure from  his  hog
 farming operation.

      The MPCA contracted with  Robertson after exploring  a
 number  of  other   disposal  options,  each  of   which  was
 rejected because of high cost or local citizen opposition.
 The MPCA  located  Robertson  through  his  neighbor,  who  was
 the Minnesota Commissioner  of  Agriculture,  and  who helped
 to allay local concerns about the waste materials.

      The MPCA hired G&T Trucking Co. of Elko, Minnesota to
 transport  the  ice  and soil from  the  Howe  site  to  the
 Robertson farm,  a distance of 140 miles (225 km).   G&T  was
 hired on the basis of  the  competitive rates  they charged,
 and because  the  firm was  a licensed  hazardous materials
 transporter.

      In late February 1979,  the  MPCA hired  W. Hodgman  and
 Sons,  Inc.,  an   excavation  contractor  in  Fairmont,
 Minnesota,  to construct  a  containment  basin  for  ice  and
 snow at the  farm.   Hodgman was  selected  because  the  firm
 was located near the  farm,  reducing the cost of transport-
 ing equipment and  personnel.   The  MPCA  hired  H.R.  Loveall
 Construction, Inc.,  of  Winnebago,  Minnesota, to backfill
 the  the  containment  basin  after  it was  emptied  and  to
 spread  the   contaminated   soil   for  composting.    Again,
 Loveall was  selected  because the firm was located near  the
 farm,  reducing transportation costs.

 Project  Costs

      The  total  cost  of   the  Howe,  Inc.  clean-up  was
 $470,434.    Of  this  amount,  the  two  largest  components
 were:   removal  and  disposal  of contaminated  materials,
 accounting  for  35%  of  expenditures,  and  ground water
 investigation and  recovery, accounting for 42%.

 Initial Response
     The   initial   response  work  at the site  lasted eight
 days,  from  January  6  to  January  13,    1979,   and  cost
 $25,290.    Most  of this amount,  $23,159,  was for  work  by
 Fuel  Recovery,  the MPCA's  emergency response contractor.
 This  work included constructing  a  plastic-lined  contain-
ment  area  and  excavating  and  moving  1,600  cubic yards

                                      14-31
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(1,223  cu.  m)  of  contaminated  ice  and  snow.    Fuel
Recovery's labor charge  for  312  hours  was $8,679, averag-
ing $27.81 per  hour.   Excavation contractors cost $7,786;
lime and sand for lining the containment area cost $5,612,
delivered; miscellaneous costs totalled $1,089.

     The City of  Minneapolis spent $2,121  in the initial
response, including $1,291 for a fence around the contain-
ment area, $401 for a police bomb squad to  remove dynamite
from the burned building,  $279  of warning signs, and $150
for surveying Ryan Creek.

Alternative Water Supply
     The City of  Brooklyn  Center spent $12,000 to connect
eleven  houses   to  the  city  water  system,  or  $1,091 per
house.

Removal and Disposal of Contaminated Materials
     The  total  cost of  excavating,  transporting,  and
disposing of the contaminated ice, soil, and  run-off water
was $166,905.   This  amount  is  broken down by  contractor
expenditures as follows:
City of Minneapolis
C.S. McCrossan
James F. Roberston
W. Hodgman & Sons
Brock-White
G&T Trucking
Loveal1 Cons true t ion
Town of Center Creek
         Total
$  1,286
$ 13,881
$  8,235
$ 31,602
$  6,376
$102,465
$  2,644
$    416
$166,905
     Excavation—C.S. McCrossan excavated 1,00 cubic yards
(765 cu. m) of soil  from a 900 foot by 15 foot (275 x 5 m)
area of Ryan Creek,  stripping off the top one to two feet
(30 - 60 cm) of  soil.  McCrossan  loaded the soil and the
stockpiled  ice  into  trucks  for transport off-site.  After
excavating, McCrossan  covered  the  stream bed with a layer
of sand, placed a 20,000 square foot  (1,858  sq. m), 10 mil
polyethylene  liner  over the  sand,  and  covered  the liner
with  another  layer  of  sand.   Of   the  $13,881  paid  to
McCrossan,  $6,688 was  for equipment rental,  $3,539 was for
labor, $2,595 was for 865 cubic yards (661 cu. m) of sand,
$790  was  for  the  polyethylene  liner,   and  $290  was  for
protective  clothing.

     The available data  are  insufficient to enable calcu-
lation  of  an  exact  unit  cost   for  soil  excavation  and
loading, since McCrossan  performed  a few tasks  simultane-
ously.    However,   a  resaonable  estimate   is   that  soil
                  300.70(c)(2)(i)
                  offsite
                  transport:
                  excavation
                                      14-32
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 excavation   and   loading  cost  about  $8  per  cubic  yard
 ($10.97  cu.  ra).

      Transportation—The  state   paid G&T Trucking $102,465
 for  transporting  contaminated materials.   From March 8 to
 March 16,  1979,  G&T  transported  1,600 cubic  yards  (1,223
 cu.  m) of  ice  and  snow and  1,000  cubic yards (765 cu m) of
 soil 140  miles   (225  km)  to   the  Robertson  farm  in  232
 loads,  averaging  11.2 cubic yards  (8.6 cu. m)  per load.
 G&T  charged $296  per  load, plus a  $410  premium for  ten
 loads transported  on a  Sunday,  totalling  $69,082.   G&T
 charged  an  additional  $559  for  lining trucks with plastic,
 and  $4,632  for demurrage  when  the  contaminated  materials
 froze in the truck beds and  delayed  operations.  The total
 cost of  transporting  the  ice   and  soil  was  $74,273,  or
 $28,56 per  cubic  yard, or 20 cents  per cubic  yard per mile
 ($37.36/cu.  m  or  16.6  Hcu. m/km).

      The state paid  G&T  $28,193  for removing  melt-water
 runoff  from  the  Howe  site.   From February  27 to  April 20,
 1979,  G&T  removed about 2.1 million gallons  (340  x  10  1)
 of   surface  water  from  the  site,  pumping  most  of  it
 directly  into  the  Minneapolis  sanitary  sewers,  and
 transporting some of  it  in tank trucks  to  the  St.  Paul
 sanitary sewer system.  The City of  Minneapolis  incurred
 $1,286  in  treatment costs for  the  water.   The  total  unit
 cost of  removing  and  treating  surface water  was   about
 0.014 cents  per gallon (0.0037  il\)

      Disposal—The  total cost  of disposal  of the contami-
 nated  ice   and   soil  by landspreading was   $49,273.   The
 largest  component  of the  cost,   $31,602,   was paid to
 W. Hodgraan and  Sons  for  constructing a containment basin
 at the  farm  and  for unloading  trucks.  This work took 21
 days,  from February 27 to  March 19, 1979.  The state paid
 James  Robertson,  the  owner  of  the farm, $8,235 for  rental
 of approximately  77 acres  (31  ha)  of land,  spreading  the
 melted ice,  and  applying  manure to the  contaminated  soil.
 H.R.  Loveall  Construction  received  $2,644   for  restoring
 the  basin  site after  it was emptied and for  spreading  the
 contaminated soil  over 2.5 acres  (1  ha).   The state  paid
 Brock-White  Company $6,376  for a 20  mil  45  foot by  280
 foot  (14 x 85 m) PVC liner, including  $5,040  for  the  liner
 itself  and   $1,336  for shipping  and  installation  assis-
 tance.  The  state reimbursed the Town  of Center Creek $416
 for  regraveling a road  leading  to  the  farm.

     Based  on  all  costs  incurred  in  the   landspreading
 operation, the unit cost of  disposal of 2,600 cubic   yards
 (1,988 cu. m)  of  contaminated  ice and soil was $18.95  per
cubic yard ($24.78/cu. m).   However, this figure  is  not  an
accurate representation  of the  cost  of landspreading
300.70(c)
offsite transport
300.70(b)(2)
microbiological
degradation
                                     14-33
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 itself,  since the bulk of expenditures, about 60%, was for
 constructing, lining,  and  later removing  the  containment
 basin.    If  the  operation  had  not  taken placed  during
 winter,  the contaminated materials could  have  been spread
 immediately,  eliminating the need for a storage structure.
 The  cost of the basin  can only  be  approximated,  given the
 available  data, but  was  probably about $30,000.   If  this
 cost  is  not included  in the  disposal  cost  calculation, the
 unit  cost  of disposal would be  about  $7.41 per cubic  yard
 ($9.69/cu.  m),  most  of which was for  unloading  the ice and
 soil,  rental of  the  land,  spreading water, and  treating
 the  soil with applied compost.

 Ground Water  Investigation and  Site Dewatering
     The ground  water  investigation took  place  from
 January  to  May  1979.   Barr  Engineering installed  the
 dewatering  system in late  May  and early  June 1979,  and
 operated it from June  7  to  November 14,  1979, a  total  of
 160  days,   recovering  almost  90 million   gallons  (340  x
 10   1)  from the Ryan Creek area.   Over  the following  nine
 months,  Barr  did  some  addtional sampling,  analyzed  data,
 and produced  a  final  report.

     The  total  cost  of  the ground  water  investigation,
 removal, and  treatment was  $199,753.   The  state paid  Barr
 Engineering  $137,048,  including $50,000   for  the  ground
 water  investigation  and  initial  design of  the dewatering
 system,  $62,329  for  final design, installation and  opera-
 tion  of  the system,   and  $24,719 for  analyzing data after
 dewatering  ceased.   The unit cost of  installing and oper-
 ating  the   system, not including  investigation,  was  0.69
 thousandths  of  a cent  per  gallon  (0.00018  ^/l).    In
 interpreting  the unit  cost, it  is  important to note  that
 over  90% of  the  installation  and  operation  cost  was  for
 final  design  work and  installation,  and of the remaining
 operation cost,  the  majority was for data  analysis.   Con-
 sequently,  the  unit  cost  of  ground water  recovery was
 primarily  a  function  of  the   total  quantity of water
 removed, rather  than  the  cost of  operating the  system.

     The City of Minneapolis paid $50,169  for treatment  of
90 million  gallons (340  x  10  1)  of  water discharged  to
 the municipal treatment works.   The unit cost of treatment
was 0.56 thousandths of  a  cent  per gallons (0.00015^/1).
The  MDH spent  $12,536  analyzing  soil  and  ground water
samples  taken during  the site investigation, the  dewater-
 ing operations,  and after dewatering  ceased.

Administrative Costs
     The state's  administrative  costs  for overseeing the
response at Howe, Inc.  totalled  $46,758.   This  figure  does
not include sample analysis, or  the costs  of cost-recovery

                                     14-34
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 litigation, which  is ongoing.   The  MDH incurred costs  of
 $27,953  for 2,625  hours of  labor,  averaging  $10.65 per
 hour.  The  MPCA  incurred costs of $13,709 for  1,200  hours
 averaging  $11.42 per  hour.    The MDH incurred  costs  of
 $5,096 for 400 hours, averaging  $12.74  per hour.

 Miscellaneous Expenses
      Miscellaneous  expenses  totalled $19,727.   The  state
 paid Scrap  Haulers  $8,702 for the administrative costs  of
 obtaining an  Illinois  disposal  permit,  a disposal option
 that was ultimately rejected.

      In  late  January  1979,  the  state paid  G&T Trucking
 $2,015 for  loading  and  transporting four  loads of  ice  40
 miles (64 km) to the Northern  States plant in  Stillwater,
 Minnesota,   for an  incineration  test,  and  then  for taking
 the  loads back  to   the Howe  site after  public  opposition
 prevented the test  from  taking place.

      In  late  April   1979,  the  state paid  G&T  $6,528  in
 loading and trucking costs and $2,482  in  disposal fees  to
 remove the  emptied  ice  containment   structure at  the  Howe
 site.  G&T loaded and transported 73 truck loads, or  about
 900 cubic yards  (688 cu.  m)  of sand   and lime to a sanitary
 landfill  about 30 miles  (48  km)  from  the  site.  The  unit
 cost of  loading  and  transportation was  $7.25  per   cubic
 yard ($9.48/cu.  m); the  unit  cost  of  disposal was   $2.75
 per cubic yard ($3.60/cu. m).
 PERFORMANCE  EVALUATION

 Delays  in  Ultimate Disposal of Contaminated Ice, Snow and
 Surface Soils

      For the most  part,  state officials  responded  to the
 Howe  emergency clean-up efficiently  and  effectively.   The
 various agencies  involved quickly organized  a task force,
 which was  on the  scene  to make critical  decisions  at all
 the   right  times,  and  continued  to  coordinate  smoothly
 among themselves  throughout  the clean-up period.  However,
 two   related  factors,  neither  fully within  the  state's
 control, caused  substantial delays in  identifying  a means
 and  place  for ultimate  disposal  of  the  contaminated  ice,
 snow  and surface  soils  removed from the  Howe  site.

      First,  Minnesota had  no commercial  facility  for  dis-
 posing  of  hazardous wastes.   Pronounced  public  opposition
had  blocked  proposals  for  siting   new  hazardous  waste
management facilities as far back as 1974.   An  inadequate
plan  for involving the public  prior  to the location deci-
sion has been cited by many  as  one of the chief  causes for

                                      14-35
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the failed  proposal.   Second,  of the first seven  disposal
alternatives  considered  and rejected  by  the  state,  only
one failed  for  technical  reasons.   The  other six  plans,
including  one to  dispose  of  the  wastes  in  a permitted
landfill  in Illinois, were  killed  by  public  opposiition.
In at  least  some of these  cases, it would be fair  to  say
that the degree  of  public concern over the nearby  disposal
of hazardous wastes from an  uncontrolled site  clean-up  was
underestimated by the state.   While decisions  had to be
made in  an atmosphere of  some urgency, it  is clear  that
more planning  to involve  the public, especially to  inform
and educate them  in  advance  of any  disposal decisions,
would  have  assisted in expediting  safe  ultimate  disposal
of the clean-up  wastes.

Effectiveness of  the Ground  Water Recovery System

     Minnesota  officials  deserve  recognition  for  having
established  acceptable levels of  pesticide   contaminants
for both  ground  water and  soil in advance of  ground water
decontamination  operations.    However,  a  number  of ques-
tions  arise  relating  directly  or  indirectly to these
standards:

     1.  To  what  extent   were  ground  water   contaminant
         levels   reduced   further  downstream  in   the
         direction  of flow?

     2.  To  what extent  were   contaminant levels  in  the
         soil reduced?

     3.  To what extent  were  the  standards actually  used
         in deciding when to stop pumping?

     4.  To what  extent was  the recovery  system responsi-
         ble  for the  observed  reductions  in  ground water
         contaminant  levels?

     These questions  are discussed  in turn below.

     First,  at   the   conclusion   of  their  work,  Barr
Engineering (1980)  pointed  out that increases at  the  time
in  the levels of some parameters  in  the  site's   eastern
most wells  correlated  with the predicted  direction  and
rate of ground water  flow  at  the site.   In the 18  months
since  the  fire,  the leachate plume  very likely could have
migrated  from the  area  of  highest initial  ground water
contamination, i.e.,  where  the  fire water  ponded at  the
culvert   outlet   on  the  western  end  of the Soo Line
property,  to  these  easternmost wells.   Barr,  therefore,
recommended that additional  monitoring  wells  be installed
to the east of those wells most easterly at the time (W-4,

                                     14-36
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P-15), and  that  these be monitored until no  further  threat
to  public  health existed.   This  recommendation was  never
implemented,  and therefore, it  is  difficult to determine
whether  ground  water  contamination  eventually  migrated
downstream   away  from  the   site   and  toward   nearby
residential areas.

     Second,  Barr  Engineering (1980)  recommended that
additional 'soil  borings be  taken  in areas  where  MDH soil
contamination  standards  were  exceeded  initially. The
original  assumption  that   pesticides  in  the  soil  would
degrade  or be washed  down  to  the   water  table  was  never
tested .by  taking more  borings  during the course of Barr's
study.   Since this  recommendation was  also  not followed,
it  is  difficult  to  determine  to  what  degree ground water
quality at  the site continues  to be  threatened by signifi-
cant concentrations of contaminants  in the soil column.

     Third ,  as  discussed   earlier,  increases  in  some
contaminants  were observed  in  the easternmost  wells when
samples were  taken  in June  1980.   In addition,  many wells
still  showed  contaminant  levels   above  MDH standards.
Nevertheless,  the MDH decided  not  to resume  pumping, con-
cluding  that  the  contamination  levels  present posed  no
threat to  public health, since  ground  water in  the Ryan
Creek area was not used for drinking water.  This  decision
raises the  question  of  how seriously the  MDH's  levels  of
concern were taken as decision-making criteria.

     Finally,   since  there was  some  evidence of  leachate
plume migration  at  the  site,  it is  difficult to determine
to  what   extent   the  ground   water  recovery  system  was
responsible for  the observed  reductionos in  contaminant
levels in  many wells.   In  addition to migration  of the
leachate  plume,  dilution due to the  spring recharge  of the
contaminated aquifer could have accounted  for some  of the
reduction.
                                     14-37
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                                 BIBLIOGRAPHY


Barr Engineering Co.  August 1980.  Howe, Inc. Fire, Ground water and Soil
     Contamination Investigations, Report to Minnesota Department of Health.
     Minneapolis, Minn.

Barr Engineering Co.  January 1979 to April 1979.  Notes of meetings with
     Minnesota Department of Health concerning Howe, Inc. investigation.
     Minneapolis, Minn.

Breimhurst, Louis J., Executive Director, Minnesota Pollution Control Agency.
     May 14, 1981.  Affidavit in Court File #767822.  Fourth Judical District
     Court, Hennepin County, Minn.

Felt, Russell, Head of Major Facilities Unit, Enforcement Section, Division of
     Water Quality.  Minnesota Pollution Control Agency.  April 12, 1981.
     Affadavit in Court File #767822.  Fourth Judicial District Court,
     Hennepin County, Minn.

Felt, Russell.  December, 1982.  Personal communications with Environmental
     Law Institute.  Minnesota Pollution Control Agency.  Roseville, Minn.

Gray, David, Head, Health Risk Assessment, Environmental Health Division,
     Minnesota Department of Health.  May 7, 1981.  Affidavit in Court File
     #767822.  Fourth Judicial District Court, Hennepin County, Minn.

Gray, David.  January, 1983.  Personal communication with Environmental Law
     Institute.  Minnesota Department of Health.  Minneapolis, Minn.

Kable, Richard, Head, Emergency Response Unit, Division of Water Quality,
     Minnesota Pollution Control Agency.  May 18, 1981.  Affidavit  in Court
     File #767822.  Fourth Judicial District Court, Hennepin County, Minn.

Kalinoski, Stan P., Compliance and Enforcement Section, Division of Water
     Quality, Minnesota Pollution Control Agency.   April 29, 1981.  Affidavit
     in Court File #767822.  Fourth Judicial District Court, Hennepin County,
     Minn.

Kalinoski, Stan P.  February 12, 1979.  Letter to Ross Grotbeck, Minnesota
     Department of Agriculture, re:  sampling at Howe, Inc.  Minnesota
     Pollution Control Agency.  Roseville, Minn.

Kiecker, Glenn D.  November 19, 1979.  Letter to Rollin Dennistoun, Deputy
     Commissioner, Minnesota Department of Agriculture, re:  City of
     Minneapolis costs of Howe, Inc. response.  Pollution Control Division,
     City of Minneapolis, Minn.

                                     14-38
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 Mitchell,  Alan R.   Special Assistant  Attorney General,  Minnesota Pollution
      Control  Agency.   April 15,  1980.  Complaint in Court File #767822.
      Fourth Judicial  District  Court,  Hennepin County, Minn.

 Mitchell,  Alan R.   May 18, 1981.   Plaintiff's Memorandum in  Support of its
      Motion for Summary Judgement,  Court  File #767822.   Fourth Judicial
      District Court,  Hennepin  County, Minn.

 Mitchell,  Alan R.   December, 1982.  Personal  communications  with Environmental
      Law Institute.   Minnesota Pollution  Control Agency.   Roseville,  Minn.

 Minnesota  Department  of Agriculture.   January,  1981.  Land Application of
      Snow, Ice,  and Soil Containing Pesticides  Residues from the Howe, Inc.
      Fire  of  January  6,  1979:  A  Summary  of Monitoring  Activities.   St.  Paul,
      Minn.

 Minnesota  Division  of Procurement.  January,  1979.   Contract for excavation  of
      soil  and  loading of soil  and  ice from Howe,  Inc. fire site.  Department
      of  Agriculture,  APID #30001-19-10.   Roseville,  Minn.

 Minnesota  Division of Procurement.  January,  1979.   Purchase order  for
      construction of  a basin and  handling of  ice,  snow,  and  soil  containing
      pesticides  from  Howe,  Inc. fire  site.  Department  of  Argiculture,  APID
      #30001-19-10.  Roseville, Minn.

 Pettersen, George R.   Commissioner, Minnesota Department  of  Health.   May 14,
      1981.  Affidavit  in Court File #767822.  Fourth Judicial  District  Court,
      Hennepin  County,  Minn.

 Rogosheske, Steven E.   Pesticide  Specialist,  Minnesota  Department of
      Agriculture.  Affidavit in Court File #767822.  Fourth  Judicial  District
      Court, Hennepin  County, Minn.

 Russell, James H.  May 7,  1980.  Letter to Alan  R. Mitchell, Office of  the
     Attorney General, Minnesota Pollution Control Agency, re:  Howe,  Inc.
     expenditures in  fire  clean-up.   Russell, Russell,  & McLeod, attorneys.
     Golden Valley,  Minn.

 Seetin, Mark W., Commissioner,  Minnesota  Department of  Agriculture.  May 8,
     1981.  Affidavit   in Court  File #767822.   Fourth Judicial District Court,
     Hennepin County,   Minn.

Seetin, Mark,  W., et  al.  January 17,  1979.   Memorandum to Executive Council
     re:   Request for  Emergency Funds  Pursuant to Minn.  State. 1974 Sec. 9.061
     Subd. 3  and 5.   Minnesota  Department of Agriculture.  St. Paul, Minn.
                                     14-39
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                                  MARTY'S CMC,
                             KINGSTON,  MASSACHUSETTS
 INTRODUCTION
                                                             NCP
                                                             References
      About 470 drums and buckets of paint sludges,  still
 bottoms,  polychlorinated  biphenyls  (PCBs)   and various
 other  organics  and contaminated   soil  were   illegally
 dumped  on  and  buried  in  a  hillside  behind  an  auto
 dealership named Marty's CMC.   The site is located near
 Kingston,    Massachusetts,   a   small   rural   town  of
 approximately  7,400  people  about  40  miles   (25  km)
 southeast  of Boston on Plymouth Bay (see Figure  1).  The
 neighboring auto dealer who was  concerned  about his on-
 site  Drinking   water   well,   reported  the   dumping,
 prompting  much  concern from  the  town,  which  was  con-
 structing   a new drinking  water  well  field   near  the
 site.   Analysis of the  liquid wastes showed that some of
 them were  highly  flammable.   Slightly less  than 1 mg/1
 dichloromethane  (methylene  chloride) was detected in the
 ground water in  July 1981.

 Background

     From  January  to April  1980,   about 470  drums  and
 buckets  of  hazardous waste and  contaminated  soil  were
 dumped  on  the hill  behind Marty's  CMC (see Figure  2).
 The  wastes  included  paint  sludges,  filter paper residue,
 still  bottoms,  waste oil  and  solvents,  and were  among
 demolition  debris and other material dumped  there.   The
 site  was  discovered when  the neighboring  auto  dealer
 reported midnight dumping  to police who reported it  to
 the  Massachusetts Attorney  General's  (AG)  office,  who
 reported   it   to   the   Massachusetts   Department   of
Environmental   Quality   Engineering   (DEQE)    in  April
 1980.  On April  5,  1980  State Police assigned to the AG,
AG  staff,  additional State  Police,  DEQE  personnel  and
 technicians  from  Black  Gold  Services, Inc.  "raided"  the
site as  the state termed it,  to  inspect and sample  the
chemicals present.   At  this  time, gas chromatograph/mass
spectrometry  (GC/MS)  testing  revealed  a   variety   of
chemicals in the drums and soil, including chlorinated
300.63(a)(4)
discovery
300.6500(1)
evidentiary
sampling
                                     15-1
-------
           Figure  1.   Location Map of  Marty's  CMC  Hazardous Waste
                         Site, Kingston,  Massachusetts
                      3	i*   •
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                                          15-2
-------
                                         MARTY'S-KINGSTON.  MA


                                                     SITE VIEW*  19HU. BEFORE JULY 1981 REMEDIATION
                                                                                                H-

                                                                                               OQ
                                                                                                w
                                                                                                H.
                                                                                                n-
                                                                                                (t


                                                                                                i2

                                                                                                a
•CONSTRUCTS PIOH SECTIONS IN MAT I !>H 1  RHP ANll NAI'S I'UflH JNH 1,81



      ON HETAt DETECTOR
-------
 and flammable  organic solvents.   Some  drums contained
 solids  covered  by  very  alkaline water,  while  others
 contained  flammable  liquids.

     Both  Mr.  Hamilton,  who had a private drinking water
 well downgradient  on the adjacent property, and the town
 of  Kingston,  which  was  planning  to  construct  a  well
 field  about  1/2  mile (0.8  km)  upgradient,  were  very
 concerned  about  the  possible  effect  of  the  hazardous
 waste  on  the  ground water.   In addition,  the  Kingston
 water  tower  is  located  about  1000  feet  (300  m)  from
 Marty's.   Although  the  water  for  this  storage  tank  is
 drawn   from   another  source  several  miles  away,   its
 proximity  to  the   site  prompted  some  of  the  town's
 concern.   At the time Mr,  Hamilton's well  had only  very
 low concentrations  of chloroform, which  were  thought  to
 be  an  equipment  artifact,  but  it was  directly  in the
 apparent  path of  ground water  flow, downgradient  from
 Marty's  CMC.   In July  1981 DEQE  found that  methylene
 chloride was the major  contaminant  in the ground water
 (735, 432  and  134  ug/1  at  48,  78 and  93 feet  (14.63,
 23.67 and  28.35 m),  respectively.

 Synopsis of  Site Response

     From  April  1980  to May  1981,  the  state's  standby
 spill response contractor,  Black Gold Services,  crushed,
 secured or wrapped about  150  empty drums  in plastic, and
 removed  another  99  drums  for examination  and  disposal,
 during  the  spring  and  summer  of 1980.    Through  the
 winter and up  to  the remedial action  in July  1981, Black
 Gold personnel returned  to  the  site several times  to re-
 cover the  drums with polyethylene.

     In   April   1981,   the   state's    hydrogeological
 consultant,  Goldberg  Zoino Associates  (GZA),  began  to
 study  the  nature  and  extent  of the  groundwater  con-
 tamination.  It maintained  and  sampled  the  wells through
 July 1981, when the remedial  action occurred.

     In  July  1981  Oil  and  Hazardous  Materials,  Inc.
 (OHM)   of  Findlay,   Ohio    excavated    and   removed
 approximately 470 drums  and buckets,  and  475  tons  (427.5
Mt) of  contaminated  soil.   Soil with low levels of  con-
 tamination (less  than  10  ug/g  PCBs)  was  capped   and
 reseeded on-site after being aerated by  spreading.   The
 remediated site now  lies open,  with the  only  restriction
 on  it being a prohibition against growing crops.
300.64(a)(2)
preliminary
assessment
300.65(b)(4)
immediate
removal
source control
300.66(c)(2)
(ill)
assessing
migration
potential
                                     15-4
-------
 SITE DESCRIPTION

 Surface Characteristics

      Eastern Massachusetts, where Marty's  is  located,  is
 situated  near  the edge  of the general  geomorphological
 region known as  the  New England province.  This area  of
 the  province  is  relatively  flat,  and  is  covered  with
 temperate  deciduous  second  growth  forest  and marshes.
 The site  is about  1 mile  (1.6 km)  from  the  center  of the
 Town of Kingston (population 7,400).

      The  surface water  lying  closest to the  site  (1,000
 feet 1300 ml northwest)   is  Smelt  Brook,  which  drains
 Smelt  Pond   (3,200   feet  (960   m)   southwest),  and
 ultimately flows out to  Kingston Bay (7,000  feet  2,100
 m  northeast)  through  the Jones River  (see  Figure 1).
 At its  closest approach, Smelt Brook has been altered  to
 support an  area of  cranberry bogs.   The Massachusetts
 state stream use classification for  Smelt Brook is Class
 B.   According to the State Water  Laws  "Waters assigned
 to this class are  designated  for the uses of protection
 and propagation  of fish,  other  aquatic  life and  wild-
 life;   and for  primary  and  secondary   contact  recrea-
 tion."   The influence of Smelt Brook on the ground water
 was found  to  be localized.   The  dominant  influence on
 the ground water flow below the  site is  the ocean.

      Precipitation  in the area averages 41.7 inches  (106
 cm)  per year,  distributed  evenly  throughout  the  year.
 Average summer  and winter  temperatures  are  74° and 22°F
 (23 -6  C),   respectively.     Winds   are  predominantly
 southerly   from  April  to  October,   changing  to  north-
 westerly during  the winter  months.

 Hydrogeology

     The Marty's  GMC  site  is located in an area of  loose
 sandy glacial  till  (see Figures  3  & 4)  of  the Monk's
 Hill  moraine,  which  was  deposited  by  a  pause  in  the
 retreat  of a glacier about 8,000 years  ago,  consisting
 of  a  relatively  thick 90-150  foot  (27-45  m)  sequence of
 stratified  sands,  gravels  and  silts overlying  a  thin
 discontinuous  glacial  till of   course  gravel  and  un-
 consolidated  sediment.     No  bedrock  outcroppings  are
 present within about  1/2 mile  (0.8  km)  of the  site.  The
 glacial  till  is   underlain  by  Dedham Grandiorite,  which
 is  a crystalline  rock  underlying  much  of  southeastern
Massachusetts.    This  bedrock was encountered  at varying
 depths  in  the area.  At  the site  itself,  the bedrock  was
 approximately 105 feet (31.5 m) deep.
                                     15-5
-------
Figure 3-  Location of Test Wells and Borings
                         15-6
-------
Figure 4.  Subsurface Profiles









































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            15-7
-------
     The ground  water  table (Figure 4)  is  located  about
10-15  feet (3-4.5  m)   deep at  the site.   This  ground
water  is  considered to be  in  an upper  aquifer  composed
of  sand  and  gravel extending  from the  surface to  the
fine  sand  and  silt  layer  below,  which  acts  as  an
aquitard allowing  only minimal  ground  water flow.   The
lower  aquifer  is composed  of  medium to course  sand  and
gravel below  the fine  sand and silt layer.  This  lower
aquifer is 7  feet  (2.1 m)  thick at  the  M-l  well  on-site,
and  is  pinched-out by the  thickening  sand  and  silt
aquitard  to   the  northeast.   The  general  ground  water
flow at the site is about 20° to the northeast.

WASTE DISPOSAL HISTORY
     About 470  drums  and   buckets  of  hazardous  wastes,
and approximately 500  tons  (454 Mt) of  contaminated soil
was dumped on a hill behind Marty's CMC  (see Figure  2),
from  about January  to April  1980.   The  actual  amount
dumped is  unclear  since  the case was still  in litigation
as  of October  1982.   State officials  believe  that  the
dumpers  initially  mixed the  wastes with  soil  at  a  lot
down  the  street  and   then scooped  up  the  soil/waste
mixture  to dump behind Marty's.    This  dumping  was part
of  the operation  known as the  "Plymouth  Ring,"  which
dumped hazardous wastes at several sites  in the  area.
The  site  owner,  Marty  Alexandis,  had  a  wetlands  fill
permit, which  allowed  him  to add clean  fill  to  the back
of  his lot on  the  hill.   Mr.  Alexandis  claimed  that he
thought that the drums were empty.

DESCRIPTION OF  CONTAMINATION

      On  April  5,   1980 state   officials   performed  the   300.65  (b)(1)
first  inspection  and  sampling  of  the  site, to  gather   evidentiary
evidence  for  litigation  and  to  assess the  contamina-   sampling
tion.   Gas chromatograph  and mass spectrometry (GC/MS)
analysis   of   the   drum contents   and   soil  revealed   a
variety  of  wastes  including   chlorinated  organics  and
flammable  solvents.   Some  of  the  drums contained solids
covered  with  very  alkaline  water or  low  flash  point
supernatants.   Among  the wastes  found  at the time using
GC/MS were:     dichloromethane   (methylene  chloride),
chlorobenzene,   toluene,   xylene,   n-propanol,   benzene,
ethyl toluene,  trimethyl  benzene,  2-methyl  propanol,
methyl  isopropylbenzene,   ethyl   xylene,   naphthalene,
tetramethyl  benzene,  propanol.   Only  a few  drums were
initially  visible;  more  were discovered  as test pits
were  dug.   Solid waste  such  as reinforcing rods and bed
springs  were  also  found in the fill material.

      Between   the'  April  1980  raid  and May 1981,  the
source of contamination  was estimated  by  test trenches
and  sampling  by  Black Gold  and  DEQE,  and  during the

                                      15-8
-------
hydrogeological  study  by GZA.   Based  on data from  two
test trenches  and  metal detector surveys by Black  Gold,
DEQE  estimated  that  there  were between 400-800  drums
buried  on-site,  and about  300-400  cubic yards  (228-304
m )  of contaminated soil.   Volatile  organics were  the
most predominant contaminant in the  soil, but  during  the
remedial work, PCBs  were also found in  soil at  about 50
ug/g.   The  highest  level  of  PCS  contamination was  62
ug/g,  found  in  otherwise  slightly  contaminated   soil
during  the remedial work.   The depth  of the soil  con-
tamination  at  the toe  of the  slope where liquid  waste
had pooled was found to be  about one foot (0.3 m),  based
on an  ft foot  (2.5 m)  deep soil bore  (A-5) next to  the
multilevel well  (M-l).

Hydrogeological  Study - Goldberg Zoino Associates

     A  hydrogeological  study was  performed by  Goldberg
Zoino   Associates   (GZA)   of   Newton   Upper   Falls,
Massachussets  from  April-July  1981.    To  assess  the
present  and  future  impact  of  the hazardous waste  at
Marty's  GMC, GZA  studied lithologic  and water  quality
data  from  previous well  logs  in the area (Figure  3) as
well  as data  from 5 new observation wells  constructed
near Marty's GMC.   In addition, GZA advised DEQE on the
predicted  impact  of  the  contamination on  the nearby
public  and private wells.   Subcontractors  were used by
GZA  for  the  laboratory  analysis of  volatile organics and
fecal  colifonas, and to prepare  site maps.

     After  studying  the  data  from  the well logs of  the
previous 14 borings in  the  area,  GZA  constructed  5  new
observation  wells near  Marty's GMC.   The location  and
depth  of these wells (M-L, A-l, A-2, A-3,  A-4)  is  shown
in Figure  3  and Table  1,  respectively.   Note  that  the
multilevel  well, M-l,  was constructed  at the  toe of the
dump   slope.     This  most  often  sampled  well  had  an
observation  well sampler at 36  feet  (10.8 m), and  had 3
BarCad gas  drive  samplers  at  47.5,  76.9 and 93.0 feet
(14.25,  23.07  and 27.9  m)  below land surface.  These 5
newly  installed  wells,  as  well  as  the 14  previously
existing wells,  were monitored to establish ground  water
flow directions  and determine water  quality.

     The  water  quality  data  in the  final August  1981
report by  GZA was  based on a  total of  21 ground  water
samples  collected  and  analyzed by GZA on April 21 and 29
and  June  12  and  26,   1981,   from new and  previously
existing wells.   Using gas  chromatograph analysis  (GC),
methylene  chloride was found to be  the most significant
contaminant  in  these  samples.    This   contaminant  was
found   only  in  the multilevel well   located on  site.
Other  contaminants were found  at less  than  50  ug/1  in
                                      15-9
-------
                               TABLE 1.  WELL INVENTORY
Well #
A-l
A-2
A-3
A-4
M-l
B-l
B-2
B-3
B-4
B-5
B-6
B-7
B-9
B-12
B-14
B-16
B-18
32-73
36-74A
TW-1
TW-2
Installed By
Con-Tec for GZA 1
ti
11
ii
it
	 — — — 	
John J. Boyle for BSC
ii
M
it
it
ii
ti
M
ir
M
ii
M
F.G. Sullivan for W&H3
ii
F.G. Sullivan for BSC3
»
Depth Below Land Surface (feet)
77
35
33
25
36*
	 	 _ 	
16
16
32
33
30
57.5
62
42
26
16
26.5
72,5
80
95
95
91
" " — — — -
Note:    *  Multilevel  sampling  installation.  Depth  of
observation well sampler given.

              1.  Wells  constructed  for  MA  DEQE  near
              Marty's CMC

              2. Wells constructed for planned  shopping
              mall

              3. Wells constructed for Kingston town
                   drinking water well
Source:  Goldberg Zoino Associates final report 8/81
                                15-10
-------
this  well,  which was  considered the  reliable  detection
limit.    Volatile organics  were analyzed because  they
were  believed to be  the  most mobile  of the  potential
contaminants.   The  last  ground water  sample  from  the
area  was taken  from  the  multi-level well  on July  15,
1981  by  GZA,  and  analyzed by  OHM  Findlay,  Ohio  labs
using  GC    and  mass   spectrometry   (MS).    This  final
sampling  corroborated  the  earlier  finding of  methylene
chloride  contamination  only  in  the on-site multilevel
well.    Methylene  chloride  levels  were  found  to  be
slightly  higher  in  the  OHM samples  -  735,  432  and  134
ug/1  at  48,  78  and  93  feet  (14,4,  23.4  and  27.9  m)
respectively.  Test  well 36-74A (Figure 3),  located next
to  the  new Kingston water  supply well, was  sampled  and
found to have no detectable volatile  organics.

     The  boring  cores  from  the  test  wells  were  also
analyzed.   This  data  primarily helped  to  clarify  the
underlying  hydrogeology, but  also  suggested that  soil
contamination  was  only  present at  the  M-l  well  on-
site.   This  finding  of  volatile organic  contamination
on-site  in  surface  samples from M-l prompted a  shallow
(8  feet  (2.4  m) deep)  test  boring (A-5)  on-site near M-l
with  "continuous  soil  sampling...  to assess  the vertical
extent  of organic contamination  at  the location  of  the
most  highly  degraded  surficial  soils"  (GZA,  1981).   An
organic  vapor  analyzer (OVA)  measurement of  the  soil
from  A-5 showed  that  the  soil  contamination there  was
the  result  of localized ponding of  contaminated runoff
water and was not expected  to to present a  significant
source  of  ground  water contamination.  As in the ground
water,  methylene  chloride  was   the  most   significant
contaminant but vinyl  chloride,  which was found in water
samples at M-l, was not  found in the  soil  samples.

PLANNING THE SITE RESPONSE

     Clean-up  work   at  this   site  consisted   of   an
emergency response action and a remedial  action.   These
actions are discussed  separately below.

Emergency Response

Initiation o& Response

     The   Massachusetts  Department   of  Environmental
Quality  Engineering  (DEQE)  first  became  involved  in
Marty's  CMC  when the  Attorney  General's  Office  (AG)
asked it  for  technical  support  in  the raid on the site
on  April  5,  1980  to  stop  the  dumping  and  to  gather    300.65 (b) (1)
evidence.   Most  of the information  produced  from  the    evidentiary
raid  was  intended for use  by  the AG in its case.   The    sampling
following  information  was  useful to  DEQE in  assessing


                                     15-11
-------
the physical threat posed by the site:

    1.   A  significant,   but   undetermined  amount   of
         contaminated soil and drummed wastes was buried
         in the hillside;

    2.   A significant amount of waste lay  exposed  in 55
         gallon drums and contaminated soil; and

    3.   Gas chromatograph/mass spectrometry (GC/MS)
         testing  and  drum labels  indicated that  some of
         the wastes were very flammable and toxic.

Based on this  information,  DEQE had Black Gold  return to
the  site  a few weeks later to secure the  surface  drums
because  of   the   threat  of  fire  from  the  drums  of
flammable wastes,  and to dig test  trenches to assess the
need  for future work.
                                             alternatives
Selection of Response Technologies

     The   general   emergency    response
available to DEQE at Marty's were:

         1.   Clean-up work;
         2.   Site assessment; or
         3.   No action.

The DEQE's  decision  to  combine  the action alternatives 1
and 2  was  based on the need  to mitigate  the  fire hazard
and  to assess  the  potential ground  water threat    The
DEQE knew  that the available Spill Fund  money  $100,000
was  not enough to  fully  remediate the site;  hence some
combination of  clean-up  work   and  site  assessment  to
estimate  future work was  needed.   The specific mix of
surface drum  clean-up  and  site  assessment  was largely
based   on   limitations  of  funding and availability  of
information.

     The   clean-up  work  was  limited  to surface  drums
because that  was  all  that  the  available  funding would
allow   and  still  leave  money   for  the  needed  site
assessment.  The surface drum work reduced the  threat ot
 fire but  not  the  threat of  ground water contamination.
The state  official  in  charge of the Emergency  Response
Branch stated that this level of clean-up was based more
 on the amount of money that  was  available, rather  than  a
 need to mitigate a specific hazard to a specific degree.

      The  site assessment primarily involved  digging  test
 trenches  to estimate  the  extent of  the  dumping, because
 that «.  needed to  estimate adequately the  extent of the
 final  remedial  work  needed,   and   also  allow for  the
                                                            300.65(9)(3)
                                                            risk of fire
                                                              300.65(b)(4)
                                                              immediate
                                                              removal
                                                              source control
                                                              300.68(k)
                                                              fund
                                                              balancing
                                       15-12
-------
maximum  amount  of immediate  clean-up  work.   The  use  of
the $100,000  exclusively for site assessment work would
have meant  that no  action  would be taken regarding  the
immediate   mitigation  of   the   threat  of  fire  and,
therefore,  was  excluded.    A  limited  amount  of  metal
detector  investigation  was  undertaken  to  locate  the
buried  drums  on-site.   Test trenches  were  specifically
chosen  because  they  were  relatively cheap  and  adequate
to estimate the extent  of  soil  work needed.  This  also
reserved  resources  for the  clean-up.   In addition,  any
of the  other  possible site  assessment  alternatives,such
as   ground-penetrating   radar,    resistivity   studies,
extensive   test  well  construction  and  monitoring,were
excluded  as  being  unwarranted,  given the  information
available  from  the  AG's  investigation, which  indicated
that only a  short  period of  recent dumping during  the
middle of winter had  occurred on the site.

Extent of Response
     The  emergency  response  ended because the money  ran
out and  the  general response goal  of surface  clean-up
and site  assessment  had  been achieved.   As  a result,  all
of the  exposed  empty drums  were not  removed  from  the
site.   Most of  these drums were  placed on plastic  sheets
pending completion of the rest of the response work.
300.65(c)
immediate
removal
completion
Remedial Action

Initiation of Response
     Because of delays  in getting  funds,  further work at
Marty's did not occur  until  7  months  after completion of
the  emergency  response,  when  Goldberg Zoino  Associates
(GZA)  was  hired  in  February  1981  to  construct  and
monitor 3  test  wells.   As with the initiation of all of
the  remedial  action contracts  (hydrogeological  study,
management consultant,  clean-up contractor),  the timing
of  the  decision  was based  on balancing  the  desire  of
DEQE and  local  interests to have the  site  cleaned up as
soon as possible,  and  the state legislature's desire to
carefully control  the expenditure  of  state funds.  Local
citizen concern had  grown condsiderably  from the time of
the  raid  in  April  1980  until the   site  clean-up  was
completed in July  1981.   However,  the delay through 1980
due  to  deliberations about  the  procedure for  using  the
Capital Outlays Acts limited DEQE's ability  to take  any
remedial action, because  of  lack of alternative  funding.

     When   approval   to  use   $5  million   from   the
Massachusetts Capital Outlay Act was  granted  in January
1981, DEQE decided to hire a hydrogeological  consultant,
Goldberg  Zoino  Associates (GZA),  to  assess  the impact,
if any, of  the  hazardous waste at Marty's  on the ground
                                     15-13
-------
water.    This   possibility  of  contamination  was   of
particular  concern  because  the  town  of  Kingston  had
already sunk  one  drinking water well 1,500 feet (450  m)
from  the  site,  and  was  planning  to  construct more
wells.    Although  this  well  field  was  known  to   be
upgradient  from the  site,  the  hydrogeologist  verified
this  fact  and  then  determined the  potential threat  to
private wells downgradient.   Local  concern  may have also
been heightened by  the proximity of the  town water tank
1,000  feet  (300 m)  from the  site.   The hydrogeologist
provided   information   that   served   to  allay   these
concerns.

     DEQE  was  not  prepared  at  that  time  to    hire  a
clean-up  contractor  because  they  had agreed  with  the
state  legislature  to  contract a  management consultant
first  to  assist and  train  DEQE  personnel  in overseeing
the  clean-up  of  Marty's  and  other  sites  around  the
state, all  of which were to  be  cleaned up with funding
from the Capital Outlay  Act.   This  agreement  was reached
between  the  state  Senate  and  House Ways  and   Means
Committees and  DEQE  during the scheduling  of funds from
the  Capital   Outlay  Act.    The   contracts  for  the
management   consultant   and   the   subsequent   clean-up
contrac tor   were   expec ted   to   be   larger   and  more
complicated  than  the  hydrogeological  consultant's  and
therefore could not be executed as quickly.

     A request  for proposals  for  a  management consultant
was  issued  in February 1981, and Arthur  D. Little, Inc.
(ADL)  was  selected in March  1981.   The  management con-
sultant  was  hired   for  Marty's  to  improve  on  the
efficiency  of  the  clean-up  supervised by  the  DEQE  at
Silresim,  in Lowell,  where  a  site  cleanup  went over
budget and past  schedule.  On May  1,  1981,  DEQE  issued a
request for  proposals for  the  clean-up of Marty's CMC,
which had been  developed in  conjunction  with ADL.  This
action directly initiated  the  final remedial work that
had  been  deemed  necessary  in  the  spring  of  1980  to
eliminate  the  ground water   contamination source,  but
which  had  been delayed  due  to  the  lack of funding.   In
July 1981, O.H. Materials Inc. (OHM) was hired.

Selection of  Response  Technologies

     The  DEQE  directed  its  contractor,  OHM to  combine
excavation  and  disposal  with  aeration  and  capping  in
order  to minimize  disposal  costs.   Only  material that
could  not  be treated  (aerated or biodegraded) was to be
disposed  of  at  an  approved  site.    DEQE  decided  to
excavate  because  the  aquifer under  Kingston is  a sole
source aquifer  for the  town.   It  is the  largest aquifer
of  drinking  water  quality  in  the  state   and  has   the

                                     15-14
300.68(f)
remedial
investigation
-------
 highest flow rate  in  the state.   Exclusive use of other
 technologies - ground water withdrawal and treatment, in
 situ treatment,  encapsulation,  and  complete excavation
 and disposal, was rejected because the technologies were
 considered unwarranted  or unfeasible, or  they  were not
 believed  to  offer the  same  level  of  cost-effective
 ground   water  protection  that  the  excavation-aeration
 option   provided.     The  specific   mix   of  disposal,
 treatment  and  capping resulted from  decisions  made on-
 site based   on  what  was  found   during  excavation  and
 testing.   In practical  terms,  the amount  to be disposed
 was minimized by separating the excavated  material into
 a  high  contaminated  soil pile   (HOP)  and  a  low  con-
 taminated  soil  pile  (LCP).   This soil pile separation
 will be  discussed below, along  with  the  decision  to
 dispose  of  the particular section of PCB  contaminated
 soil, and  the bulking  method that  was  used.

     Defining  the  LCP   vs.  HOP—The  DEQE  decided  to    300.68(h)(l)
 aerate  part  of  the "low contamination soil  pile" (LCP)    screening;
 and leave  it on-site because officials believed that it    cost
 was not a  significant  threat,  and  sought  to  minimize
 disposal costs.   The  separation of the LCP  from the high
 contamination soil  pile  (HCP)  began during  the emergency
 test  trench   excavation,  when  Black Gold  created  the  2
 distinct piles  based on  visual  evidence of  contamination
 (containing   solid  or  wet hazardous wastes).    This
 initial  separation was  part  of DEQE's  overall plan  to
 minimize the  amount of material requiring disposal.

     During  the  remedial phase,  the basis  for separating
 the  LCP  from  the  HCP,  which  was disposed of  at  an
 approved landfill,  was  the  organic vapor level  emitted
 from  the  soil.   O.K.  Materials used  a photoionization
 detector (PID)  calibrated for  organic  contamination with
 uncalibrated  response  for all volatile hydrocarbons.   If
 a PID reading of 20 ug/g or greater was found at  ground
 level when soil was excavated,  then that soil  would  go
 to  the HCP for  subsequent disposal.  The resulting piles
were assessed later for  total organic  carbon  (TOG).   The
TOG  level  of the HCP was about  8,200  ug/g;  the LCP  was
between 1,900-6,400 ug/g (most  soil on the hillside  was
 from 2,400-4,400  ug/g).   By comparison, the  TOG control
of clean, dry sand at the site was  about 500-520 ug/g.

     The DEQE's decision  to leave  the  LCP on-site,  which
was later amended because of the PCB discovery,  was made
without  a  specific  regulatory  framework  because of  the
"emergency" nature of  the work.  Although the RCRA tests
of  ignitability,  reactivity  and  (EP)  toxicity were
performed  and  considered  in the  decision,  according  to
the DEQE's General Counsel  and  the on  scene coordinator,
the decision was based on "professional judgement"  under

                                     15-15
-------
the  state  law  governing  emergency  operations,   which
gives DEQE  authority to  clean  up hazardous waste  sites
using  any  environmentally  safe  means.   The  site  was
cleaned up  by the Emergency  Response Branch because  it
was   the   only   unit   of  DEQE   that  had   sufficient
contracting  expertise.    The  Site  Management Branch,
which  now  deals  with  long  term  clean-ups,   was  not
effectively  operational  at  the  time.   The  use of  the
term "remedial response"  is used in  this report for  the
July 1981 work to  distinguish it  from the 1980  emergency
work.

     The  cost basis  for  the  decision  on  whether   to
dispose of  the LCP off-site was very  clear.   In a Budget
Variance  Report  for  the  period from  July  10 -  16, 1981
OHM  informed  DEQE  that disposal  of the entire  750  cubic
yards  (573  m ;  950  tons;  864.5  Mt)  of LCP would cost
$220,000  (transportation  + disposal  +  15%),  and  would
put  the  project  over   budget.      In  addition,  O.K.
Materials proposed  the alternative  of biodegrading  the
contaminants  out  of  the  LCP  at  a  cost   of  $96,000.
Neither plan  was  used.   As will  be discussed below,  PCB
contamination  of  the  LCP  ultimately  determined  the
extent  of disposal  of the LCP.    The DEQE decided  to
aerate  the  LCP,  which was only  part of  the  proposed
biodegradation plan,  because it  believed  this would  be   in Sltu  SO11
adequate  to  reduce the volatile  organics to  the desired   treatment
extent.    The  DEQE   obtained  "background"  levels   of
volatile organics in the LCP.

     PCBs  in  the LCP—A  relatively  more   complicated
process was  involved  in  the decision to  leave on-site
the  part  of  the  LCP that  contained  7 ug/g or less  of
PCBs.   Black  Gold's  testing during  the  emergency work
did  not  detect any PCBs  on the site.  However, on July
15,  during  the  first  week of  operation,  OHM  performed
PCB  screens along  with pH testing (for compatibility)  of
all  of  the  excavated material,  and  found low  levels  of
PCBs in the LCP  but  none  in the  HCP.  This  prompted  the
DEQE  to  request  a test  to be  run  on  the  material  at
OHM's Findlay-based  lab of  a  composite of 6  samples from
the  LCP.  This test  confirmed the presence  of PCBs  at 19
ug/g.   The  possibility   of hot  spots  of  PCBs  prompted
DEQE to have  OHM split the  LCP  into 8 sections, and take
8  samples (4  sections  on  either side of  a  long,  split
oval)  from  each  section.    These  samples were  split  and
tested by OHM and ADL.  Both  labs found PCBs at about 50
ug/g in 3  of the 8  sections  (OHM/ADL: 61/51,  62/24/42
ug/g) DEQE  had these 3 sections,  which were in one  area,
removed   for  disposal  and  ordered  that  an  extensive
sampling  program be  carried  out  throughout  the site to
make sure that no other  PCB  hot spots had  been missed.
Samples were  taken from 26 locations throughout the site

                                      15-16
-------
 on  July 29th  after  the 3  moderately contaminated  sec-
 tions had been  removed  from the  site.  While the results
 from  these   26  samples  were  awaited from  the  Findlay
 labs,  the  soil  was   aerated by  spreading  it  over  the
 hillside  for 4  days using a front  loader.   The  last
 sample  results  were  called  in to DEQE on  Sunday, August
 2,  when it  was  reported  that no  PCPs over  7  ug/g  had
 been  found.   On  Monday the LCP,  which  had been spread
 thinly  on a  60 x 50  foot   (18 x 15  m) area, was capped
 with 2-3 feet  (0.6-0.9  m)  of soil, followed by a 6  inch
 (0.15 m) cap  that was applied to  the whole site.

     ^Mixing   liquids  into the  HOP—When the  drums  con-
 taining  liquid  hazardous wastes  were excavated  out of
 the hillside, they were emptied  onto and mixed with  the
 HCP,  as  OHM  had recommended.    DEQE  agreed  to   the
 recommended   action  because it  was  feasible  from   the
 standpoint  of liquids compatibility,  and  it was cheaper
 than   bulking   the   liquids  and   transporting    them
 separately  in  DOT-specified  containers.    The  HOP  was
 already slated  for disposal  in a Class I landfill, so it
 was considered  economical   to  combine  the 18  drums of
 liquid  with  the  soil  and avoid  additional  disposal
 expenses.   In  a weekly  report from OHM to  DEQE,  dated
 July 23, 1981,  the  site manager  for  OHM noted  that  the
 18 drums of  liquids   would  not provide  for significant
 economies  of  scale to warrant using a bulk  tanker.   He
 concluded  "since there  were not  enough liquids to  bulk
 together,  that   it would be  more cost effective  to  mix
 the liquids  into  the  highly contaminated  soil  pile  for
 disposal."

     After  the   contents of  the  drums were  poured  out,
 the  drums  were  crushed  with  the  front  loader  and
 disposed of  in  separate  trucks.    The  full   5  gallon
 buckets  were  not  emptied and  separated.    Instead  they
 were  simply  dumped onto the HCP  and mixed  in, because
 unlike  the 55-gallon  drums  they would not interfere  with
 the mixing and loading for the  disposal process.

Extent of Response

     The DEQE ended  the  remedial  operations  because  the
planned   excavation   and  partial   disposal  had  been
accomplished  and,   based   on   the  best   professional
judgement of  its officials,  the site  no longer presented
a  threat to  public  health  or  the  environment.    The
specific decisions regarding the  extent of  disposal  and
the  amount  of   material left  on-site  and  capped   are
discussed  above  in   the "Selection  of  Site Response"
section.  Generally,  the plan  to excavate the  hillside
and  dispose of   the drums,   and all  of the  contaminated
soil  that could not   be decontaminated  adequately  on-
 300.70(b)(2)
 in situ soil
 treatment
300.68(j)
extent of
remedy
                                     15-17
-------
site, was carried out to completion.

     The level  of  volatile organic contamination  in  the
LCP  left   on   site  was  reduced  to   the   "background
level."  The LCP was aerated for four days by  spreading
and respreading  it  using a front-loader, while  awaiting
the results  from the extensive  PCS sampling.   The only
major  surprise,  which   altered  the  planned  completion
date, was the discovery  of PCBs.  As  discussed  above,  by
disposing of  the  soil  having  about  50  ug/g PCB, only
soil with a  PCB concentration of 7ug/g or less  was left
on-site.   This  PCB problem extended  the completion  of
the  clean-up  about  a week,  but did  not significantly
alter the planned clean-up.

DESIGN AND EXECUTION OF SITE RESPONSE

     The  following  technologies were  employed  at  the
Marty's CMC clean-up.

    1.    Emergency   Response   (site  stabilization   and
         assessment)

    2.    Excavation

    3.    Bulking  (drum  opening  and mixing contents with
         contaminated soil)

    4.    Soil Aeration

    5.    Laboratory Analytical Work

    6.    Capping

    7.    Safety Procedures

These technologies will be discussed in turn  below.

     As noted in the section  above, the  clean-up work at
Marty's  was  separated  into  two  distinct   operations:
emergency  response, which  occurred in  April  1980,  and
remedial action, which  occurred from July-August 1981.
These  opertions  will be  discussed  separately in  this
section.    The  emergency  response will  be  considered
briefly  because  of the  relatively small  scale  of  the
operation  and  because  of  the  lack  of  documentation
available.   The remedial  response  will be discussed in
sections according  to the  technology  applied.
                                     15-18
-------
Emergency Response

     The  state's  spill contractor, Black Gold  Services,
Inc.  of  Stoughton,  Massachusetts,  performed  emergency
mitigation work and assessed  the  site  in preparation for
future  work.    It became  involved  in  the  Marty's  CMC
cleanup when DEQE  asked it for backhoes and  technicians
to  assist  in the  April 5,  1980 raid.  On that  day  Black
Gold  personnel  sampled   and   removed  an  undetermined
number of drums to provide the Attorney  General's Office
(AG) with direct evidence  of hazardous waste  dumping on-
site.  A backhoe was used  to prove that  there was buried
hazardous waste on-site.   The  drums that were removed by
Black   Gold   were  placed  in   storage  at   Recycling
Industries of  Braintree,  Massachusetts as  evidence  in
litigation.    Ten of   the  exposed  drums   were removed
immediately because of  the threat of  fire posed by  their
flammable contents, while  89  other full or  partly  full
drums were removed shortly thereafter.   This  initial  9
work-days  of  emergency work  ended on June  3,  when the
exposed drums  had  either  been removed from the site for
evidence  or,   because   of  high   flammability,  had   been
covered with polyethylene (Figure 2).

     On July 22,  Black Gold returned  to the  site to dig
test holes and secure  the excavated soil and drums  that
came  from these holes.   Using 22.6  tons  (20.16 Mt)  of
clay, a staging area  was  created  away  from  the toe  of
the  slope by  spreading the clay and building a  2   /2
foot (0.15 m)  berm around  the  downgrade  side.  This  clay
platform and dike  was  then covered with  polyethylene.   A
month and  a half  later, on September 4-5, 18 drums  were
removed from the  site  and stored prior  to disposal.   A
total of  150  empty,  but  waste-contaminated  drums  were
s tored  in  this area until the remedial action began in
July  1981, when they were removed and disposed of  at  a
landfill.    Black  Gold returned  to the site on 6  more
days  between   September  30,   1980  and May  19,  1981  to
maintain the secured soil  and  drum pile  by  replacing the
polythylene plastic when it deteriorated or blew off.

     The  site  preparation and assessment  work  occurred
in  the  spring  and summer  of 1981.  Black Gold  cleared  a
work  area for the planned  remedial  action  by cutting
down  all  small trees  in  the  future  operating area and
consolidating  all  of  the  uncontaminated tree stumps and
demolition debris  in  a pile  at the west side of the toe
of  the slope.

     An organic  vapor  analyzer,  borrowed  from U.S.  EPA
Region  I, was  used to determine  the  level of contamina-
tion  of  soil  as it was excavated.   Black Gold used its
metal detector to determine the  location  and  extent  of
300.65(b)(l)
evidentiary
sampling
300.65(b)(7)
physical
barriers
                                     15-19
-------
buried  drums  for estimating future work.   Through these
estimates,  the  depth  of the  contaminated fill  and  the
location  of  the buried drums  were determined,  as shown
in Figure  2.   From Black Gold's  work,  the DEQE estimated
that 400-800  drums,  about half  of which  were  empty,  and
300-400  cubic  yards  (228-304 m )  of contaminated  soil
were on-site.
300.66(c)(2)
(ii) assessing
hazardous
substances
jSxcavation

     Preliminary  excavation work for  the  remedial  phase
began on  Tuesday,  July 14, 1981, one  week after the OHM
contract  was  signed  and  the same day that  the site  owner
signed  an authorization  for the  removal.   A  Case  580
backhoe was  used  to move to clean  fill  above the dumped
material  to  prevent  contamination  of  the  soil.   This
fill was  stockpiled  in  a clean  area  for  future use  as
cover.     A  Caterpillar  (Cat)  955  front-end loader  was
used to  consolidate  the contaminated  soil  and crushed
drums in  one area away  from  the toe of the  slope  where
excavation would  occur.   This  Cat  955 was also used  to
c rush  the  emp ty   drums  and  1 oad  them and  the h igh ly
contaminated  soil  separately for disposal.

     The  three-day excavation  operation into the  hill-
side began  on the next day, July 15,  1981, when the Cat
955 front loader,  the Case  580  C backhoe and the Cat 215
backhoe,  with a  grappler attachment,  were  used to  dig
out  the  northeast half  the  staging  area   (See Figure
2).   The excavation of  soil  of the  slope  nearest  the
drums was completed  on  Friday,  July 17,  1980.   A  total
of  1,058  cubic yards  (809  m )  of  contaminated  soil was
excavated.  Air monitoring  that was performed throughout
the excavation is discussed  in the "Chemical Analysis"
section below.

     As   discussed  in  the  "Extent  of  Site Response"
section above, material  was excavated until it showed no
visual  evidence  of  contamination   or  PID   readings  of
greater than  10 ug/g. Excavated soil  was  separated into
2  piles  (high  and  low  contamination)  based  on  PID
readings  of  above or below 20  ug/g.  The piles of con-
taminated  soil   were  placed   on   polyethylene  sheets
depending on whether  PID  readings  of  less  than  or
greater than  20 ug/g were measured  at ground level  above
the source of the  excavated material.

     The  drums were  removed from the hillside excavation
using  the  grappler  attachment to  a  Cat 215  backhoe,
which   is  a  large,  long  armed,   caterpillar-treaded
vehicle.  The grappler attachment to the arm was a claw-
like device  that  rotated 180 degress  and  was especially
designed  for manipulating  55  gallon  drums.   The  drums
300.70(c)(2)
(i)
excavation
                                     15-20
-------
 were  staged  on polyethylene  liners  for  compatibility
 testing prior to bulking and disposal.

 Bulking

      Of  the  151  drums  excavated   from  the  hillside
 (excluding the  144  full  buckets),  59 drums were  "full",
 41  of  which  contained   solids   such  as  filter paper
 residue, and  18 of which contained  liquids.   Of the  92
 remaining drums, some were  stored  off-site as evidence,
 and  some  were  empty  and were  crushed  and disposed  of
 with the other wastes.  As the drums  were excavated  from
 the hillside, they were  sampled  for  compatibility tests
 using  a non-sparking  brass  punch  on  the  Case 580-C
 backhoe to open the drums.  On Friday and Saturday,  July
 17, and 18,  the  following  three  tests were performed  on
 the  contents   to   determine   their  compatibility  for
 bulking:

     1.    pH testing was  performed on the contents  from
          the  18  liquid-filled  drums  to ensure  that  no
          violent exothermic  reactions would  occur  from
          mixing  them together;

     2.    PCB  testing was  performed to  ensure that non-
          PCB  contaminated material was  not  mixed  with
          PCB-contaminated    material,    which   requires
          special regulatory  considerations for disposal;
          and

     3.    Cyanide   testing  was   performed   to   prevent
          cyanide   cross  contamination.      Cyanide    is
          acutely  toxic and may produce  hydrogen cyanide
          gas  when mixed with acid.

All   wastes   were   found   to be   compatible  and  could
therefore be  bulked.   Testing procedures and results  are
discussed in  the "Chemical Analysis" section below.

      Since  the  18 drums of  liquid were  not believed to
constitute  a  large  enough volume to be  cost-effectively
bulked as a  liquid,  they were poured onto and mixed into
the high  contamination  soil  pile  (HCP).   A 10,000 gallon
(38,000  1)  mobile compatibility  chamber was  brought to
the  site but not used.   Instead,  the grappler  equipped
Cat  215  was  used to pour the contents of the  full drums
onto  the HCP.

     The  Case 580C  backhoe was used  to  mix the  liquids
and  solids  from the  59  full  drums  and  the 144  five-
gallon buckets into the HCP for disposal.
                                     15-21
-------
Chemical Analysis

     The chemical  analysis program that was  carried out
by  OHM involved an  on-site  laboratory trailer  and  base
(Findlay,  Ohio)  laboratory  work.    This  sampling  and
analysis  program  occurred from  the  first  day of  site
response to the last day of demobilization.
     At the clean-up  site, testing  was  performed by  hand
held   equipment   and  in  the  on-site  mobile  trailer
laboratory.    Upon  arriving  at  the  site  and  before
beginning  the  excavation  operation,   an  air  scan  was
performed with 4  personal air sampling pumps  with Tenax
and Ambersorb XE-347  adsorbant material.   These  samples
were taken  around the  site and  sent  to the Findlay lab
for  analysis.    Three  mobile  infrared   gas   analyzers
(MIRANS) were used  during the  excavation and  bulking.
These  MIRANS  were  calibrated   for  chlorobenzene   and
toluene,  based  on  the personal  air  sampler  results.
This  MIRANS  monitoring  showed  that  chlorobenzene   and
toluene were  present in the  air  only during  bulking  at
maximums of  0.2 and  0.5  ppm, respectively.    They  were
not detected  during the  excavation.   A photoionization
detector  (PID)  was  used  throughout  the  excavation  and
bulking  to  identify  contaminated  soil.   This PID  was
calibrated  for   aromatic  hydrocarbons,   with  an   un-
calibrated response for volatile hydrocarbons.  A  Drager
portable  air  sampler  was  used   on site  with  specific
sampling tubes for phenol, benzene, cyanide,  toluene and
methylene chloride.  Only  benzene was detectable.

     The mobile analytical trailer  was used on site for
storing and maintaining  this  field  equipment,  as well  as
performing   additional   analytical   work.      A   gas
chromatograph (GC) was  used to screen the  soil for PCBs,
until  a breakdown forced  the  PCS  testing  to be done  in
the Findlay  lab  during the  last  week.   Total organic
carbon  (TOG)  was  also  analyzed  in  the  mobile  lab  to
corroborate the findings of the PID identification.   The
low contamination soil  pile  (LCP)  was also  tested  for
the reactivity  and ignitability  for  RCRA characteriza-
tion (the  EP  toxicity  testing was done  in the Findlay
lab).   Ignitability testing was performed  with a Pensky-
Marten close-up analyzer to identify the flashpoint.

     The   Findlay   lab   provided   additional   testing
facilities for air,  water and soil samples.   A total  of
6 air  samples (including  2 controls)  were analyzed  for
volatile  organics  using  gas  chromatograph   and  mass
spectrometry  (GC/MS).    The  water samples  from  all  4
levels  of  the  M-l  well  on-site  were  analyzed using
GC/MS.   The results  of this testing showed 735, 432 and
134 ug/1  methylene  chloride  present at  48,  78  and  93
feet (14.4, 23.4 and 27.9  m) deep, respectively.

                                    15-22
-------
     The  Findlay   lab   tested  both  the   extract   and
volatiles  present  in  the  LCP   soil.    A  standard  EP
toxicity  extract  was  tested  using  atomic  absorbtion
spectrophotometry  for  arsenic,   selenium  and  mercury.
This extract was  also tested  for chlorinated  pesticides
and chlorinated phenoxy  acid herbicides  using  GC with an
electron capture  detector followed  by GC/MS.    The  soil
was also tested  for volatile  organics by heating it and
running the air through  GC/MS.  In  addition, a GC screen
was done  on the LCP  soil  to screen the soil  for PCB's.
This  GC  gas  elutrient  was  then  split   to  a  flame
ionization detector and  an electron  capture  detector.

Soil Aeration

     After  the  highly contaminated  soil and  drums  were  300.70  (b)(2)
removed  for disposal,   the  remaining low  contamination  (iii)(E)
soil pile  (LCP)  was  spread  at the  toe  of   the  slope to  in situ
enhance  the evaporation of the volatile   organic  con-  treatment
taminants.    As   discussed   in  the  "Extent  of  Site
Response"  section above,  the finding of  low  levels of
PCBs in  the LCP caused  a  hiatus  of several days in the
project   while    additional    samples  were   taken   and
analyzed.   While  awaiting  the results  of  the analysis
and a  decision on the  LCP  disposal,  the Cat  955 front
loader  was  used  to  turn  and   spread  each   of the  8
sections.   This  aeration  process   occurred for  4  days
during this waiting  period,  in an effort to minimize the
standby  time  of  the  front  loader and  operator,  who
remained onsite.   As  indicated by PID readings, volatile
organics  were  at  background  levels at  the end  of the
aeration.

Transportation .and Disposal

     A  total  of 28  truckloads of contaminated soil and  300.70(c)
drums  were hauled 520  miles (825  km)  to  the  Class  I  off-site
landfill  at CECOS  in Niagra  Falls, New York.   Crushed  disposal
drums  (3 truckloads)  and  contaminated  soil  (21 truck-
loads) were transported and  disposed  of separately  from
the  PCB-contaminated  soil   (4   truckloads)  which  was
disposed of in a  double  secure cell  at CECOS.

     The  average  net  weight  of  the loads  was about 17
tons  (15.3 Mt)  instead  of  the  22  (19.8  Mt)  ton rated
truck  capacity  because  the  contaminated  soil  was  too
bulky  to put 22  tons in one truckload.  A 22 ton  load
would  have  occupied  about  16.9  cubic yards (12.94 m ),
which  would have  overfilled  the  13  cubic  yard (9.94 m  )
capacity  trucks.    A conversion  of 1.3  tons/cubic yard
(1.54  Mt/m3)  was  used  by  OHM,  according   to  a company
official.   A  full  13   cubic  yard   load  of contaminated
soil  (9.94 m3) weighed about  16.9  tons (18.6 Mt)  (470

                                     15-23
-------
tons/28  truckloads).    Crushed drums  were  transported
separately in two truckloads on July  18,  1981.

Safety Procedures
     Upon arrival at  the site,  the contaminated area was
separated from  the  neighboring  auto dealer's property by
a  rope  fence,  with colored ribbon surveyor's  tape  and
"dangerous"  placards.    Support  trailers and  equipment
were  located   in   the  designated  clean  area  on  this
neighboring  property.    The  entire  area  of  visually
apparent dumping was  roped off from  the  rest  of Marty's
property a  few days later.   A portable  decontamination
building was  located along  the northern  "contamination
zone boundary"  (see Figure 5.)
     Al1  personne1  entering   the   s ite  donned  se1f-
contained breathing apparatus  and  "moon suits"  before
entering  until  portable  sampler  and   P.I.D.   readings
showed no  detectable air  contamination.   All  personnel
entering  the contaminated zone  were required to  have
prior authorization from the DEQK  and sign  a  site visit
authorization and release  form.  Suits,  tanks  and other
personnel  equipment  were  decontaminated daily  by  OHM
technicians.      O.H.   Materials   also   provided   night
security.

     Cleaning and sealing  of trucks coming from the site
was done to  avoid  contamination of public areas enroute
from the dump  site  to the secure landfill.  All trucks,
backhoes  and   equipment  leaving  the   site   were  de-
contaminated using  a high  pressure  water  laser.  Heavier
contamination on  the buckets,  drum  punch  and grappler
was  removed  using  a  sand  blasting attachment   to  the
water  laser.    Trucks containing  contaminated  material
were  sealed  using  a chemical  sealing  unit,  including
lining and covering of the load with polyethylene.

Capping

     After  the  low contamination  soil   (LCP)  pile  was
aerated  and  the   three  sections   containing  moderate
levels of PCB contamination  were removed, the  remaining
soil  with  low  levels (less  than  7  ug/g)  of PCBs  was
spread and capped before an  additional cap was placed on
the  entire  site.    The  LCP  was spread  on  the hillside
onto  on  a  60  x  50  foot (18.29  x  15.24  m)  area  and
covered with 2-3 feet   (0.61 x 0.91 m)  of soil.   The
entire site  was then capped with 6 inches (21.24 cm) of
native  sandy loam  soil  throughout  the  area  that  had
experienced  contaminated fill  dumping.   Grass  seed  and
fertilizer were then spread  on  the entire site, followed
by straw to prevent intervening erosion.
300.71
worker health
and safety
300.70(b)(l)
surface
seals
                                     15-24
-------
    Figure 5.  Contaminated Zone Schematic
                              O.H.  MATERIALS  CO
                              PROJECT  NO. 436
                              WARTY S CMC  KINGSTON. MAE
                              INITIAL SITE  MAP
Source: 0.5  H.Material
 final report, g/SI
                    15-25
-------
COST AND FUNDING

Source of Funding

     Funding  for the  emergency response  came from  the
Massachusetts Spill Fund  because  it was the only  funding
immediately  available.    (The  Spill Fund was  a $300,000
revolving  fund  that  was  originally  designed for  quick
responses to  oil  spills).  The other  sources  of  funding
that could have been  considered (CERCLA had not yet been
passed), and  the  reasons  that  they were excluded are  as
follows:

    1.   Governor's  Emergency  Account  -  This  fund   is
         only  used  when  all   other  options  have  been
         pursued.    The  director  of  DEQE's Emergency
         Response  Unit  said  that  if  the  Spill  Fund
         turned  out  to be  inadequate  for  the  desired
         level  of  emergency  response,  this fund  might
         have been  used.   The  Spill  Fund was adequate,
         so it was not used.

    2.   Special    appropriation    from    the     state
         legislature - This funding method  had been used
         previously  for  cleaning  up   hazardous   waste
         sites by  obtaining a site-specific  appropria-
         tion.   This  source  was  not  considered viable
         for  Marty's   because  of  political  problems
         between DEQE and the state legislators.

     The  amount of  $100,000   for  emergency  action   at
Marty's provided by  the Spill  Fund was  established as  a
compromise between  taking some emergency action at that
site and  the  imminent need for taking emergency action
at 2-3 other  sites  around the  state.   DEQE  expected that
1/3  of the  $300,000  fund  would   acheive  a  reasonable
level  of  surface clean-up  and site  assessment.    It  is
unclear  if   there  was  a  conscious  attempt  to  evenly
distribute the Spill Fund among 3 sites.

     The Capital Outlay Act  (Acts of 1979,  Chapter 798,
Section 2, Item 2240-8801) was  used to  fund  the remedial
action at Marty's  GMC because  it  was easier  than  using
the only  other  potentially  viable  alternative-a  special
appropriation  from  the  state  legislature.   Although
funds  from  the  Capital  Outlay Act  were  not availbale
until  January 1981,  the  Act  was  designed  specifically
for the type  of  clean-up  needed at Marty's.   CERCLA  had
not yet become a viable alternative and the  dumpers were
virtually bankrupt.    Lawsuits for  cost recovery  would
have taken  too  much  time regardless of their potential
for success.   The Capital Outlay  Act was passed by  the
state  legislature   in November  1979  in an attempt  to
300.62(a)
state-funded
response
300.68(k)
fund
balancing
                                     15-26
-------
overcome  some of  the  problems attendent with  depending
on  special  appropriations  and other funding sources.   It
created  a  $5 million  Fund   for  hazardous  waste  site
clean-ups  that  was allocated  according to  a  schedule
worked out  by the  state House and Senate Way  and Means
Committees.

Selection of Contractors

     DEQE chose  Black  Gold Services,  Inc. to  perform  the
emergency  response  work  because   the  firm  was  DEQE's
emergency  spill   contractor  on stand-by  at  the  time.
Black Gold  had  been placed on  retainer  for a  standard
two year  period  beginning  on  July 1, 1979.  DEQE hired
Black  Gold  on  a  sole  source basis  for  approximately
$100,000 worth of  time  and materials.   Black Gold  was
asked to provide a backhoe and technicans for  the April
5  raid  to  sample  drums and  to  prove that  drums were
buried.   In addition,  it subsequently removed or  secured
the surface drums  to mitigate  the fire threat, and  dug
test trenches  to assess the extent of the buried drums.

     The  DEQE  hired  3  firms  in  the  course  of  the
remedial work  at  Marty's:

    1.    Goldberg Zoino  Associates  (GZA)  was  hired on a
         sole   source basis in  February 1981  to  install
         and sample  5  observation wells as part  of  the
         hydrogeological study of  the area,  and  model
         the impact  of possible ground water contamina-
         tion.    GZA's  work began  in  March  1981 and  its
         first   draft   report   was  submitted  in  June
         1981.    GZA  was  chosen  on  the basis  of  the
         professional judgement of DEQE water pollution
         specialists, who believed that GZA was the best
         hydrogeological firm in the area.

    2.    Arthur  D.  Little   (ADL)  was  hired by DEQE  to
         help  them manage  hazardous  waste site clean-up
         projects  covered   by   the Capital  Outlay Act
         scheduling.  The management consultant contract
         was let  through an  RFP  process  in  February -
        March  1981.     Proposals  were reviewed   by  a
         standing  committee  and   ADL   was  selected  in
        March.   In June 1981, a  contract  was  executed
        with ADL that  included plans for evaluating the
         clean-up contractors1  proposals,  monitoring the
         clean-up progress   and  costs,  and training DEQE
        personnel   to   take over  these  tasks  in the
         future.     In   October  1982,  ADL's  role  had
         shifted  largely to training  DEQE  personnel.
                                    15-27
-------
    3.   O.K. Materials  (OHM)  was hired in July  1981  as
         the  primary  clean-up  contractor  "to  remove,
         transport,  treat,  and   dispose   of   hazardous
         wastes"  at  Marty's CMC,  according to the  RFP,
         which was  released in May  1981.   From  a  field
         of  four  proposers,  OHM was chosen on  the  basis
         of  a multi-criteria  bid  evaluation  procedure
         developed  by   ADL.     The  DEQE  heeded   the
         recommendation  of  ADL,  who   considered   such
         factors  as  qualifications,  technical  approach,
         project  management  and  cost  as well  as "other
         subjective  factors   such  as  reputation   for
         quality work and DEQE's  desire  to use  different
         contractors in  order to  broaden  their base  of
         experience," according to a draft Report of Bid
         Evaluation and  Contractor Selection  by  ADL  in
         June 1981.

     The OHM contract  was  let on a  time and  materials
basis  because DEQE  believed  that  a  fixed price  would
lead  to over-bidding  by  contractors   trying  to  cover
contingencies  for unknown  costs.   Since  the   extent  of
the clean-up work needed was  only roughly known,  state
officials  believed that a  fixed price  would   lock  them
into  a  bid that  covered the  higher  end of the possible
cost  range.    Based  on  the  test  trench  estimates  from
Black Gold's work  in Spring  1980,  the  RFP  estimated  that
there  were  from  400-800 drums  on-site,  about half  of
which were  empty, and 300-400  cubic yards (228-304  m )
of contaminated soil.

     The proposal submitted by  OHM  estimated  the  total
clean-up costs based  on  an actual amount  of work at the
mean  of DEQE's estimate  and  a  detailed  cost  breakdown
chart.  The  daily invoices from OHM were audited by ADL.

Pro j e_c_t_ Cos t s
     The   Massachusetts   Department   of   Environmental
Quality  Engineering  (DEQE)   was   charged  a   total  of
$562,031 (see  Table  2.)  on the Marty's  CMC  clean-up and
directly related  activities  from  April 5,  1980  to August
10,1981.   The  amount DEQE  actually  paid was $551,049
because  of  a  $10,982  discount  for  rapid  payment  of
invoices   for  the  remedial   work.     This  total   cost
excludes administrative  costs within  the  agency,  which
were   estimated   at   about   $400,000,   but   were   not
documented.  Massachusetts  paid  for  the work through its
Emergency  Spill Fund and the Capital Outlay Act of  1979,
as  itemized in Table  2.   About  three-quarters  of the
expense  ($409,000) was incurred  during the month  of July
1981  for the excavation and disposal  of 470  tons (426.5
Mt) of  contaminated soil and 453  crushed drums  and
                                     15-28
-------
                           TABLE 2.   SUMMARY OF COST INFORMATION-MARTY'S CMC, KINGSTON,  MA
 i
ro
Tank
EMtKGtNa RKSl'ONSE
[jifmr
Equipment
Stor.iE..'
Di
S95,750(,l)
(-19!!)

Unit Cost
S19/m,-in hr.
nee cost text
enlry-$20/drum
Sl.OO/drum/
week
$70/drum

NA
NA
$47/<;u.yd.
(61 /ml)
NA
NA
$2300 truck-
load )
(S228/Ht)


Estimated
Future1 Togt
NA
NA
$50,000


NA
NA
ft
6
*
0

i-mi-rncnty
tl-Xt


rundinR
Smircu
Statu Spill
V,,m\
State Kplll
lunJ
State Spill


State Capita
Outlays Ait
COA
St. lit COA
Mt.itii COA
State COA
State COA
Si, Hi! CIIA
sum- COA
SlilLr COA

Period of
Pl'rfr.lln.niLl'
4/5/80-
5/I9/R1
4/5/RO-
i/n/Hi
4/5/80-
5/19/81
4/5/811-
5/19/81

1981
I9B1
7/14-
c!/(./K1
7/8-
B/d/81
7/11-
8/5/81
7/1B-
7/24/81
7/1H-
2/24 /fil
It •)()-
7/ll/H!
7/8-
B/5/81

                               (a)  ADL report for period  7/31 - 8/4/81

                               (b)  Includes 15% added cost for
                                   sub-contractor handling
(c) Actual subtotal paid after discount
   was $408,268.  Variance=$106,732
   (-21%)

(d) Actual total paid after discount was
   $551,049.
-------
buckets.    The  budgeted  ceiling  of  $515,000  for  the
remedial response  was  not reached primarily because  the
amount of  contaminated material found on site was  lower
than  expected.   The discovery  of  PCBs,  however,  raised
the costs.   The emergency work cost $44,468;  the  hydro-
geological   study   cost  $25,000;   and  the   management
consultant cost $80,000.

Labor

     For both  the  emergency and  the  remedial  response
work,  for   which  separate   costs  are  available,   labor
costs accounted  for about 1/3 and 1/4, respectively,  of
the  total   project  phase  costs   (See  Table  2).     The
difference  in  the  proportion  of  the costs  devoted  to
labor reflects  the greater  transportation  and  disposal
costs during the  remedial   response.   The  labor  costs
given  in   Table   2  include  only  primary   contractor
personnel,    i.e.,    Black   Gold   Services,   and   O.H.
Materials.    Since  these  labor  costs  do   not  include
subcontractors   or  administrative  personnel,  the unit
costs   discussed   below  in  the  text  may   be  more
valuable.   The  comparison of actual and projected  labor
usage   was  tracked   by   charts  such  as   Figure   6.
Approximately 3,503  hours of labor was  used during  the
remedial work  by OHM.   This was  less  than the  expected
4,100 hours because  of  the lower  amount  of  material
found.   The labor  cost was  $94,941,  which was $36,771
(29%) less than the $128,712 expected.

Excavation - Remedial Phase

     The   total   costs   of   excavation   activities,   which
occurred on  July  14-17,  1981, were not invoiced  separately,
but  can be  estimated  only  by  correlating  the  time  of the
operation  with  the billings for  the  same period.   On this
basis,  the  total  cost  of   the  4-day  excavation  activity,
excluding  subsequent transportation  and  disposal costs, was
about $49,850  (3/7  x  $86,912  -  July 10-16 weekly  invoice
total),   +  $12,602  (July  17  daily  invoice  total),  including
all  costs   for  the period  (labor,   equipment,  per diem,
analytical  work and  miscellaneous  costs).    The  cost for
mobilization, demobilization and mixing liquids  with  the HCP
is  not  included in this  amount.   The cost  of  simultaneous
sampling and support is included.

     The volume of  drums  and contaminated soil excavated can
be  approximated by adding  the  750   cubic  yards  (573 m  )
estimated  to be  in the LCP, to  the 308 cubic yards (235 m  )
of  non-PCB  material   (non-LCP)  disposed of  from  the HCP.
Hence,  the unit cost  for  excavating3 contaminated soil and
drums was  about $47/cubic yard  ($61/m  ).
                                     15-30
-------
     Figure  6.   Estimated  and Actual Labor Hours in  Remedial Phase
  5000
  4000
  3000
c£
til -
  2000
  1000
                                                               4100 (approx)
                                                                             503
TOTAL ESTIMATED MA1IHOURS
                                                   Reporting Period:

                                                   July 3 chru August 4, 1981
          Source:  Arthur D.  Little  weekly project  report  to MA DEQE
                  8/4/81
                                      15-31
-------
Transportation - Remedial Phase

     The  DEQE spent a  total of  $60,000 for transportation
during the remedial work.  This cost was $37,854 (39%) below
what was  expected  because  the lower than expected amount of
contaminated  soil  on site  required fewer  truckloads.   The
disposal  hauling  of about  520  miles  (825  km) was  done by
Tonawanda Trucking  and  Relco Systems.   A 15% service charge
was  added  to  the  subcontractor  rate by O.K.  Materials
resulting in  a rate of  $2,300  per 13  cubic yard  (9.94 m )
truckload, which  held  about  16.9  tons  (15.3 Mt),  according
to  an  OHM  official.    The  unit  cost  charged  to  DEQE  was
26 /cubic yard/mile (18 /Mt/km).

Disposal - Emergency and Remedial Phases

     The  DEQE spent a  total of $63,675 on disposal during
the emergency and  the remedial  responses.   All disposal was
carried out  at  the Chemical  and  Environmental Conservation
Systems,  Inc.  (CECOS)  facility  in Niagra  Falls,  New York.
Of  the  101  full and partially  full drums  removed  from the
site during  the  emergency response, 89  remained  in storage
as  of  October 1982 at  Recycling  Industries,  in  Braintree,
phase.   Massachussetts,  pending completion  of  the criminal
litigation,  for which they serve as evidence.  The estimated
future cost of $50,000 for storing and disposing of these 89
drums is based on  a verbal  estimate by a DEQE official that
the  total   emergency   operation   will  ultimately  total
$100,000,  minus  the costs  accounted  for  in  the  invoices.
The disposal  costs  charged by O.K.  Materials includes a 15%
service charge added to the unit costs.

Hydrogeological Study

     The DEQE spent $25,000 for the hydrogeological study by
Goldberg Zoino Associates (GZA).   Results  of this  study are
discussed  above   in  the   "Description  of  Contamination"
section."  Three subcontractors were used  by GZA:   Con-Tec,
Inc.  (Concord,  New Hampshire),  for  drilling the 5  test
wells;  Energy Resources, Inc. (Cambridge, Massachusetts) for
laboratory analysis of  the voltile  organics in the soil and
water   samples    and    GHR  Engineering   (New   Bedford,
Massachusetts)  for fecal  coliform analysis of the ground
water.

Management Consultant

     Arthur  D.  Little,  Inc.,  of  Cambridge,  Massachusetts
(ADL) provided  management  consulting  services to  DEQE  for
the remedial  phase  of  the Marty's CMC  project  as  part of a
contract with a ceiling  of  $467,108 that extended from June
6, 1981 to October 29, 1982.  The $80,000 share of this work
that related  to the Marty's  GMC  clean-up,  given in Table 2,

                                     15-32
-------
 is  based on  an estimate  given by  a DEQE  official.   This
 estimate  was  noted to include significant one-time  start-up
 costs.    For  comparison,  if the  $467,108 were  spread out
 evenly    over    the    16-month    contract   period    at
 $29,194.25/month,  the  2i/4-month  work  related  to Marty's
 CMC, the billing would have been $65,687 ($467,108 x 2,25).

      Two  subcontractors were retained  by ADL,  with DEQE's
 approval.    Coopers   and  Lybrand  of Boston,  Massachusetts
 performed invoice auditing.  Haley and Aldrich of Cambridge,
 Massachusetts provided  independent  hydrogeological advice,
 such as assisting  in  the  ground water sensitivity survey of
 the area with DEQE and a Kingston town official.

      The  issue  of   the   assistance  versus  the  training
 function  of ADL  became  important  during  the Marty's  GMC
 phase  of ADL's DEQE  contract.    The  plan  for  using  a
 management  consultant   involved  having  ADL   train   DEQE
 personnel to manage hazardous waste  site  clean-ups  on their
 own.    By  September 1982,  ADL  was almost  completely phased
 out because DEQE  staff  were able  to perform the same  work
 themselves.   A  DEQE  official  was  concerned, however,  that
 his newly trained engineers and managers would move to  jobs
 in the  private  sector.

      Officials   in  DEQE  believed   that   the  use   of   the
 management consultant was cost-effective  for  two  reasons.
 First,  the  auditing  of  on-site work  and  invoices  allowed
 DEQE  to take  full  advantage of  the  potential economies  of
 the time-and-materials clean-up  contract.   Since the exact
 amount  of contaminated material at Marty's GMC was  found  to
 be  lower  than expected,  the  careful scrutiny  by  the  on-scene
 coordinator  ensured that  a  commensurately  lower  charge was
 billed.    A  DEQE official said  that  experienced engineers
 were  needed  to  perform this on-site scrutiny.  In addition,
 cost  tracking  was enhanced by comparing expected  and actual
 costs against 8  specific milestones for the operation.

     Second,  the cost for the  primary  contractor was  also
 reduced  by payment  within  the  discount period.    Previous
 state contracts  did not  include a provision for a discount,
 since payment  was  usually delayed.    A discount  of 5%  was
 offered if the bill was  paid within 15 days, and  2%  if paid
within  20  days.   The  invoices were paid  on a weekly basis.
The discount rate was  extrapolated  for the day paid between
 15-20 days  after billing.   Discounts  were  achieved  for all
 invoices  on  an  average  of 2.62%  and a   total  savings of
$10,983.  A DEQE official believed that the agency would not
have  obtained  the  discount  without  the  greater  accounting
resources provided through the ADL contract.

     An official with  the  contractor  for the clean-up work,
O.H.  Materials,  believed  that  additional  savings  were

                                    15-33
-------
realized from  the  use of  the  management consultant because
he believed that they were  able  to cut through the red tape
at  DEQE  and communicate  more effectively with  the  agency
since  the  ADL  had   the   credibility  of  an  independent
consultant.

Equipment - Remedial Phase

     During the  remedial  phase,  the  DEQE spent  a  total of
$138,442  on  contractor equipment rental,  excluding  sub-
contractor  equipment.   During the week of July 17  - 23,
1981,  for  which  detailed  invoices  are  available,  sub-
contractor    equipment    accounted    for    about    1/10
($3925/$40,023)  the amount  charged  for  equipment by OHM,
including mobile analytical  equipment and facilities, which
accounted for about 20% of its equipment charges.

     The unit costs charged by the different contractors for
similar  pieces  of equipment  were  roughly  similar.    One
contractor  sometimes  charged more  for one piece,  but less
for  another.   For example,  OHM  charged $56/hour for  a 955
CAT  front-loader;  whereas  Black  Gold, Inc. charged $65/hour
for  a  955  CAT.   However,   an  OHM subcontractor, CMC,  Inc.
charged  $25/hour  for a  Case  580  C  backhoe,  whereas  Black
Gold charged $15/hour for  a  Case  680  C backhoe.   The hourly
charge  for  OHM's   30-foot  CAT   215   backhoe  reflects  the
substantially larger size of the CAT 215 over the Case 580 C
backhoe.  This large,  treaded backhoe, and the drum grappler
attachment  ($225/day) were  primary pieces of equipment used
for  the  clean-up  that were  not  readily available elsewhere
at  the  time.    The  cost   for   the   compatibility  chamber
($500/day), which  was brought  to the  site but  not  used, as
mentioned  above  in "Technology:  Bulking," was  not charged.
The cost for the mobile analytical laboratory ($550/day) did
not  include the  costs  of  hand held or large  lab equipment,
or field measurement equipment (PID, TOC, GC).

Safety Procedure Costs

     Of the 2 elements of the cost of  safety procedures used
during  the  emergency  and  remedial   actions   - labor and
equipment  - only  the  equipment  cost during  the  remedial
action  can be distinguished from the  other  costs.   During
the   emergency  response,    no   specific  safety  procedure
information is availble for  site surveillance, which was not
provided by the contractor.  From April  1980 - May 1981, the
deputy  fire chief who served  as  the  acting hazardous  waste
coordinator for  Kingston,  and the police chief of Kingston
regularly  drove  by the  site to ensure  that the  polyethylene
cover  had  not  been  removed.    Although  no  schedule  or
billings were  prepared for this  site security provided  by
the  town,  a DEQE official  estimated  that  this service  would
have  cost  the  state an extra $1,000  per month,  if  the state

                                     15-34
-------
 had paid for it.

      During the week of July 17-23,  1981, for which detailed
 invoices are available,  and during which  the  final  excava-
 tion, bulking  and loading  occurred,  the  safety  procedures
 were the most  extensive of  the entire  remedial  operation.
 For this week,  the total cost of equipment devoted to safety
 procedures  was an average  of  33%  (range 16-49%;  standard
 deviation (SD)  11.2) of the  overall equipment  costs  for the
 week; it was an  average of 42% (range 20-63%;  SD-0.15.)  of
 the non-analytical equipment costs for the week.   Since the
 total equipment  costs  were  about  41%  of  the weekly  invoice
 total (excluding  the discount  $40,023/$97,245), the  cost  of
 safety   procedures  accounted  for  about  14% of the  weekly
 invoice  total  (33% x  41%  or $13,428/97,245).   Among  the
 standard safety  equipment   included  in  these   total  safety
 equipment   costs   are   the   following:  decontamination  and
 equipment   trailer  ($350/day);  high  pressure  water  laser
 ($400/day);  chemical  sealing unit  ($130/day); self-contained
 breathing   apparatus   ($150/day);   regulated  manifold   air
 supply    system   ($105/day);   protective   clothing    set
 ($100/day);  portable pool  ($75/day);  emergency escape  pack
 ($43/day).

 PERFORMANCE  EVALUATION

      Through the  project, the DEQE sought to acheive  a  cost-
 effective  site  response at  Marty's  CMC.   The Massachusetts
 DEQE's   technical  and  financial  expertise with  hazardous
 waste were  important in thier  apparent  success at  meeting
 this  goal.   The department's experience  with earlier clean-
 ups  had  also  suggested the  need  for  greater  cost  control
 assistance,  such  as that provided  by  ADL  at Marty's.   The
 segregation  of work into   immediate  and  planned response
 phases   provided  a  contructive  means   of  allocating  the
 state's   limited   resources  between  competing   sites  and
 balancing those needs with the  remaining  funds.

     Another cost effectiveness  control was achieved  through
 the  use  of  the  time  and  materials   type  of  contract.
However,   since  the  exact  volume  of  material was  the  only
major unknown in  the  RFP,  a  unit  price contract might have
been  cheaper.    Savings could have also been  acheived by
eliminating  charges  during  analysis  delays.     But  the
contract  change  orders   due  to the discovery of PCBs might
have eliminated these savings.

     The   work    performed    during   the   emergency   phase
effectively  mitigated  the  threat  of   fire,  which was  the
immediate concern.  The site  assessment during the emergency
period   was  efficient   and  practical   since  it  provided
adequate  information  for future work and  used available on-
site  equipment.     Monitoring  and  maintenance   of  the

                                    15-35
-------
temporarily  secured  drums ensured  that  the  threat  of fire
did not arise again.

     The  work  performed  during  the  remedial  phase  was
apparently    effective    in   removing    the   source   of
contamination.     The   bulking  of   liquids   and   highly
contaminated  soil  was a  practical  means  of  increasing the
efficiency   of   this  operation.     An  assessment  of  the
environmental consequences  of leaving the PCS contaminated
soil (under  7 ug/g)  must await  future analysis and review.
Planning for follow-up monitoring of the site was pending as
of November  1982.

     Future  work  at  the  site  should  primarily  involve
monitoring  the   capped  area  of PCB  contaminated  soil  and
ensuring  that   any   contaminated   ground  water  does  not
threaten public  health  or the  environment.   Generally, the
PCB  contaminated  soil  should  be  monitored  to  ensure  the
ability  of   the  cap  to  prevent erosion  and  its  effect  on
plants growing on  the area.   Since PCB  is highly insoluble
(Arochlor 1260 - 3 ug/1  in  water), the  threat of downward
migration into the aquifer is  probably  insignificant.  The
ground water which flows toward Kingston and Plymouth Bays
should be  monitored  to  determine  the  extent  and  route  of
contamination, if  any.    Construction of new  water   supply
wells  downgradient should be done very cautiously,  if  at
all,  to  prevent  public  health problems.     Although  the
commercial   cranberry  bogs   are  not  hydrologically  down-
gradient from the  site,  the  proximity  of these bogs and the
potential for  bioaccumulation suggests  that  they should be
monitored in the future.
                                     15-36
-------
                       BIBLIOGRAPHY
Arthur D. Little,  Inc.,  (ADL)  April,  1981. Kingston Bid
     Evaluation Package.

ADL. May  1981. "Report of bid evaluation and contractor
     selection" to DEQE.

ADL,  "Weekly Progress Reports" to DEQE: July 24-July 30,
     1981; July 31-August 4, 1981.

ADL.  July 1981.   "PCS in LCP soil analysis."

Amiro, Joe.  DEQE  Accountant.  October, 1982.  Personal
     communication with Environmental Law Institute.

Attorney General of Massachusetts. Complaint against alleged
     dumpers as amended April 23, 1981.

Black Gold Services, Inc. Invoice # 403, 412, 415, 425, 437,
     444, 460, 477, 480 and 502 to DEQE.

Bronson, Peter.  DEQE Attorney General Counsel's Office.
     October 1982.   Personal communication with Environmental
     Law Institute.

Conally, Joseph.   DEQE Southeast Regional Ofice.  October
     1982.   Personnal  communication  with Environmental  Law
     Institute.

Coopers and Lybrand, Inc.  July 29, 1981.  Invoice audit.

Cortese, Antony D, Commissioner, DEQE, September 27, 1981.
     Letter to Kingston Board of Selectmen.

Feldman, Larry.  Goldberg Zoino Assc., Inc.  October 1982.
     Personal communication with Environmental Law Institute.

Goldberg Zoino Associates, Inc.   August 1981.   Kingston
     Hydrogeological Study.

Gould,  Jeff,  on-scene coordinator DEQE,  September 10,  1981.
     Memo to William Marhoffer.

Huniwell,  Dodi. Water Pbllution Control, DEQE.   October 1982.
     Personal communication with Environmental Law Institute.
                                 15-37
-------
Ikalalenen, Barbara.   U.S.  EPA Region I, Boston, MA.
     September    1982.        Personal    communication    with
     Environmental Law Institute.

Kelly, Richard, former Assistant Attorney General, Criminal
     September 1982.   Personal communication.

Kirk, Joseph, Vice President O.K.  Materials, Findlay, Ohio.
     October 1982.   Personal  communication with Environmental
     Law Institute.

Marhoffer, William, project manager, DEQE.   October 1982.
     Personal communication with Environmental Law Institute.

McShane, Tohomas, Legislative Liason, DEQE.  October 1982.
     Personal communication with Environmental Law Institute.

Massachusetts Department of Environmental Quality Engineering,
     (MA DEQE) form AF-4 for ADL services.

MA DEQE RFP, dated May 1, 1981.

MA DEQE, contract with O.K. Materials,  signed June 26, 1981.

O'Brien, John.  July 2, 1981. "Response to press inquiries
     by DEQE."

O.K. Materials.  May 1981.  Proposal to DEQE.

O.H. Materials.  August 1981. Invoices.

O.K. Materials, Weekly Progress Reports to DEQE:
          July 8 - July 16, 1981
          July 17 - July 23,  1981
          July 24 - July 30,  1981
          July 31 - August 4, 1981

O.H. Materials, Budget Variance Reports to DEQE:
          July 8 - July 16, 1981
          July 24 - July 30,  1981

O.H. Materials, Weekly Analytical Reports  to  DEQE:
          July 8 - July 16, 1981
          July 17 - Jyly 23,  1981

O.H. Materials.  July  1981. "Sampling  procedure for PCB's
      in LCP".

O.H. Materials.  August  1981.   Final Report,  by Robert
      Panning.

O'Purier,  J.J.,  DEQE,  Memo to William  Simmons on final  site
      disposition recommendation.  August  1981.

                                 15-38
-------
Panning, Robert, Vice president, O.K. Materials.  October
     1982.    Personal  communication with  Environmental  Law
     Institute.

Pittman, Malcolm, former Assistant Attorney General, Civil
     Division. September 1982.  Personal communication.

Rappaport, Ann, Deputy Director, DEQE. September 1982.
     Personal communication with Environmental Law Institute.

Simmons, William, Emergency Response Unit Director, DEQE.
     August  1982.   Personal  communication  with Environmental
     Law Institute.

Shotwell, JoAnn, Assistant Attorney General, Civil Division,
     Environmental Protection.  September 1982.  Personal
     communication with Environmental Law Institute.

Spittler, Tom, U.S.  EPA, Region I, Boston, MA.. Laboratory and
     Technical   Services.       October    1982.       Personal
     communication with Environmental Law Institute.
                                15-39
-------
-------
                               N.W. MAUTHE, INC.

                              APPLETON, WISCONSIN
 INTRODUCTION

     N.W.  Mauthe,  Inc.  is  a  former  chrome  plating  shop
 located  in  Appleton,  Wisconsin.    In  March,   1982,  the
 Wisconsin  Department  of  Natural  Resources  (WDNR)  dis-
 covered  puddles  of  yellow chromium  contaminated  water
 along  railroad  tracks  immediately south  of the  plating
 shop.    Subsequent  investigation  revealed hexavalent
 chromium contamination of soil, surface water, and shallow
 ground water beneath  and  south  of the  shop.   Contaminated
 water was  seeping  into  a  nearby residential  basement,  and
 threatened to enter the Fox River via storm sewers.

 Background

     From  1966  to  1976,  Norbert  W.  Mauthe operated  a
 chrome plating  facility  at 725 South  Outagamie  Street  in
 Appleton,  Wisconsin under the  name  of the  Wisconsin
 Chromium Corporation.   In 1976, Mauthe  sold  the name  and
 chrome  plating customer  list  to another  company but
 continued  to do  cadmium and zinc  plating at  the  Outagamie
 Street facility  for some  time  thereafter.  At the  time  of
 site discovery   in March  1982, Mauthe  remained  the  sole
 owner of the property at Outagamie Street.

     An anonymous  phone call to the WDNR led to  site  dis-
 covery.   Yellow  puddles were  reported along the railroad
 tracks behind the chrome  plating  plant and in an adjacent
 ditch leading to a storm sewer  which discharged  to the  Fox
 River.     Investigation  by  WDNR  revealed  that   chromium
 contaminated water was being pumped from a sump  pump  at  a
 residence 150 feet (46 m) from  the  plant.  WDNR  responded
with a quick sampling effort  to  determine  the  extent  of
contamination  and  discovered  a  high  level  of  chromium
contamination and  low levels  of  cyanide,  zinc,  copper,
cadmium and  othe metals.    Figure  1  presents a  layout  of
the site  and the primary areas  of  contamination.
  NCP References
300.63(a)94)
discovery
                                     16-1
-------
                                                                    Storm Sewer Pipe
                   R
            WISCONSIN CHROMIUM CORP
Figure 1.    Location  and Extent of Surface  Chrome Contamination at the Mauthe  Site
-------
 Synopsis of Site Response

     The WDNR  determined  that  snowmelt and rainwater were
 leaching chrome  out  of the soil near  the plating building
 and transporting it  laterally along  the permeable railroad
 beds and to  the  nearby resident's sump pump.  The  immedi-
 ate concern was  to contain the  contaminated surface water
 and remove it  from the area to  reduce  possible exposure of
 nearby  residents  and  to  prevent  the  contaminated water
 from migrating into  the  Fox  River  via  the storm  sewers.
 The  WDNR  made an  arrangement with a local  contractor,
 Rocket Sewer Handling, to  pump  and dispose  of the contami-
 nated surface  water  from the puddles surrounding the site,
 from the  drainage ditch   adjacent to  the railroad  tracks,
 and from the nearby  storm  sewer.  Beginning in April 1982,
 Rocket Sewer   Hauling  pumped and  transported the contami-
 nated Liquid to the  nearby City of DePere Sewage Treatment
 Plant.  This effort  was combined with  the   construction of
 a small dam across the  drainage ditch to reduce the  flow
 of contaminated  water into  the storm sewer, and applica-
 tion of Loads  of  sand  to  contain the  spill.  Over the
 following  six weeks,  Rocket  Sewer   Hauling periodically
 returned to  the site  to   remove puddles  of  contaminated
 water from melting snow and rainfall.

     Between   May  18-20,  1982,  Commercial  Pumping  and
 Incineration (CPI),  under  contract with WDNR, installed a
 more  permanent  collection  system.   The   system included
 shallow subsurface drains  which collected the contaminated
 surface  water  and  shallow ground water  and routed it to
 collection  sumps  where   they  were pumped  into a  holding
 tank.  Contaminated  soils  were  removed from the north side
 of the  tracks in  the  process of installing the collection
 sump there.  CPI   also  installed a  drain  pipe to  collect
 clean  rainfall  runoff  and  divert it away from the sub-
 surface drains  so  as to  minimize  the  quantity of water
 which is collected,  pumped and hauled  off site.

     Rocket Sewer  Hauling  continues to haul the collected
 contaminated liquids   to DePere Sewage Treatment Pland and
 as  of  December 1982,  273,000  gallons (1.03 x 10° 1) of
 contaminated liquid have been pumped.

     In October 1982, Mauthe  drilled  through the concrete
 floor  of   the  plating building,  excavated  a trench  and
 installed a sump pump to pump contaminated  liquid into the
holding tank.
300.65(b)(6)
moving hazardous
substances
off-site

300.65(b)(7)
physical
barriers to
deter spread of
release
300.70(b)(l)
(iii)
ground water
controls

300.70(b)(l)(ii)
(b)
surface water
diversion and
collection
300.70(c)(2)(i)
excavation of
contaminated
soils
                                     16-3
-------
SITE DESCRIPTION

     The  Mauthe  site   is  located  in  Appleton,  in east
central Wisconsin.  The site is bounded by South Outagamie
Street s 2nd  Street  and Melvin Street.   The  source  of  the
contamination  was  the  Wisconsin  Chromium  Corporation,
formerly  located  at  725 Outagamie  Street  adjacent  to  the
Chicago and Northwest Railroad tracks.  This area  is mixed
industrial   and   residential.   Private  residences   are
located  within  150 feet  (46 m) of  the source  of contam-
ination.  There  are  6  primary    and  secondary  schools
within  one  mile (1.6 Km) of  the  site,  one of which  is
located just 1  1/2  blocks from the site.   Figure 2 shows
the location of the Mauthe site.

Surface Characteristics

     The  climate  of  Outagamie  County is mild with long
cold  and  snowy  winters  and  warm  summers.   There is a
considerable  temperature  range from season to  season  and
from year to year.   The maximum average daily temperature
in  Appleton ranges  from  a  low  of   26.1°F  (-3.3°C)   in
January to  82.6°F  (28.1°C)  in July.   The  average  daily
minimum temperature  ranges  from a  low  of  9.8°F (-12.3°C)
in January to a high of 61.9°F (16.6°C) in July.

     The average yearly precipitation in  Appleton is 25.5
inches (64.8 cm) and 55 percent of  the precipitation falls
between May and  September.    Snowfall  and  sleet  average
about 43.4  inches  (110.3 cm), but  vary greatly from year
to year.  The  last  freezing  temperature occurs   later than
April  30th  in  6  out  of  10  years.   Prevailing  winds  are
from the  northwest  in  winter  and  from the  southwest   in
summer.

     The  city  of  Appleton  and most of Outagamie  County
lie  in the  Fox River  drainage  basin.  The river, which
is about 0.5  miles (0.8 Km) south  of  the  Mauthe  site,
flows  in a  southwesterly  direction through Appleton  and
discharges into Lake Winnebago.

     The topographic relief of Outagaraie County  was  formed
by recent glaciation.   The soil are  well  drained,  nearly
level to gently sloping, and were formed in clayey glacial
till.  The upper soils are principally brown and red clays
and silty clays.  The  permeability of these  soils is slow
to moderately  slow.   In the immediate  area  of  the  Mauthe
site, much of the native soils have been covered with fill
consisting of  cinders,  sand and gravel.   This   fill  layer
is discontinuous but  is  1  to 2 feet  (0.3-0.6 m) thick  in
some areas.   A perched  water  table is present in the fill
material.
300.68(e)(2)(i)
(A)
population at
risk
300.68(e)(2)
(i)(E)
climate
300.68(e)(2)
hydrogeological
factors
                                     16-4
-------
Figure 2.  Location of Che Mauthe Site - Appleton, Wisconsin
                          16-5
-------
Hydrogeology

     The   surface  geology of Outagamie  County is charac-
terized by a thick layer of glacial drift deposited during
the  Wisconsin  stage  of glaciation.   These  deposits  are
underlain  by  sandstone and  dolomite of  the  Cambrian and
Ordovician  age.   The  geology in  the  area of the Mauthe
site is outlined more  specifically in  the geologic cross-
section shown in Figure 3  and in Table 1 which summarizes
driller's well logs for two wells located within 0.5 miles
(0.8 km) of the site.

     The  glacial  drift which is  mainly  till containing
sand, clay, silt and  gravel  varies widely in  thickness in
the  area of Appleton  and  is  reported  to  be  about 60 feet
(18 m) thick beneath the Mauthe  site.

     The upper 10 to 20 feet  (3-6 m) of the  glacial till
has  been  characterized by borings which were  taken during
the  site  investigation efforts at the Mauthe  site in May
1982.  The drift was chiefly  brown and red clays and silty
clays  with discontinuous  sand  and  gravel  seams.   Thin
sand and gravel seams  of  1-2 inches (2.5-5 cm) were found
in most borings and thicker  sand  seams of 1 to 5 feet (0.3
- 1.5 m) occured in several borings  at depths  below 5 feet
(1.5 m).   Water flowed  freely where  these highly permeable
sand or gravel  strata  were  encountered.   The surrounding
clay soils were generally  saturated.

     As  indicated  in  Figure 3  and  in  the  drillers logs
(Table  1), the glacial till is  underlain by a  dolomite
unit,  ranging  in  thickness from  about  20 to 80 feet (6 -
24 m) .   Vertical  fracturing  and  numerous sandy and silty
zones are  characteristic of  this  formation.  In some areas
there  is  15  to  20  feet  (4.5-6 m)  of  fine  to medium
sandstone  near the base of this  unit.

     As  Figure  3  illustrates,  the  dolomite   formation is
underlain  by  a  sandstone  unit (St. Peter sandstone) which
is   characterized  by  fine  to   coarse  grained   sandstone
containing  some chert.  This unit is discontinuous but is
shown  to  be 70  feet  (21 m) thick  in the area of  well No.
280.

     The  fractured dolomite  or the  sandstone,  where  found,
is   in  turn  underlain  by  an   older,  denser  dolomite
formation.    This  dolomite   contains  numerous  shaly and
sandy   zones    and  layers of chert.   It is over  100  feet
(30  M)  thick beneath  the  site.

     Finally this dense dolomite formation  is  underlain by
about  150 feet (50  ra) of sandstone of the late  Cambrian

                                     16-6
-------
Northwest
                         APPl I I UN
                                                                           Southeast
          Ditum it ntftn IH /•¥*/
Figure 3.  Geological  Cross Section of Area Around the Mauthe  Site




Source:  LeRoux,  1957
                                    16-7
-------
TABLE  1.   WELL  LOGS  FROM  TWO  WELLS  WITHIN  0.5  MILES  OF  THE  MAUTHE  SITE
                                                              . u. T. a s.. a. n x.
                                                                               (ft.)
                                                                                          Depth
                                                                                       -   (ft.)
                            3*04. iat. mv-nofc. •maaii—
                            TJC, pat 4otonuac_	
                            3:wi. ana. i
                            TIT. nipt T*ui>iur*r
                         Giteia doiwniic nod FUiMvul* (ornucao;
                            Unooiu. UtOi-nmTr soaw ittot Wu*«tmT.-	
                            sina*t*j*. swuom-io rtni 1111 mi iicu-Enr. dolooune..!!!	I
                         sc

                            jiumon*. tta»-« mdua-cnBHii. nrr mat W»T	
                            COOR. H»T. 3UU[-CJtT	
                            jh"**. no: cam. mvB-fnr. onJc..

                         n_ 2*?- S?7i -r«U»"'«»r. o™I«-_™T titoi (tmy, aaar. ^>«. ew. oottdiu
                         Opptr OmbrajB OWIB:
                           ^aonoDo. TCTT armttaio. TVT 11«M mr. dn
                                                               M. T- a N_ a. 17 x.
                             OaioaiM, Mu-cnT ud cnr	

                             Do. 'mm. lirat-fny'
                                   fln^tmnd. pfni. dntomdc ___ _ ________
                            poki-niB;. nndT. Trt. tntt. tauamtie __________ ________
                            aaiaiam. aa*»rtin«c. niT. n«a. aevimme. (Unconioe _____ IIII. ~  **"
                            iiBdJerac. la» a BMlOB-oamwuwO. ll«nl-fT»r.
                   Source:   LeRoux,  1957
-------
 Age.    It  is  a fine  to  coarse grained sandstone which  is
 shaly and dolotnitic  in some places.

      Ground  water  occurs  under  both  water  table and
 artesian conditions  in  the  Appleton area.   Water  table
 conditions  prevail  locally  in  bodies of  clean sand  and
 gravel  and   in  the  dolomite  where  water  moves   freely
 through  cracks  and  solution  channels.    Artesian  water
 occurs locally,  confined by layers of silt  and  clay in the
 glacial  drift.    It  also  occurs  throughout  the  bedrock
 formations  wherever  it is confined by relatively  imperme-
 able  dolomite and  shale.

      The sandstones  of the  upper  Cambrian  series  and  the
 St. Peter's  sandstone, where it is sufficiently  thick,  are
 the  most  important   aquifers  in  Outagarnie County.    The
 dolomite formations  also  supply some  water  to domestic  and
 industrial wells  in  the  county but yields from  these  wells
 are  generally  low.    Yields  from  wells  drilled  in  the
 glacial  till  are good  where  the  permeable  layers  are
 sufficiently  thick.    Piezometric maps  indicate that  the
 ground water  flow  is  in  a  southeastern direction.   This  is
 a  result of  natural discharge into the Fox  River, recharge
 from  areas  west  of Appleton, industrial  pumping along  the
 Fox River and the  eastward  dip  of  the  bedrock.

     The city  of Appleton  is  served  by  a  municipal  water
 supply  and WDNR   has  indicated   that  there   is only one
 domestic well in  the "immediate" area.  This well is not
 supplied by  the  glacial   drift  and  is  not contaminated.
 There  are several industrial  wells  in  Appleton  and the
 sandstone and, to  a  lesser  extent, the dolomite  formations
 supply these  wells.
300.68(e)(2)
population at
risk
WASTE DISPOSAL HISTORY

     Norbert  Mauthe  purchased  the   property  at  725
Outagamie  Street  in  1966.    He  operated  the  Wisconsin
Chromium Corporation,  a  facility  involved  in  chrome
plating and other types of electroplating, until March 26,
1976,  when  he  sold  the   name   and   the  chrome  plating
customer list  to Southern  Plating located in another part
of  the  State.    Mr.  Mauthe  retained  the Outagamie Street
facility where he  has  continued  to  do cadmium  and  zinc
plating.

     As  the  name implies, Wisconsin Chromium Corporation
was   chiefly   involved   in  chromplating.  The  process
involved  immersion  of  the  metal   into  an acidic solu-
tion  of  chromic  acid  or chromium salts so that some of
the  base metal was  converted to one of the components of
300.68
amount and form
of substance
present
                                     16-9
-------
the film by reaction with the aqueous  solution.   Chromium
plating solutions contain chromic  acid at  concentrations
of 400 g/1 and small amounts  of  sulfuric acid  or  a mixture
of  sulfuric   and   fluoro-silicate  or   fluoride  ions.
Chromate conversions can be  produced on a  number  of metals
including  zinc,  cadmium,  copper  and  aluminum  and   low
concentrations of these  dissolved  metals  can be  found  in
the chromating bath.

     During operation  of  the Wisconsin  Chromium  Corpo-
ration at  South Outagamie Street,  there were  two possible
sources of contamination.   One  was a blower  vent located
along  the  southern  face of  the  facility  which  discharged
chromium  laden mist to  the  outside.   The second  source
apparently resulted  from  leakage of chromium plating
wastewater  through  cracks  in the  concrete  floor.    The
chromating tanks were  located along  the south wall of the
facility.  A  trough had  run  adjacent  to tanks in order to
catch  the drippings and  to  conduct them to  the sanitary
sewer.  Cracks in the  trough and in the  concrete flooring
resulted  in  seepage of  chromium bearing  waste  water  into
the underlying soil.

     On  March 31,  1982,  the   WDNR, responding  to  an
anonymous  complaint, discovered puddles of yellow water in
the vicinity  of  the Outagamie Street  plating  facility and
in a  ditch which ran  adjacent to  the railroad  tracks, as
illustrated  in Figure  1.  Apparently  the upward movement
of the water  table resulting from snowmelt  and rain had
caused the   surface   expression  of  the  contamination.
WDNR's subsequent  investigation and  sampling at the  site
verified  the  presence  of high concentrations of hexavalent
chromium  and low  concentrations  of other metals and
cyanide.   Because  of  these  findings,  WDNR initiated  both
an emergency  response  and a  planned remedial response.
 DESCRIPTION OF CONTAMINATION

      In  the  course of  developing  both  an  emergency
 response  and   a   planned remedial  response, WDNR has con-
 ducted  several sampling and  monitoring efforts to deter-
 mine the extent and  severity  of  the contamination problem.

      On April  1  and again    on  April  21,  after emergency
 efforts  had  been undertaken to  pump contaminated water
 from  puddles   and  from  the drainage ditches  WDNR took  a
 number  of  samples   from   shallow 18  to 36  inch (46-91cm)
 hand-dug, auger holes,   from  surface puddles,  and from  the
 sump  pump  of  a  residence   located   less   than 150 feet
 (50 m)  from  the  site.  The  samples were  analysed  for
 hexavalent  chromium,  cyanide   and for a number of other
300.68(f)
remedial
investigation
300.65(b)(l)
collecting and
analyzing
samples
                                      16-10
-------
metals.   The   location   of  the   sampling   points   and   the
results  of  those  sampling efforts  are  summarized  in  Figure
4  and Tables  2  and 3.   The  results clearly  indicate  the
following:

      •   Hexavalent   chromium  was   the  major   contaminant
         although  cyanide,  zinc   and   other   metals were
         also  detected.
     •  The  highest  chromium concent rat ions were  found  at
        or near  the  surface  in  the  area west of  a  concrete
        slab   (see   Figure 4, samples  3 and E),  along  the
        southern wall  of the facility and  adjacent  to  the
        blower   discharge vent  which was  used  for  exhaust-
        ing  chromium laden mist.

     •  The  contaminated  water  had  entered   a  drainage
        ditch  which  ran adjacent  to the south side  of  the
        railroad tracks and  discharged into the Fox River
        via  a  storm  sewer.

     •  The  permeable railway bed and  the topography were
        causing  the  contaminated  groundwater to move in  a
        northeastern direction.

     •  The  contaminated water  was  also moving  in  a  south-
        easterly direction,  as  was  evident  from  the high
        concentrations  of chromium  in  samples  taken  from a
        nearby basement sump pump (Sample 9, Figure  4).

     •  Contaminant  migrated to a lesser  extent north  and
        west of  the  site was minimal.

     On  May 6 and 7, 1982, two weeks  prior to  the instal-
lation  of  a  surface   water  collection  and  diversion
system,  Soil  Testing  Services  of   Green Bay, Wisconsin
conducted a subsurface  exploration.

     Nine  borings   were drilled at the locations  shown  on
Figure  5  using  a   trailer  mounted  hollow flight,  split
spoon   sampler   in   accordance  with  ASTM  specification
D1586-67.   Six,   20-foot (6 m)  and  three, 10-foot   (3 m)
borings  were  made   and   samples  were  taken  at  2.5 foot
(0.8 m)  intervals.    The  boring  logs  which resulted from
this effort were described under  "hydrogeology."  Table  4
summarizes  the  levels  of  total  chromium  found   in  the
borings at various depths.  Levels of  30 mg/kg or  less  are
considered to be background levels.  The results indicated
Chat chromium  had migrated  vertically to a maximum of  13
feet (4  m)  and   further  confirmed  that  the  direction  of
migration was in a northeast and southeast direction.  The
300.68)(e)(2)
amount and form
of substance
present
300.68(e)(l)(v)
highly contami-
nated soil at or
near the surface
300.68(f)
sampling and
monitoring
300.68(e)(2)(ii)
extent of migra-
tion of
substance
                                     16-11
-------
                        TABLE 2.   RESULTS  OF APRIL  1,  1982 SAMPLING AT MAUTHE  SITE
Sample
lumber
SA-1
SA-3
SA-6
SA-7
SA-8
SA-9
As
mg/l
<1
<1
<1
<1
<1
<1
Ba
mg/l
<0.4
<0.4
<0.4
5
<0.4
<0.4
Cd
mg/l
<0.02
<0.02
0.04
<0.02
<0.02
i ' i
<0,02
Cu
mg/l
<0.05
<0.05
0.08
<0.05
<0.05
<0,1
• i • •^•^—
Fe
mg/l
1.4
0.8
1.0
5.1
2.4
8.5
Pb
mg/l
<0.1
<0.1
0.1
<0.1
<0.1
<0.1
i i "
-
Se
mg/l
<1
<1
<1
<1
<1
<1
*• 1 '*' 1"
Ag
mg/l
<0.05
<0,05
<0.05
<0.05
<0.05
<0.05
Zn
mg/l
0.150
0.080
0.580
0.100
0.280
0.170
Cr+6
rag/1
1.3
340
8.5
0.520
22
96
i I'
Cr-Tot.
mg/l
.
1.3
400
13
<0.1
21
no
GN
mg/l
<.01
.02
.21
	
— 	 **.. 	
<.01
I
I—'
NJ
          All samples except SA-7 were properly filtered and Preflerved.  All  samples were  from

          shallow (18-36 inches) augerholea except SA-9 which is  a  aump pump  sample.
-------
                         TABLE 3.   RESULTS OF  APRIL  21,  1982  SAMPLING AT  MAUTHE  SITE
 I
»—•
LJ
Sample
A
B
c
D
E
F
G
H
I
K
As
rag/1


-------
            OLD WISCONSIN CHROMIUM CORP
             I
     April 1 Sampling Points
     April 21 Sampling Points
Figure 4.  Location of April  1  and April 21, 1982 Sampling Points
-------
I
(->
Oi
                          Oil) WISCONSIN CHROMIUM CORP

                          I
                   Borings


                   Wells
              Figure 5.  Location of  Borings and Wells Drilled  and Installed on May  6  & 7,1982
-------
TABLE 4   RESULTS OF MAY  1982 SOIL BORINGS  -  TOTAL CHROMIUM (nig/kg)
          (NITRIC ACID EXTRACTION) OF^OIL  SAMPLES ON AND ADJACENT
          TO THE N.W.-_MAUTHE COMPANY.             •         "  .
	 . — . —
Deptl
(ft)

3
6
8
11
13
16
18
21
i Boring
1
80
61
30
27
30
	 -
30
21
20
2
4300
1300
420
720
810
1500
30
20
30
.^ aw**^— "-B^-^
3
i ' '
390
770
160
220 .
. 	 ' ' *~
140




^•^— ^— ^— ^— ^
4
^m^^—*^^^^^^^
200
390
62
110
120




5
t^ ^^^B^N^fc^^
150
110
82
210
150
20

6
-^-•^•PI • "
79
310
51
44
16
72


•••— ^ i
•• i •
7
750
280
55
41
23
20
21
20
26
•.i -^— ^
••— _^ .^B^— ^^^— 1
8
910
120
120
110
25
25
28
~- — -^ — — •


9
••••••••••••••••••»•
32
34
29
23
24
22
21
16
19
Soil sample immediately under plating buildings slab: 33,000 mg/kg
total Cr 	 — 	
1Blanks indicate that sample was not taken
All depths are+_ foot. ^ 	 	 	 	
                                 16-16
-------
high chromium levels detected in boring #5 were thought to
be attributable to  a  small spi11 from  the  chrome plating
facility.   A  grab  sample  of  soil  from  underneath  the
building slab  was also  taken  and  had  an  extremely  high
chromium concentration  of  33,000  mg/kg.    This  high
chromium  concentrations  led WDNR  to  suspect   that  the
blower vent  was  not  the only  source.  WDNR subsequently
invest igated  the  buiIding and  found  evidence   of  leaky
collection  troughs  and  cracks   in  the concrete  flooring
thorugh which the chromium had  seeped.

     In two of the 20  foot (6 m)  borings, PVC observation
wells were  also  installed.  Figure 5 shows the   locations
of  these we 11s.    The  wells  were  protected with  steel
protector pipes  and  locks.  One  well,  B-7,  was  screened
from  15  to  20 feet  (4.5 -6m)  and  the other,  B-8,  was
screened from 10  to 15 feet (3-4.5 m).

     A second  round  of  borings  and monitoring wells  were
completed by  Twin City Testing  of Appleton  in  December
1982.  Five borings made inside  the plating building  to a
depth of 15 to 20 feet (4.5-6 m).  Seven borings  were made
to a depth of 15  to 20 feet (4.5-6 m)  at various  locations
in  the   area  of   south  Outagaraie  and  Second Street  and
twelve,  2-inch diameter  schedule 160  PVC  piezometers  were
installed.  Drill ing  and sampling procedures  were similar
to  those  used  during  the May  6  and  7  hydrogeologic
investigation.  Boring and well locations, boring logs and
sampling results  were not available as of January 1, 1983.
PLANNING THE SITE RESPONSE

InJLt_i.at^iqn of Response

     On  March  31,  1982,  the  WDNR  was   alerted  to  the
chromium  spill  at  725  Sout Outagamie  Street  by  an
anonymous  phone  call  reporting  yellow  and  green  water
pumping  out  of  the  ground  around  the site of Norbert
Mauthe's  chrome  plating  plant.   The WDNR responded with
an  initial  investigation  to determine  the type of con-
tamination  and  immediately hired Rocket Sewer Hauling to
begin  pumping  the  contaminated   liquid from puddles and
from the drainage ditch  next  to the  railroad  tracks.   The
WDNR1s initial sampling determined the contamination to be
primarily  hexavalent   chromium in   the   soil  and  ground
water.    The  immediate  threat  involved  three factors:
(1)  the  danger  posed  by  human  or  animal exposure by
direct  contact to puddles of hexavalent chromium contami-
nated water,  (2)  the  threat  of human exposure  by  direct
contact  through  seepage  of contaminated  water  into  local
300.64(a)(2)
identificat ion
of the source
and nature of
the release
300.65(a)(l)
exposure to
toxic substances
                                     16-17
-------
resident's  basements,  and (3)  the  possibility of contam-
inated  water  migrating to the  Fox River  about 0.5 miles
(.8 km) south of the site.

^election of Site Response

     The  emergency  activities  at  the Mauthe  site,  which
included  periodic  pumping of  chromium contaminated water
from the  drainage  ditch and from puddles,  were viewed by
WDNR to be interim control measures  to  provide them with
the time they needed to determine the  extent of contamina-
tion and  to develop a  planned response.   Based  on early
sampling results and  WDNR's  inspection  of  the site, they
proposed  a  response  plan  which  included  the following
elements:

     •  Control  and  dispose of  surface water in order to
        reduce  potential  health  effects  and  to  prevent
        contamination  from  entering  the Fox River  via the
        storm sewers (Phase l)
        Identify  the  horizontal  and  vertical  extent of
        contamination and the  transport  mechanisms (Phase
        II

        Design  and  implement a  contamination containment
        or removal plan (Phase III + IV).
     Although WDNR could have continued to pump water from
the puddles  and  drainage ditch, this  approach was expen-
sive and  inefficient as a  long-term solution.   A lot of
contamination  was  escaping  these  collection  efforts  and
the WDNR was incurring a large expense because of  the need
to pump the puddles  and  ditch  after  every rain storm.   In
addition, unnecessary  expenses  were  incurred from pumping
large amounts  of clean rainwater running on  to  the site.
Therefore WDNR considered alternatives for controlling the
surface water.

     They  decided   that  a  drainage  system  should  be
installed  to  reduce  the  high  costs  and  staff   time
involved  with  pumping  from  the  ditch and the puddles.
WDNR briefly  considered alternatives to a drainage system
but dismissed them.  Dewatering wells  would not have been
effective because the soils were too clayey and the perme-
ability too low.

     The District WDNR staff decided that, due to a short-
age of manpower  and  lack of staff engineering experience,
300.70(b)(l)(ii)
and (iii)
surface water
and ground water
controls

300.68(f)
sampling
and monitoring

300.70(b)(iii)
ground water
controls
300.68(g) and
(h)
development and
screening of
alternatives
                                     16-18
-------
 the  design  and  installation  of  the  collection  system
 should  be  performed  by  an  outside  contractor.    WDNR
 contacted  several  potential  contractors and  on April  14
 they  received  four proposals  which  included  the  remedial
 actions proposed  in Table  5.

               Table  5.  PROPOSED REMEDIAL RESPONSE FOR PHASE  I
Proposed Remedial Response
Collection lines with meter sprinkler
system to leach chromium from the soil
Trench system with pretreatment prior
to discharge to sanitary sewer
Groundwater depression pump with
collection and treatment
Trench system with collection and off-
site treatment of contaminated water;
removal of highly contaminated soils;
diversion of clean surface water
WDNR's Rationale for Selection
or Rejection
Rejected: high cost and soils
too impermeable for leaching
Rejected: high cost of pretreat-
ment
Rejected: soils too clayey to
pump
Selected: on basis of cost and
effectiveness
WDNR  accepted the  proposal  submitted by  CPI.    Due  to  a
delay  in  funding,  the work was  not  begun until May  18th.
However  most  of the  construction  was  completed  by May
20th.

     Phase  III  or  the  design  of  the  remedial response
activities  is  still ongoing at  this  time.   As of January
1983, WDNR had just received the first round of monitoring
data from the wells which were completed in December  1982,
but  the results  will  not  be   available  until  WDNR has
reviewed and analyzed the data.

Extent of Response

     During Phase I the WDNR sought  primarily to contain
the  immediate  threat  of  the  chromium contamination  by
minimizing  migration of the contaminated  ground and sur-
face  water  from the site.   Consequently the selection of
the length and depth of the drainage system and  the amount
of soil excavated was based upon WDNR's evaluation of what
was  necessary  to  remove  the  immediate  threat.    The
response  activity  thus far  can be  termed an  emergency
300.65(c)
immediate
removal is
complete
300.68(j)
extent of remedy
                                     16-19
-------
response and an  interim  control measure.  The WDNR is in
the  process of analyzing the most recent  hydrogeological
data and planning a more extensive response to the site in
order to prevent further horizontal and vertical migration
of the contaminated water.
300.66(a)
assessment for
further action
DESIGN AND EXECUTION OF THE SITE RESPONSE

     As  indicated  previously,  the  remedial  response
activities at  the Mauthe  site have  involved  an  emergency
response,  the  planned,  Phase I  interim  response for more
efficient  control and collection  of  surface water  and the
planned  Phase  IV  response  for containing  or  removing
remaining  contaminated ground water.

Emergency  Response

     Within hours after WDNR was notified  by the chromium
contamination  problem,  they reviewed their list  of quali-
fied  contractors  and  Rocket Sewer  Hauling  Company from
Appleton  was  contacted and  requested  to begin  pumping
operations.  Over a 5 day period from March 31 to April 4,
Rocket Sewer Hauling, collected 6000-7000 gallons (11,400-
26,5001)   of contaminated   liquid from the  drainage ditch
running adjacent to the railroad tracks, from pools on the
ground  surface and  from a nearby storm sewer.  The snow-
melt and heavy rains which  occurred over the first several
days of  the  emergency response were  causing  the drainage
ditch  running  parallel  to  the railroad  tracks  to  fill up
rapidly and  were  also  resulting  in  the surface expression
of  chromium  contaminated  water  in  puddles throughout the
area.   The  drainage  ditch emptied  into  the  storm sewer
system  via  a  corrugated  drain pipe  at  south  Outagamie
Street and the storm  water  was  eventually discharged into
the  Fox  River.   Therefore, WDNR was  very concerned with
minimizing discharge from the ditch  into the storm sewer.

     On April  2, with the threat of heavy  rains, WDNR con-
structed   a  small  coffer dam across the drainage ditch to
minimize   discharge of  contaminated water  into  the storm
sewer.   They  also  used   sandbags  to   isolate  the highly
contaminated   area  and  to  prevent  the  chromium contam-
inated  water  from  gravitating  back  into the  residents
yards.   However,  these efforts  were not very successful.
The  rain  was  very  heavy and  the water  flooded over the
drainage  ditch and  into  the  backyards of  the  residents
threatening  to flood their  basements.  It  was necessary to
break  the  dam  and release some of the water into the storm
sewer.
300.65(b)(6)
moving hazardous
substances of f-
site
300.65(a)(7)
use of barrier
to deter  spread
of releases
                                      16-20
-------
      The Department  of Public Works  then brought  in two
 loads of sand which were  used  to  isolate  the most heavily
 contaminated area in  an  area of about 50  feet  by 50 feet
 (15m by 15m) and to divert  the  uncontaminated runoff from
 the Miller Electric  Co. parking lot just  west of the site.
 After the water which had flooded over the ditch water had
 receded, sand bags were again placed in the ditch near the
 storm sewer pipe.  These  measures,  together  with periodic
 pumping from puddles  and the drainage ditch,  were  effec-
 tive  in minimizing  the  quantity  of  contaminated  water
 discharged into the  storm sewer.

      In addition to  pumping and diking, WDNR and the city
 of Appleton  took a  number  of other  measures  to  reduce
 public  health  hazard.  The Department of Public Works put
 up several  hundred   feet of  snow  fence  to   isolated the
 heavily  contaminated   area  from the   adjacent residence.
 The sump pump hose from a nearby house which  was discharg-
 ing into Second Street was rerouted into  the  area of heavy
 contamination.
300.65(b)(3)
security
fencing
 Phase  I:   Collection and Control  of Surface Water

     With   the   immediate  emergency  abated,   WDNR  began
 further   investigation  of the  site  to determine the extent
 of   contamination   and  to  plan for a  more  effective and
 efficient  surface  water control system.

     On  April 15, WDNR selected  CPI to install  a  surface
 water  and  shallow ground  water  collection  system,  divert
 clean  water away  from  the  site  and  to  haul  away  highly
 contaminated  soils.   However,  due to problems  in funding,
 installation  of  the  system was  not begun  until May  18,
 1982.  By  this  time  Soil  Testing  Service had completed the
 first  series  of borings  and monitoring wells  (drilled  on
 May  6  and  7,  1982).  Although this  information  indicated
 that chromium had migrated  to a  depth of 13 feet  (3.9  m)
 in the area of highest  contamination,  the  results were not
 available  in  time to be  used  in  designing  the collection
 system and  this  information is being considered  for  Phase
 II.

     Through  April and   early May,  prior  to the  construc-
 tion of the collection  system, Rocket  Sewer Hauling  con-
 tinued to pump the chrome   contaminated liquid  and  to  haul
 it  to  the  DePere  Sewage  Treatment  Plant.   By  April  14
about  10,000  gallons (38,000  1)  had been  hauled and,  by
May 4,  the volume had reached about  20,000 gallons
 (75,700 1) DePere had only  agreed to  accept  15,000 gallons
 (56,800 1)  and  it was  necessary  for WDNR  to negotiate a
long term contract with DePere.  The  city of DePere Sewage

                                      16-21
-------
Treatment  Plant  was  the  logical choice  for treating  the
contaminated water for the following reasons:

     •  The  plant   ran  very  efficiently  whereas   the
        Appleton  STP,  the  only other  reasonably  close
        plant, had operational  problems  and  occassionally
        had to bypass due to overload

     •  Treatment thus  far had  not  caused any operational
        problems at the DePere STP

     •  Sludge was incinerated  and  the ash disposed of in
        a licensed landfill,  whereas Appleton1s sludge  was
        landspread.

     The major elements of the collection system are shown
in  Figure 6.  The system  includes 3  parallel subsurface
drains which are about 3 feet (1m)  deep and  have the fol-
lowing lengths:

     •  Drain to the north of main track - 325 feet (99 m)

     •  Drain to the south of main track - 275 feet (84 m)

     •  Drain to the  south of  switching track - 150 feet
        (46 m)

     The  drains  were  installed  by  excavating  a  trench
about 2  feet  (0,6 m) wide and  3 feet (1 m)  deep  us ing a
track type backhoe.   The  trenches were sloped at one per-
cent grade to two collection points  as shown in Figure 6.
Four inch (10cm), perforated schedule 40 PVC  pipe was laid
in the trench and surrounded with about  2 inches (5cm) of
gravel.    The  trenches  were  then  backfilled with  native
soils.  Sumps were installed  at each of the two collection
points.    The  sumps  were connected to  each  other by about
25 feet (7.6 m) of PVC pipe so that water collected in  the
sump  south  of the  tracks  could be  pumped  into  a  larger
sump north of  tracks.   The sump on  the  south side  of  the
tracks is  a 4  foot  diameter (1.2 m by  1.2  m)  perforated
concrete cylinder which was installed about 4 feet (1.2 m)
below the grade  of the  railroad tracks.  The sump  on  the
north side of  the  tracks,  located in  the  area  of highest
chromium  contamination  consists  of  two  of  these concrete
cylinders, one on  top of  the  other,  and was installed 6
feet  (1.8 m)  below  railroad track grade.    This sump is
equipped  with  a pump  which  empties  the contents  into a
10,000 gallon (38,000 1) steel tank.

     During installation of  the  sump  on  north side  of  the
tracks,  CPI encountered  layers  and  streaks  of  yellow  and
green  (chromium) stained  soil.    The  contaminated  area

                                     16-22
300.70(b)(l)(ii)
(B)
surface water
diversion and
collection
-------
 contain or   remove   contaminated  ground  water.   The  extent
 of the Phase IV activities will   be  largely   determined  by
 the  results of  a  detailed  hydrogeologic   investigation
 controls which  is currently  underway.   This  investigation
 includes soil  sampling  and  ground  water monitoring  from
 borings  and wells  which  were  completed  by  Twin  City
 Testing in  December  1982.   As of January 19,  1983,  WDNR
 had received the  first set of  ground  water monitoring  data
 from the newly  installed wells, but  the data had not  been
 analyzed.

      Potential  remedial  measures  which WDNR  is  considering
 include the  installation  of deeper  subsurface drains  to
 collect contaminated groud  water, removal  of  additional
 contaminated soils  with  the  possibility of razing the old
 chroraeplating building  to  remove any  contaminated soils
 beneath it.
 COST AND FUNDING

 Source  of Funding

     The  WDNR was  able  to procure  funding  for  the  site
 clean-up  through  the  state's  Emergency  Spill  Fund,
 authorized by  the Wisconsin Hazardous Waste Management Act
 of  1978.  However,  the State of Wisconsin has brought  suit
 against Norbert W.  Mauthe  in  Circuit Court for reimburse-
 ment  of the  expenses incurred  in  the  site  clean-up for
 which  he   is   charged  with statutory  responsibility.   A
 complaint  was filed  in  Circuit  Court by  the Wisconsin    300.68(c)
 Department of  Justice on  October 4, 1982, and a trial is    responsible
 expected. If these  expenses are collected from Mauthe, the    party
 money will be  returned to  the Emergency  Spill Fund.

 Selection of Contractors

     The  WDNR staff  performed  some  of the  initial  site
 investigation and  then  contracted  with  Soil Testing
 Services  in Green  Bay,  Wisconsin  to   perform  a  hydro-
 geologic investigation which was conducted on May 6 and 7,
 1982.  Rocket  Sewer Hauling in Appleton was contracted for
 regular  pumping  and  transportation of the  accumulated
 chromium water to  DePere  Sewage  Treatment Plant.   These
 two contractors were  selected by the WDNR  on an informal
basis  during  the   emergency  phase.     After  the  initial
emergency, WDNR formally sought bids from waste haulers to
haul the  chromium  contaminated water  to DePere.   Rocket
Sewer  Hauling  was  again  selected  because  they had  the
lowest  bid.    The DePere  Sewage Treatment  Plant was  the
 logical choice because the Appleton Sewage Treatment Plant
was  not  equipped   to  accept  the  chromium  contaminated

                                     16-25
-------
water.  SST and Twin City Testing of Appleton responded to
WDNR's  August  31,  1982  quotation request  for  additional
soil borings and of these two firms, Twin City Testing was
selected to provide the additional subsurface exploration.

     After deciding to install a more permanent collection
system, the  WDNR  invited  nine  contractors  to  submit
proposals  for  its  design and  installation by April 14,
1982.   The WDNR  provided  prospective contractors  with the
opportunity  to  visit the  site  and  four  of the potential
contractors  subsequently  submitted   proposals.    Two  of
these  four  proposals  were rejected  on  the  bases  of cost.
A  third proposal  was  rejected because  it  proposed ground
water  pumping which WDNR  felt would  be ineffective in the
low  permeability  soils.    WDNR  judged   the  proposal
submitted by  CPI to be the  most cost  effective  and they
were awarded the contract.

Project Costs

     A  breakdown of  the  project costs  by category  of
activities is shown in Table 6.   This cost information was
derived from purchase orders  from  the WDNR  as   of  mid-
December  1982  and  therefore may reflect  in some  cases
planned purchases  rather  than  actual  services  received.
The  total   amount   spent  on  the  emergency response  and
surface water collection system as of mid-December 1982 is
$72,229.   Since  the Appleton  site has only been  tempor-
arily  contained  and more  complete  actions  are  planned,
this  is not a total  cost.  The  WDNR  is in the  planning
stages  of Phase IV  of the  site  clean-up and reimbursement
is being  sought  for the  costs  of the  emergency  response
and Phase I  from Norbert  Mauthe, the  owner  of  the chrome
plating  facility.    Rocket  Sewer   Hauling  continues  to
transport  contaminated water  to the DePere  Sewage Treat-
ment Plant,  and  thus the  total  expenditure continues  to
increase with time.  Transporting  this  contaminated water
has  been  the  largest portion  of  the clean-up  expense,
comprising over 51% of the total.
Site Investigation—
     The total of $7,643 shown for soil testing is the sum
of two figures:   $1,643 paid  to  Soil  Testing Services for
the initial drilling, sampling and monitoring,  and $6,000
to  Twin  City  Testing  of  Appleton,  WI  for  additional
drilling, monitoring and sampling.  WDNR had just received
the first round of monitoring data  from  Twin City Testing
at the  time  of this writing  (January 1983) and  the data
were in the process of being  analyzed  by the WDNR as part
of the  planning and design (Phase  III)  for the  Phase IV
remedial action.

                                     16-26
-------
Pumping and Transportation—
     As of mid-December  1982,  $41,000 was  authorized for
the  Emergency  Spill  Fund   to  Rocket  Sewer Hauling  for
pumping and  transportation  of  contaminated water.   As of
mid-December  1982,  $38,180 had  actually  been  paid  to
Rocker  Sewer.    This  sum  includes  some  initial  start-up
costs  for  pumping  puddles of water which  were  charged to
WDNR on  an hourly basis.   Therefore, unit  costs  are not
obtained  by  dividing  $38,180  by the  number  of  gallons
transported.   Rather, the unit cost figures shown in Table
7  were taken from Rocker Sewers standard  charge  of $210
per  $3,000  gallon  (11,400  1)  load.   The pumping  and
transportation  costs  for  the  contaminated water  at $210
per 3,000  gallon (11,400 1) load, transported  a distance
of  50  miles (81  km)   to DePere  Sewage  Treatment  Plant
resulted   in a   unit   cost  of  0.14  cents/gallon/mile
(0.02 cents/1/km).

Collection System and Soil Removal—
     CPI was paid  a  total of $13,975  for the construction
and installation of the subsurface drains, the sump pumps,
and the clean water  collection and diversion system.  CPI
also received  a total of  $7,564 for  soil  excavation and
removal.   Transportation  and disposal  costs  for  the
contaminated soil were $6,100  or $61/cubic yard ($80/m ).
Excavation and  loading  costs for the soil  were $1,464 or
$14.60/cubic yard ($19/m  ).

Water Treatment  and Disposal—
     A total of  $2,275  had been paid to DePere  STP as of
mid-December 1982  for  the treatment  and  disposal  of con-
taminated  water.   The unit  cost is  $25 per 3,000 gallon
(11,400 1) load  or less than 0.08 cents  per gallon (0.22
cents/1).  The  total volume  of water  treated and disposed
of was 273,000 gallons (1.03 x 10  1)  as of mid-December.
                                     16-27
-------
             TABLE 6.  SUMMARY OF COST INFORMATION-N.W.  MAUTHE.INC.,  APPLETON, WISCONSIN
Task
Soil Testing, Sampling
Monitoring
Pumping and Transporta-
tion of contaminated
water
Treatment and disposal
of contaminated water
Construction of sump
pumps, drainpipe,
collection system
Transportation &
disposal of soil
Excavation & loading
of soil
Miscellaneous (incl.
steel tank at sewage
treatment plant)
TOTAL
Quantity
N/A
273,000 gallon
(1.03 x 106 J)
273,000 Rallon
(1.03 x 10^ 1)
N/A
100 cu.yds
(76.5m3)
100 cu.yds.
(76.5m3)
N/A
Expenditure
§7,643
$38,180
$2,275
$13,975
$6,100
$1,464
$2,592
$72,229
Unit Cost
N/A
. 14((/gallon/mile
(.02d/l/km)
.8^/gallon
(.2(1/1)
N/A
$61/cubic yd.
($80 per m3)
$14.60/cu.yd
($19/m3)
N/A
Funding Source
Wisconsin Emergency
Spill Fund
Wisconsin Emergency
Spill Fund
Wisconsin Emergency
Spill Fund
Wisconsin Emergency
Spill Fund
Wisconsin Emergency
Spill Fund
Wisconsin Emergency
Spill Fund
Wisconsin Emergency
-SgHl_Fund=i==_= 	
Wisconsin Emergency
Spill Fund
Period of
Performance
April 1982-Jnn. 1983
Continuous since
April 1982
Continuous since
April 1982
May 1982
October 1982
October 1982
April 1982 -
January 1983
PO
CO
                                      N/A:  Not Applicable
-------
PERFORMANCE EVALUATION

     There  is  only limited data  available from  which  to
evaluate  the  performance  of the collection  system at the
Mauthe site.   Delivery logs recording the volume of con-
taminated  liquid   hauled  to the  DePere  Sewage 6Treatment
Plant  indicate  that 273,000 gallons  (1.03 x 10   1) were
collected  and treated  from April through  December 1982.
As  Table  7  indicates,  the concentration of  hexavalent
chromium  in the collection  tank has ranged from 230  to 430
mg/1.  Assuming  an average concentration  of  300  mg/1,  an
estimated  683 pounds  (310  kg)  of  hexavalent chromium was
collected  during  this  8-month  period.   The  surface water
collection  system has  apparently  been  effective  in
minimizing  off-site migration  of  chromium.   However, the
limited  monitoring data  summarized   in  Table 7  does not
permit any  more quantitative evaluation  of performance.

      In  evaluating  performance  of  the  collection  system
installed  at  the  Mauthe Site,  it  is important  to  keep in
mind  that  the  system was  intended  to  collect  surface water
and  shallow ground water  and was not  intended to  remove or
contain  the  contaminated  groundwater which  had  migrated
outside   the  influence  of  the  collection  system.   As
mentioned previously,  a more complete response is planned
 in Phase IV.
                                      16-29
-------
                      TABLE 7.  SUMMARY OF MONITORING  RESULTS AT MAUTHE  SITES1

Location
Well #7
Well #8
Small Crock
Collection Tank
Residence Sump Pump
April 1
Cr+6
(mg
~
—
—
96
Cr Total
1)
—
—
—
110
May 24
Cr+6
(rag
--
~
230
—
Cr Total
/I)
—
~
—
—
June 2
Cr+6
(rag
—
—
250
—
Cr Total
/)
—
--
—
—
1 .
July 7
cr*6
(mg
0,020
73
67
260
70

Cr Total
/I)
0.024
73
'
71
—
74

August 19
Cr*6
(ra
0.020
120
76
430
100

Cr Total
5/U
0.024
110
i — ^-^ .__ ___
78
440
100

I
u»
o
                         analysis was done
-------
                                 BIBLIOGRAPHY


 Arens, A.H.  April  5,  1982.  "Toxic Chemical Spill of 31 March 82."  Outagamie
      County, Emergency Government.  Appleton, Wisconsin.

 Botz, J.J.  May 3,  1982.  "Subsurface Exploration for the N.W. Mauthe Company
      in Appleton, Wisconsin."  STS Consultants Ltd.  Green Bay, Wisconsin.

 Catlin, M.  Catlin  Law Office, Appleton, WI.  October 4, 1982.  Written
      Communication  to  Mr. George Kraft, Wisconsin Department of Natural
      Resources.  Re:   File No. 4430.

 DePere Wastewater Treatment Plant.  September 1982.  "Special Liquid Waste
      Delivery Log."  DePere, WI.

 Eggleson, S.  October  4, 1982.  "State of Wisconsin vs. Norbert W. Mauthe:
      Complaint."  Wisconsin Department of Justice Curcuit Court, Outagamie
      County, Wisconsin.

 Eggleson, S.  Wisconsin Department of Justice.  February 1983.  Personal
      communication.

 Kraft, G.J.  Wisconsin Department of Natural Resources, Green Bay, Wisconsin.
     May 4, 1982.  Written Correspondence to Mr. Dave Benner, City of DePere.

 Kraft, G.J.  June 7, 1982.  Memo to Perry Manor.  "Re:  Mauthe Alternatives"
     Wisconsin Department of Natural Resources, Wisconsin.

 Kraft, G.J.  June 15,  1982.  "N.W. Mauthe Summary."  Wisconsin Department of
     Natural Resources, Green Bay, Wisconsin.

 Kraft, G.J.  August 13, 1982.  Memo to Files.  Mauthe Plating; "June 2,  1983,
     Tank Sample" Department of Natural Resources, Green Bay, Wisconsin.

 Kraft, G.J.  August 19, 1982.  Memo to Files:  N.W.  Mauthe Company. "July 7
     Sampling" Department of Natural Resources, Green Bay, Wisconsin.

Kraft, G.J.  September 7, 1982.  memo to Files:  "Mauthe Plating,  May 6  & &
     Soil Sampling."  Department of Natural Resources, Green Bay,  Wisconsin.

Kraft, G.J.  October 19,  1982.   Memo to Files:   "N.W. Mauthe Company August
     19,  1982 Sampling."  Department of Natural Resources,  Green Bay,
     Wisconsin.
                                     16-31
-------
Kraft, G.J.  Wisconsin Department of Natural Resources November 1982 and
     February 1983.  Personal Communications.

LeRoux  E.F.  1957.  Geology and Groundwater Resources of Outagamie County,
     Wisconsin Geological Survey Water Supply Paper 1421.  Government Printing
     Office, Washington, D.C.

Manor  P.  May 11, 1982.  Memo to Spill Files:  "Early Happenings and Stages
     in the Appleton Chromium Spill."  Department of Natural Resources, Green
     Bay, Wisconsin.

Pagels, J.  May 21, 1982.  "Chromium Spill-Mauthe Plating, Appleton.11
     Department of Natural Resources, Green Bay, Wisconsin.

Soil Conservation  Service.   1978.  Soil Survey of Outagamie County, Wisconsin.
      United States Department of Agriculture and University of Wisconsin.

Wade  K.  and K. Stensby.  1982.  Memo to File of N.W. Mauthe Company,
     '"Chromium Contamination, Appleton, WI."  Department of Natural Resources,
     Green Bay, Wisconsin.
                                       16-32
-------
               OCCIDENTIAL CHEMICAL COMPANY

                    LATHROP, CALIFORNIA
INTRODUCTION

     The   Occidential   Chemical  Agricultural   Products
Company1s Lathrop,  California  facility is  located  in the
San  Joaquin  River  Valley  in  a  rural agricultural  area
about 60 miles (95 km) east of San Francisco, 55 miles (90
km) south of  Sacramento  and  1.0  mile (1.6 km) east of the
San Joaquin River.  Storage and evaporation of rinse water
from  the  fertilizer  and  pesticide  operation  in unlined
surface  impoundments,  and  burial   of  waste  pesticides,
caused  groundwater  contamination near  the  plant.    The
primary  ground  water  contaminants  were  dibromochloro-
propane (DBCP) (1-1200 ug/1) and sulfate (500-7,000 mg/1).
Other  ground  water  contaminants  included  EDB,  sulfolane
lindane, alpha-BHC, delta-BHC,  Dimethoate, and Disyston.

Background

     At various times during the  operation of the Lathrop
plant  since  it  opened  in  1953,  Occidential  Chemical
Company  (OCC) and/or  its  predecessor,   Best  Fertilizer,
disposed  of  process  wastes  into several  unlined surface
impoundments,  and  buried  sol id  pesticide  wastes  in  an
area known as  the  "boneyard."   These wastes resulted from
the production  of fertilizers  and related chemicals, and
the  synthesis and  formulation  (blending  of concentrates
with  inert   ingredients)  of  about  150-200  different
pesticides  for retail  and  wholesale  trade.    Pesticide
formulation began at the Lathrop plant in  1957.  Among the
wastes  disposed  of on-site  were DBCP,   gypsum  (calcium
sulfate),  lindane  and   other   isoraers  of BHC;  ethylene
dibroraide (EDB); heptachlor; ammonia and waste heavy metal
catalysts.    Because  of  its  persistence,  lipophilicity,
mutagenicity, carcinogenic ity and volume  of use,  DBCP was
the  main contaminant  of  concern   in  the  ground  water
throughout the remedial work.

     The problems at the site were   initially suggested in
a December 1978 meeting  between Occidental  and the Cali-
fornia Regional Water Quality  Control Board (WQCB), where
OCC  informed the WQCB  that documents  would be  released

                                     17-1
NCP References
300.63(a)(3)
notification by
federal or state
permit holder
-------
soon  in  ongoing  litigation  showing  that  organic  and
inorganic  chemical concentrations  had  increased  in  the
ground water near  the  plant.   No specifics were provided.
On January 2, 1979 the WQCB received  a letter from the US
EPA  Region  IX  office  noting  that  the  above-mentioned
documents, disclosed  in  an Ohio  court  case,  specifically
alleged  that pesticide disposal  on-site has caused ground
water contamination around the Lathrop  facility.   Follow-
ing an  immediate discussion with the  plant  operators on
Monday, January 5, 1979,  an inspector  from the  WQCB took
samples from the gypsum ponds  on January 6 indicating that
surface sulfate  levels had  risen from 26 mg/1 in 1962 to
1700  mg/1 in  1979.   Pesticide  wastes were also found on
site,   resulting  in another  site inspection  and testing
of   local   drinking  and  irrigation   water  wells.  On
February 8, 1979  the  Libby-Owens-Ford (LOF)  well on the
property  adjacent  to  the Occidential  site was sampled, by
the  WQCB  along with the well  of a  nearby dairy  farmer.
Both  of  these wells  were found  to be contaminated with
DBCP  at about 13 ug/1, and  the  owners were  immediately
advised  to  stop using them.   A consultant for Occidental
later  found  58  ug/1  of DBCP  in  the  neighboring  dairy
farmers  well in  February 1979.   (David  Keith Todd  Inc.
Oct.  1979).   The  state1s  advice  to  the  neighbors was
based  on the assumption that  any level  of DBCP was harm-
ful, which  in turn was  based  on the facts that the state
has had  an action  level  of  1 ug/1 for DBCP and laboratory
animal  tests  showed  that  it  caused  stomach  cancer  at  3
mg/1 as  well  as the  fact  that the U.S.  FDA action level
was 1.5 mg/1 in milk  fat  (55 ug/1 in whole milk) (3/19/79
letter   from Vaughn,  Stockton  sanitary  engineer  to
Robertson, Executive Director  of the WQCB).

Synopsis of Site Response

     The remedial action was carried out under the general
provisions  set  forth  in  a   Consent  Decree  lodged  on
February 6, 1981, and  were  worked  out in detail through
the US EPA's  National  Enforcement  Investigations Center
(NEIC) and  the state  WQCB and  DoHS.  The  "boneyard" of
pesticide wastes, as  well as the contaminated sediments in
the gypsum  ponds were  excavated by  the  end of February
1981.   A  ground  water   extraction/treatment/reinjection
system  was  approved in  January 1982  by  the US EPA and
State of  California, and went  on-line in  July 1982.  The
system extracts contaminated ground water from five wells,
treats  it in a reverse pulse   granular  activated  carbon
systems, and  then  reinjects   it into an  unusable  briny
aquifer  through an  injection  well about  500 feet (90 m)
deep.   The  carbon  system is   intended to reduce the DBCP
concentration,   which  was  agreed  upon  as  the  surrogate
criterion for all  other  contaminants,  from  about  2000 ppb
300.64
preliminary
assessment
300.64UX1)
evaluation of
the magnitude of
the hazard

300.65(b)(2)
providing alter-
nate water
supplies

300.64(b)
collection
or review of
literature
300.68(c)
responsible
party clean-up

300.68(e)(2)
source control
300.70(c)(2)(i)
excavation.
300.70(b)(2)(ii)
carbon
absorption
                                     17-2
-------
 to  an  effluent concentration  of 1 ug/1.   As of  December
 1982 the  effluent  DBCP concentrations being  injected  into
 the deep  unusable  aquifer were  initially between 4-6 ug/1.
 The  use  of  an  additional  carbon  contractor  column  was
 expected  to  enable the system  to  achieve  the agreed  upon
 level of  decontamination.
 SITE DESCRIPTION

      The  surface  characteristics and hydrogeology  of the
 Occidental Chemical  Company  site are discussed separately
 below.
 Surface Characteristics

      The OCC site occupies  approximately  130  acres  on the
 northern edge  of  the San Joquin  Valley (Figure  1).   The
 site is bounded on the north by Louise Avenue and by resi-
 dential areas and  schools on the outskirts of Lathrop.  To
 the east,  west  and  south of the site are  large  areas of
 farmland  that   are   typical of   the  San  Joquin  Valley.
 Southern-Pacific,  Inc.  railroad  tracks  and  Rowland  Road
 bisect  the  eastern  portion  of  the site and  a Libby-Owens
 Ford,  Inc.  glass factory occupies  an area immediately west
 of  the  northern  portion  of the  OCC site.   Besides  the
 Libby-Owens  Ford  company,  other  entities   in  the  area
 include an  Army depot and an Air Products,  Inc.  plant.

     All of  the  land   in  the   area   slopes   gently  north
 toward  the  San  Francisco  delta  (about 2 feet per mile  or
 0.38  m/km)   and  lies  about  10  feet  (3 m)  above mean  sea
 level.   This flat area  is about 35 miles  (56.3  km)  wide,
 bounded on  the  east  by the  Sierra-Nevada range and  on the
 west  by the Diablo  range.   Rainfall  in   this area  of the
 valley   averages  about  11.45 inches  (29 cm)  per  year  with
 80  percent  of this   falling   between   November and   March.
 The annual  evaporation  rate  is  five  times  greater than the
 annual   rainfall  necessitating  a  considerable  need   for
 agricultural  irrigation  water.

 Hydrogeology

     The first 230-foot  (70 m) depth of alluvial  plain, on
which   the OCC   site  is  situated,  is  composed   of  great
 thicknesses  of  interbedded   sands,  silts,  clays,  and
gravels. Several water-bearing units,  located  in  the semi-
continuous  layers   of  sand   and   gravel   in   this  layer,
combine to form  the large aquifer system which lies within
13 to 26 feet (3.9  to 7.8 m) of the  surface  and supplies
the  primary source  of  domestic,   agricultural,  and
 300.68(e)(2)(i)
 (A)population at
 risk
300.68(e)(2)(i)
(E)
climate
300.68(e)(2)(i)
(D)
hydrogeologic
factors
                                     17-3
-------
Figure 1.  Location of Occidental Chemical Company Site
                                             Approximate boundries of  the
                                           •  Occidental Chemical Company
                                17-4
-------
 industrial  water  for  the  area.   The  horizontal perme-
                                                 —A *•
 abilities  in  this  aquifer system vary between 10   cm/sec
 and   10    cm/sec.-  Vertical  permeabilities are lower,
 ranging between  10    and  10   cm/sec.  The overall aquifer
 has  a transmissivity  of  21,000 gallons per  day per foot
 and  a storage coefficient of  7  x 10

      Lying beneath  the aquifer  is  an approximate 90-foot
 (27.5 m)  thickness  of blue and  yellow  clay  which extends
 horizontally  for several miles in all  directions.   This
 layer is  believed  to  be part  of the massive Corcoran clay
 deposit which formed  when the entire  area was flooded by a
 large body of water.   Several  bore  holes and  test wells
 have  confirmed  the  continuity of this clay layer  and have
 uncovered  permeable zones beneath  this  layer which extend
 downward  from about  310  feet (94.5  m)  below the  surface.
 The  waters in  these   lower  zones  are  high  in  dissolved
 solids  and chloride  indicating  a possible connection with
 the  San Francisco Bay Delta.

      The  nearest permanent  surface  water in  the  site area
 is the  San Joquin  River which is about 1 mile (1.6 km) to
 the  west.   Due  to the  arid climate,  flat  topography, and
 permeable  soils,  there are  no well-defined natural drain-
 age  channels connecting the OCC site  area and the  river.
WASTE DISPOSAL HISTORY

     The  present  site  was first developed  in  1953  by the
Best Fertilizer  Company  which constructed several lagoons
to  receive  fertilizer  wastes.    In  1964,  Occidental
Chemical Company  purchased  the  site and  began  manu-
facturing  several  fertilizers  such  as phosphoric  acid,
aqua anroonia, and  ammonium sulfate.   In addition to these
product lines, the OCC plant began formulating between 150
and  200  different pesticides.   Until  1976,  all  liquid
wastes  from  the  pesticide operations  (about  5  tons  per
year) were placed  into a 5-acre pond, labelled 1 in Figure
2.   (There  are  also  undocumented  reports of  pesticide
dumping in a well which is located south of the pesticide-
formulation area and has  since  been  capped.)   In addition
to  the  liquid  pesticide wastes,  this   pond  received
contaminated  cool ing  water  from the 4.5-acre  phosphoric
acid concentrator pond (Pond 2 in Figure 2).  This cooling
water travelled  in a  700-foot  long ditch  connecting  the
two ponds.   Since 1976, all  liquid  pesticide  wastes have
been collected in  tanks prior  to  transport to  an off-site
hazardous waste landfill.
                                     17-5
-------
Figure 2.  Aerial Photograph of the Occidental Chemical
           Company, Lathrop, California
                          17-6
-------
     Between  1964 and  1970 solid  wastes  from  the  plant
were buried  in  the unpermitted "boneyard".   These wastes
included:

     •  Off-specification pesticides

     •  Pesticide containers

     •  Burned solid wastes

     •  Spent catalysts  (Va, Ni, Cu, and  Zn)

     •  Off-specification fertilizer

     •  Spent activated  carbon

     •  Construction debris.

     After  1970,  burial of  wastes  in  the  "boneyard"  was
discontinued  and,  by  1979,  the solid pesticide wastes  and
the spent catalysts were being sent to a California  Class
I landfill.  The other wastes  are presumably  sent  to  other
t ype s o f 1and fills.

     Gypsum  slurry  produced  during   the  manufacture   of
phosphoric acid, has been deposited in  a  number of unlined
settling ponds around the site since 1953  (the most recent
of these are  identified  as  ponds 3  through  8  in Figure  2).
The OCC  facility  has  since  converted  to  a dry phosphoric
acid production  process thereby eliminating  the  need  for
these ponds.

     The only other documented disposal of  hazardous  waste
at  the  OCC  site  involved  a pond  which  received  cooling
water from  the  phosphoric  acid  concentrator.   This pond
was filled in and used as a building site  in  1968.
DESCRIPTION OF CONTAMINATION

     The possibility of ground water  contamination  at  the
OCC  site was  brought to  the  attention  of   the  Regional
Water  Quality  Control Board in 1978.  The Board  did some
preliminary testing of the lagoons and the ground  water  at
the site and confirmed a suspected violation  of OCC1s pre-
viously set discharge standards which expressly prohibited
any ground water or surface water contamination at the OCC
site.

     In  March  and  July  1979,  further  testing of  the
lagoons, burial  ditches,  and  ground  water  revealed the
following contaminants:
300.63(a)(3)
notification by
a federal or
state permit
holder
300.64
preliminary
assessment
                                     17-7
-------
      Lagoons  and  burial  ditches

      DBCP                               Disulfoton

      Malathion                          Dursban
      Me thoxychlor                      DEF

      Dibrom                             Ethion

      Chlordane                          EDB

      Endosulfan                         DDT

      Ethyl Parathion

      ground vater^

        EDB

        alpha-BHC

        delta-BHC

        DBCP

        ETDB
        Benzene Hexachloride  (BHC)

        Ethyl Parathion
        DNBP

        Lindane (gamma BHC).

      The  concentrations   of these  substances  reached  90
ug/1  in some  of the  test wells and 2,000 ug/1 in portions
of  the  ditches  and  lagoons.   Some  pesticides,  primarily
DBCP,  were  also   detected  in  some   private well  water
supplies  in  the  vicinity.   In  addition,  high radiation
levels (up to 113 p Cu/1)  were  detected  in nearby public
wells.  The  source of  these  high levels  were  thought to
come  from the unlined  gypsum  ponds since  the gypsum there
was high in uranium; but naturally high background levels
have not been rulled out.

     As a result  of the  above  investigations, the State of
California  and the U.S.  EPA filed a  lawsuit  against the
Occidental Petroleum  Company  (the parent  company to OCC)
requiring OCC to  initiate  a multi-phased remedial strategy
beginning with  a  comprehensive  study  of  the  site  (Phase
I).   OCC  then contracted with an  outside  firm to conduct
the Phase I  study.  The Phase  I  study was  completed in
December of 1980  and included:

     •  A complete  hydrogeological  assessment  of  the
        entire area
300.68(f)
remedial
investigation
                                     17-8
-------
     •  A  thorough  sampling  and analysis plan  to include
        all quality control/quality assurance measures

     •  A  complete  assessment  of  the type,  concentrations
        and extent of chemicals buried around the site

     •  The  establishment  of  a  permanent  ground  water
        monitoring  system  including  new  wells constructed
        on  the  site  as   we11 as   ex i s t ing  on-site  and
        off-site wells.

     This  study  included  the  development  of  42  monitoring
wells at 14 locations  (3  wells per  location)  at the site.
These  three  wells  at  each   location  were  designed  to
penetrate   three  zones  with  respect  to  the  plume  of
contaminated  ground  water:     1)  the  zone  of  greatest
contamination; 2) the zone in  the middle of the  plume; and
3) the zone just below the plume.   Sulfate  was  chosen as
the contaminant  for indicating  the desired drilling depths
because a  large  amount  of sulfate had seeped from the OCC
site into  the  ground  water,  sulfate was  as  mobile  as any
other constituent  in  the  contaminated plume,  and it could
be monitored  rapidly  and inexpensively.    To  locate  the
three zones at  each location,  three  representatives bore
holes were drilled using  a  dual  tube reverse  air  rotary
rig.  This  drilling method allowed an almost instantaneous
and  continuous  review  of  the  cuttings  by  an  expert
geologist  and  ground  water  sampling  at 10-foot   (3  m)
intervals  for  inorganic constituents (SO, ,  NO-,  pH, NH,,) .
Once  the  desired  depth  for  each  well was   achieved,
permanent  wells  were  constructed  by  drilling  12-inch (30
cm) diameter bore holes with a  conventional rotary rig and
installing 6-inch (15 era)  steel casing with 5-foot (1.5 m)
diameter stainless steel screens.

     Samples  from the monitoring  wells were  analysed for
29 organic  pesticides,  several inorganics,  and  radiologi-
cal assays.  The neraatocide DBCP was found in the majority
of  these   wells  and  six  other chemicals (EDB,  lindane,
delta-BHC,  alpha-BHC, Demethoate,  and Disyston)  were found
in over  10 percent of  the  wells.    Most  of the  other  22
organic chemicals that were  found  were  at  or  near their
detection   limits.   Sulfate  was   the  major   inorganic
pollutant  found  in the wells—exceeding  500 mg/1  at  all
but one test  well site.  All  of  the contaminants  in the
test wells  exhibited decreasing concentrations with depth.
The downward gradient that caused  the deeper contamination
(despite   relatively  low vertical  perraab ilities)  was
created by several deep-pumping  irrigation wells  around
the site.   The  total  area of  ground water  contamination
was estimated  to occupy 1  square mile and reach  a depth of
200 (61 m) feet below  the  surface.   Figures 3  through  8

                                     17-9
-------
                                              * •-*%. N*.  :i-
                                                 i*   *S.i
                                 ^^r-^^fi
                           Louras *••    •      •  £1
                                                             .
                               NOTE: CONCEHTRATIOKS PRESENTED AS    ;;-
                                    MG/L SULFATE 9 DEfTH           ;j

                                  * INDICATES OHPEST OR SHAUOWEST  ;j
                                    OBSERVATION AT THIS SITE
Figure 3.  Averaged Observed  Sulfate Concentrations in

           Shallow Monitoring Wells
(Source:  Camp. Dresser,  and  McKee July, 1981)	
                        17-10
-------
                                                         • -;^  \-_  ::.
                                        tj.&Vtf*- -
                                                7^-iM.in   ^ -v ",|T3i --
                                                5?=*-^ ^;-<:_
                                              : CONCENTRATIONS PRESENTED AS
                                               MG/L SULFATE 9 DEPTH
                                              VINDICATES DEEPEST OR SHALLOWEST
                                               OBSERVATION AT THIS SITE
                  !f>l<;  V^-s.  =,   -
 Figure  4.   Average Observed Sulfate  Concentrations  in  Intermediate
             Depth Moni tori ng We 11s
(Source:     Camp, Dresser,  and McKee,  July,  1981)
                                 17-11
-------
                                                 : CQHCSmiATIQNS PRESENTED AS
                                                  MG/L SULFATE 9
                                                ^INDICATES DEEPEST OR SHALLOWEST ^
                                                  OBSERVATION AT THIS SITE
 Figure  5.   Average Observed Sulfate Concentrations in  Deep Monitoring
             Wells
(Source:     Camp, Dresser, and McKee,  July,  1981).
                                     17-12
-------
                                                  CONCENTRATIONS PRESENTED AS
                                                  ufi/L DBCP 9 DEPTH
                                                  INDICATES DEEPEST OR SHALLOWEST
                                                  OBSERVATION AT THIS SITE
(Source:
Average Observed  DBCP Concentrations  in Shallow Monitoring
We 11 s
Camp,  Dresser,  and McKee,  July 1981)	
                                     17-13
-------
                             • ~*— pi^asSis   NJS
                             -^m^iim^  i
                                   ^s=5^r^:s -v^_^,
                                       V  —-         5i
                                   CONCENTRATIONS PRESENTED AS   **
                                   uS/L OBCP 9 DEPTW          -.:
                                   INDICATES DEEPEST OR SHALLOWEST  ;j
                                   OBSERVATION AT THIS SITE
(Source:
Average Observed DBCP Concentrations  in Intermediate Depth
Monitoring Veils
Camp, Dresser, and McKee, July,  1981)
                           17-14
-------
          *• a      nRes«r/oirs     11
                   S C           !l
                                                  : CONCENTRATIONS PRESENTED AS
                                                   wG/L D8CP 9 DEPTH             ;

                                                   INDICATES DEEPEST OR SHALLOWEST :
                                                   OBSERVATION AT THIS SITE___    3
 Figure  8.   Average  Observed  DBCP Concentrations in Deep  Monitoring We11s

(Source:     Camp,  Dresser,  and McKee,  July,  1981)
                                     17-15
-------
provide  concentrations  of  DBCP  and  sulfate  at  various
depths and locations throughout and OCC site.

     The Phase I  study also  included the  excavation of 16
exploratory trenches and the drilling  of  17  soil borings.
Several  shallow  test  pits  were  also  excavated.    These
activities  revealed the  presence  of  4  hazardous  waste
disposal  trenches  and pits  within  the  "boneyard"  area
containing  thousands of small  (1/2  to 1  pint or  0.25 to
0.5 1) glass pesticide bottles located above and below the
water  table  (see  Figure 2).   These bottles  contained 29
types  of  pesticides   formulated  at  to  OCC  plant.    In
addition, a large  area of  pesticide-contaminated soil was
found  in the southern  portion of Pond 1 (see Figure 2).
PLANNING THE SITE RESPONSE

Initiation of Site Response

     On March 23, 1979, the WQCB issued a cease and desist
order directing  an  immediate  end  to the discharges on the
site  and  compliance with  a site  assessment  and clean-up
schedule  because of  the  public health threat  from DBCP
contaminated ground water.  On November 19, 1980, a "Stip-
ulation  and  Judgement Approving settlement"  was filed to
settle  a  December 18,  1979  complaint against Occidental,
and was lodged on  February 6, 1981.  This  consent decree
provided  the  framework for the remedial action eventually
carried  out  at  the  site.    The  formalization  of the
remedial  action  was delayed from  early  1979  to late  1980
for several reasons,  including the following:

      1.   Occidental  asked the  state to review  the  cease
          and desist  order because they contended that the
          compliance  schedule would  require shutting  down
          the plant.   A revised cease and desist  order was
          issued  on April  27, 1979  that  provided  for  an
          extended compliance  schedule.

      2.   Negotiations on  a  consent  decree  failed  in
          December  1979,  resulting in  the  filling  of the
          above-mentioned  complaint.

      During  the  period between the filling  of  the compaint
 in December  1979, and  the  settling of the consent  decree
 in February  1981, the state, US EPA and Occidental  worked
 together  to study  the  site  and  develop   remedial  action
 alternatives.    When  the  suit was settled on February  6,
 1981,   the  company  and  the  US  EPA  state  had  already
 established  a  rather detailed  remedial plan  and the
 excavation  of  contaminated  material had  already  begun.

                                      17-16
300.68(c)
judicial process
-------
The  excavation and  removal work  was completed  within a
couple  of  weeks,  by  February 25,  1981, in compliance with
the March  1 deadline  imposed by the settlement.

     Following  the  immediate  removal  of  the  source  of
contamination,  the long terra  remedial  plan was developed
during  1981  and placed on-line in July  1982.   Details of
the ground water   extraction/treatment/injection plan were
worked  out  between the U.S. EPA NEIC, the  state WQCB  and
DoHS, and  Occidential.  The last significant approval  was
given   by NEIC  on  January 28,  1982, when  it indicated sat-
isfaction  that  studies performed for  Occidental has estab-
lished  (l) that the  briny  unusable aquifer into which  the
treated  effluent  would be  injected was  isolated from  any
other usable  aquifer; and  (2) that the  extraction system
was  adequate  to  contain,  collect  and  treat  the contami-
nated  groundwater.   When   this  last  approval  was  given,
Occidental began  implementing  the long term remedial plan.

Selection of Response Technologies

     The preliminary  selection of remedial actions for  the
OCC  site  was  made in the  recommendations  section  of  the
final   Phase   I report  and  involved several  proposed
alternatives.    The   criteria  used  to  select   among   the
various mitigation alternatives were:

     •  The chemical  constituents present

     •  The hydrogeologic conditions

     •  The regulatory requirements

     •  Assessment of long-term risks

     •  The size of each mitigative area

     •  Economics

     •  Availability of the technology.

The U.S. EPA  and  the  State  reviewed  and  approved  of  the
alternatives   that were  proposed   in  the  Phase  I  study.
However, there were numerous negotiations on and revisions
to the original remediation  plans  prior  to final approval
of all parties involved.

     The  recommended  remedial  measures for the contami-
nated soils at the OCC site were  proposed after considera-
tion of the following alternatives:

     •  No  action

     •  Excavation and disposal of  contaminated soils off-
        site  at a licensed  facility
300.68(c)
state or federal
evaluation of
clean-up
proposals
300.68(h)
initial
screening of
alternatives
                                     17-17
-------
     •  In situ containment using:

        — Containment barriers
        — Fixation
        — Groundwater gradient modification

     •  On-site treatment.

     Of  these,  the  excavation and  off-site  disposal  of
contaminated soils became  the  method  of  choice  because it
was  shown  to  provide  the most  certainty  that  further
ground water contamination would be prevented.   After this
selection was made,  further selections were necessary to
determine the proper method of closing the excavated areas
and to prevent seepage of any remaining chemical residues.
Several   types  of  capping  material  were  considered
including:

     •  Mixing on-site soils with cement

     •  Hauling in clay from off-site

     •  Asphalt

     •  Cement

     •  Several   types  of  synthetic  liner  including
        Hypalon,  PVC and rubber.

The  option  of hauling  in clay  from off-site  was  chosen
because it was the most cost-effective measure.

     The  suggested approach  to ground  water  remediation
was  counterpumping coupled with treatment and  disposal of
the  extracted  water.   Counterpumping was  selected  as  a
result  of a  comprehensive ' ground  water modeling  effort
under Phase  11 of the overall  plan.   The modeling effort
used parameters  and  constants developed  during  the exten-
sive ground water testing  efforts of Phase I and data from
additional  test  wells which were drilled during  Phase II
of the project.

     The modeling  effort  revealed  that counterpumping was
the  only  feasible  method  to arrest  the northwesterly flow
of contaminants.   The model was then used to determine the
number of  extraction wells, their  placement,  depth, pump-
ing rates, and the seasonal effects of other pumping wells
in the immediate area.
                                     17-18
-------
      Several  treatment  and  disposal  options  for  the
 extracted  ground water  were  evaluated  as   part  of  the
 Interim Phase II study.  Treatment options included:

      •  Air stripping

      •  Carbon adsorption
      •  Ultraviolet oxidation

      •  Peroxide oxidation.

      Of these, carbon adsorption and ultraviolet oxidation
 were selected  for bench  scale  and  pilot plant  testing.
 These tests resulted in the selection of carbon adsorption
 as  the  method  of   choice.    Ultraviolet  oxidation  was
 rejected due  to  lower  performance,  scaling  problems,  and
 the formation of manganese oxide precipitants.

      Disposal options considered  for  the  treated  effluent
 included:

      •   Reuse in the  OCC  process

      •   Spray irrigation

      •   Reuse in cooling  towers

      •   Solar stills

      •   Deep well injections.

      The reuse of  treated  water  as  process  water in  the
 OCC plant was rejected due to  high  dissolved  solids  which
 would ruin  plant equipment.  A further  negative aspect  of
 this  option was  that  the  supply  of  treated  water at  the
 proposed pumping  rates  would  far  exceed  the plant's normal
 requirements.

      The discharge of  treated  water to  cooling  towers,
 spray irrigation equipment,  and/or  evaporation ponds was
 rejected because  the  levels of  dissolved solids  in  the
 treated  water  would  exceed  state  standards,  thereby
 necessitating  unreasonable  expenditures  for  lining  the
 ponds that would  be needed  for  each  of these alternatives.

      Solar  stills were  eliminated from  further  considera-
 tion  because of  possible vaporization of  organics to the
 air  coupled  with the need  to treat  still  bottoms having
high dissolved solids.

     Deep  well   injection  into  a  confined,  unusable
aquifer, located  over 300 feet beneath the ground surface,
was  chosen  as  the  best disposal  method for  the  treated
                                     17-19
-------
effluent after  extensive  testing showed that  this  method
was both feasible and environmentally acceptable.

Extent of Site Response

     The February 6,  1981  settlement did not  specify  any
numerical   clean-up  standards,  but  required  that  the
excavation  and  remedial plan  be carried out "in  a  manner
consistent  with  the  goals  and  standards  stated   in
paragraph IV E  of  (the)  Stipulation," which were general
public  health  goals.   As  with  other  aspects  of  the
remedial action, the  extent  of the  excavation and  ground
water treatment were agreed upon by the U.S.  EPA  NEIC,  the
state WQCB  and  DoHS,  and Occidental.   Generally,  both  the
excavation  and  the  ground  water treatment  levels were
based on a combination of available standards,  contaminant
and site characteristics,  and best professional judgement.

     During the excavation operation in February  1981,  the
decisions concerning  whether  particular  material  would be
disposed in a Class  I  facility,  a  Class  II-l  facility, or
into  the same  trench  were   largely made  on-site.    The
pesticide bottles and  the  visually  obvious  contamination,
referred to by  a WQCB  official  as  type "C"  material, were
automatically disposed  of  at  a Class  I  landfill with  a
minimum  of  testing   to   confirm   the  contamination.
Similarly,  the  backfilled  soil  that  had been  placed  over
the  wastes,  referred  to  as  type  "A"  material,   was
temporarily placed nearby  to  be tested before reusing as
backfill after  it had been found to be clean.

     As  noted  in  the  "Design and  Execution  of Site
Response"  section,   some   of   the  contaminated   soil  was
excavated using the  "mud  wave" technique.   During  this
process, when  the  bulldozer was  consolidating   the
contaminated material  by  driving through  the  saturated
layer.   The  strip   of  soil   behind  the  dozer  blaze  was
visually monotired  by the on-site coordinator.   This strip
of soil had to be inspected quickly before the  water being
pushed by  the  bulldozer could  flow around  the  bulldozer
blade  and   cover  the  soil  again.     The  excavation  was
stopped  when the on-site  coordinator  determined  that  the
strip of soil behind  the bulldozer blade  was  not  contami-
nated.   Thousands  of gallons  of contaminated water  were
pumped from the excavations  and bulked with the  company's
other process waste water for landfilling off-site.   After
a  backhoe had  removed the accumulated solid material  and
placed it on  polyethylene  sheets,  composite samples of 5
or 6  samples per pile were  flown  back to the Raltech labs
via Federal Express  for analysis.  The analytical results
were  returned   within 2-4 weeks,  and  provided   the  WQCB
on-scene coordinator  (OSC) with the  necessary  information

                                     17-20
-------
 for  making  the disposal decision.   Using  this analytical
 data,  the  state and  federal  officials  on-site considered
 the  following  factors  in  deciding  the  fate  of  the
 material:  mobility, based on solubility and soil adhesion
 characteristics   of  the  contaminants;  water  quality
 standards,  if  any,   for  the  particular  contaminant;
 persistence; and the soil type.

     The  use  of   this  procedure   may  be  illustrated  by
 considering  two primary decisions made based  on chemical
 and  physical   characteristics.    First,  the  chemical
 characteristics were the overriding factor in deciding how
 to manage  the  DBCP contaminated  material.   Whether  DBCP
 was  within  the  range  of  confidence  of  the  analysis
 technique (50  ug/1),  dictated whether  the material  would
 go to  a Class  I landfill.    This  was the  primary contami-
 nant  found  in  the type  B  material.    Physical character-
 istics  were  used  to  decide on the disposal  of pellets of
 catalyst  waste.   Any   waste  having   the  unique  pellet
 texture, was put  into overpack drums and diposed of  at a
 Class  I facility.

     The performance  standard of  the  treatment system was
 decided  upon  through a  somewhat more  institutionalized
 process.   Although the  treated  effluent  from the  carbon
 filter  system was  to be injected into an unusable aquifer,
 the  State  of  California and the  US  EPA  required that a
 decontamination standard be  met just in case the unusable
 deep  aquifer  was  found  to   commune iate  with the  upper
 usable  aquifer, and also in case the injection well  leaked
 into  the  surrounding  upper  aquifer  through  which it  was
 injected.  The decontaminated  effluent  level was  set  at 1
 ug/1 DBCP because  it  was concluded that DBCP served  as an
 adequate surrogate criterion and   1  ug/1 was  the existing
 "action  level" set  by  the  state  and supported  by  the
 federal  government.    This  use   of  DBCP  as  a  surrogate
 criteria  for  other  contaminants   was   estalished  through
 results from the pilot scale  testing of the system.   These
 results  indicated  that  when  DBCP  was removed,  all  other
 organic  contaminants   were  removed   to  below  detectable
 levels  except  sulfolane.  The  state  concurred  with an OCC
 study  that determined sulfolane presented  an insignificant
 risk  at  the  residual   levels  resulting  from  the   DBCP
 removal  to  1  ug/1 and  considering the aquifer  where  the
 treated water  was  injected.  The  1 ug/1 action level  (the
 level  at which some  remedial action  such as provision of
 alternative  water  sources  and  source  clean-up  would  be
undertaken)  had recently been  established by  the  state to
manage  a variety  of  DBCP contamination problems  that  had
 recently been  discovered  in  the  San Joaquin Valley.   The
action  figure  was  set at this  level  because, even  through
 the  toxicologists  and epidemiologist  with  the  DoHS

                                     17-21
-------
believed that  0.5 ug/1 might  have been safer,  they were
not confident enough about the existance of  an additional
risk reduction  to recommend  this  level which  would have
required closing the  number of  wells  that  would  be
required, rather  than  the 1.0 ug/1  standard,  which would
require closing only 10% of the wells.
DESIGN AND EXECUTION OF SITE RESPONSE

     The remedial actions carried out at the OCC site were
designed to:

     •  Prevent further leaching of contaminants from past
        disposal areas to ground water

     •  Extract and decontaminate ground water beneath the
        site to preclude offsite migration.

     The fulfillment of the first goal was accomplished by
excavation  of  contaminated soils  within the  site  bound-
aries and capping the  site.   The second goal was achieved
by  installing  a  ground water  extraction,  treatment  and
reinjection system.  The equipment  and  procedures  used to
implement these actions are discussed separately below.

Excavation and Capping

     The initial activity began  in  the  spring of 1980 and
continued through  the summer of 1980 during  the  Phase I
investigations.    The  Phase  I  contractor  excavated  16
exploratory  trenches,   drilled   17  test  borings and  dug
several test pits.  This work was keyed to the area of the
site  which   contains   pond  number  1  and the  "boneyard"
because this is  where  OCC  records  indicated the majority
of  liquid and  solid pesticides  were deposited (see Figure
1).  The exploratory excavation  work led to the identifi-
cation of several localized areas of contamination (Figure
9).

     The  trench  excavations   required  a variety  of
equipment and  procedures depending on whether  the  waste
was  above  or   below   the  water table.     The  following
procedures were used:

     Above water table:

     •  Removal of clean overburden

     •  Excavation of waste materials

     •  Placement of excavated materials on  20-foot (6.1m)
        wide strips of 4 to 8-mil  thick, polyethylene for
                                     17-22
-------
 I
NJ
U>
Approximate Units
of Pond  II
                                   •MM MM •!• MKBVtl

                              fi)    IK Ull III II iOUIMM • UUll lilt HI MNH M M,
                              ~    IMMWina MM mni»itMtl *ua*
                               I    MMC< MM INI* MHIM*. Ill) l«j


                                   ftWK* MM


                              i*f   ItlMIMB « IWCt IMMCI HM.


                              ' t ' fI (IUHIII* to«i taiiHuM nincm


                              •~~1  N
                         Figure 9.   Location of  Exploratory
                         Trenches  and Surface  Seals
                         (From Cannonie  Environmental
                          Services  Corp.,  July 1981)
-------
        temporary  storage.   Other  strips  of polyethylene
        were  placed  over the  wastes  during  non-working
        hours

     •   Selective   removal  of  waste   chemical-containing
        containers   from the   excavated  material  for
        placement  into  overpacks  then  into  Class  I
        dumpsters   (specially  sealed)  prior  to  off-site
        transport  and disposal

     •   Selective  removal of  empty  containers  from the
        excavated  materials  and  placement into  Class II
        sealed  dumpsters  prior to  off-site  transport and
        disposal.

     Below water table:

     •   Backhoe was used  to dig a trench into groundwater,
        creating  a  mud  slurry  from  ground  water and
        existing soil.

     •   Bulldozer  was then  used  to  push  a wedge  of dry
        soil  down  a  ramp  at one  end  of the  trench to
        create  a  wave   of  mud   slurry  primed  with
        contaminated  ground  water  which was continuously
        removed by the backhoe and  a  portable pump

     •   The trench was gradually filled in as  the  process
        continued  and eventually  all  the mud  slurry and
        contaminated  ground water were  removed

     •   The excavated material  was  handled in  the  same
        manner  as   that used on the material from trenches
        above  the  water   table and the  contaminated ground
        water  was  stored in tanks prior to transport  to  a
        licensed disposal site.

     After all  of  the exploratory trenching under  Phase  I
was  completed,  a  decision was  made that, under  Phase II,
some additional contaminated  soils would  be  removed and
that  all  excavations  would  be  sealed  to  prevent any
possible  future contamination.  Figure 9 shows  all  areas
within  pond number 1   and  the  "boneyard"   which were
excavated and  capped  and  Table 1  shows  the type and amount
of  wastes  removed  from these  areas,  their  method of
disposal,  and the  phase  of the  study  in which  they were
excavated.  Table  1  and  Figure 9 show  that  although twice
as much material was excavated under Phase II,  not all of
the  contaminated  soils were  removed and/or capped,  because
all  soils were not  contaminated  with hazardous  wastes.
Therefore, some of the darkened exploratory trenches shown
in Figure 7 contained only non-hazardous wastes.

                                     17-24
-------
 TABLE  1.   SUMMARY OF MATERIALS EXCAVATED AND REMOVED FROM
           THE OCC SITE
Location
T ranch 1,5.4
PT 3
Trench 9, 10, 11
Traoch 1
PT 2 and Adjacent
ATM
PT 3 and PT 4
Tr«nch 9
Overflow Ditch
Overflow Ditch
Wastewater Pond
Material fro*
Pil«a II and X
Excavated fro* B
lay«r Tr«nch 1 & 5
Material Quantity
PHA
1,230 cu. yds.
30 cu. yda.
100 cu. yda.
160 cu. yda.
100 cu. yd*.
120 cu. yda.
PHA
80 cu, yds.
210 cu. yda.
1,265 cu. yda.
992 cu. yda.
366 cu. yda.
Type of Disposal
SE I
Clasa I
Class I
Class II-l
Claas II-i
Class II-l
Claaa II-l
SE II
Claas II-l
Claaa I
Claaa II-l
Claas II-l
Claaa II-l
Type of Material
Bottles, crushed
drums, Soil
Drums, Debris,
Bottles, Soil
Vanadium pellets
and crushed drums
Sand & Vanadium
pellets
Sand & Vanadium
pellets
Vanadium soil mix
Vanadium soil mix
top 2' of soil
Soil from 2'
to 8'
Soil
SoU
(From Cannonie Environmental Services Corp., 1981)
                             17-25
-------
     The excavations  under Phase  II  were conducted  in  a
similar manner to those conducted under Phase I, therefore
these methods  will  not be repeated.   The capping  of the
contaminated areas shown in Figure 9 was accomplished by:

     •  Filling in the excavations (or stripping areas not
        previously excavated) to within 3  feet  (0.9 m)  of
        grade.

     •  Spreading clay  from  off-site borrow  areas  evenly
        in the  3-foot (0.9 m) depressions  and  compacting
        to  a  minimum  thickness  of   1   foot   and   a
        permeability of 10   cm/sec or less.
         Spreading a  2-foot  (0.6 m)
        over  the  clay  to   protect
        cracking.
layer  of clean  fill
it  from  drying  and
     The spreading of soils and clay was done using  bull-
dozers  and  the compaction of the  clay was  accomplished
with four to eight  passes of a tamping foot compactor.  A
nuclear density  gauge  was used to monitor  the  density of
the compaction and the water content of the compacted clay
was monitored  using a  Speedy Moisture  instrument.   The
total sealed area was about 129,000 ft  (11,984 m ), using
approximately  5,200  cubic  yards  (4,000  m)  of  fill
material.

     After  the  caps and  cap  overfill  materials were  in
place,  the  entire   area  was  graded  to  prevent  surface
ponding of rain water.

Ground Water Extraction, Tr^eatment and Reinjection

     Ground water remediation  at  the  OCC  site consists of
five  extraction  wells  coupled   to  an  activated  carbon
treatment plant and  2  injection wells  (Figure 10).   These
components are described separately below.

     The five extraction  wells were drilled  and screened
according  to  the  specifications  in Figure  11.    All
extraction wells  were  initially constructed with a 6-inch
(15 cm) I.D. test well.  The first 50  feet  (15  m)  of each
finished well  is  a  30-inch (7.6  cm) diameter reamed bore
hole with  a 22-inch  (56  cm)  I.D.  by  114  inch (290  cm)
thick  single  plate  conductor  casing.    The remaining
portion  of  each  well  consists  of  a 20  inch  (51  cm)
diameter  reamed  bore hole  cased  with  12 inch  (30.5  cm)
I.D. by 3/16  inch  (0.5  cm)  thick  copper/steel  louvered
casing  in  the  upper  portion and with 8 inch  (20 cm) I.D,
by 3/16  inch  (0.5 cm)  thick copper/steel plain  casing in
the lower 5 feet  (1.5 m).   Extraction wells numbers 1 and

                                     17-26
                        300.70(b)(l)(ii)
                        (C)
                        grading
-------
Figure 10.  Location of the 5 Extraction Wells (EW), the Carbon Treatment
            Plant, and One of the Injection Wells (IW) at the OCC Site
            (From Black and Veatch Consulting Engineers, November,  1981)
                              17-27
-------
Figure 11.  Design Specifications of the 5 Extraction Wells
            at the OCC Site (From Black and Veatch Consulting
            Engineers, November, 1981}.
                          17-28
-------
2 were  fitted with 3-stage vertical turbine  pumps  capable
of pumping  at  a rate  of 300 gallons (1,136 1)  per  minute.
The  prescribed  pumping  rates  of  these  wells  are  150
gallons  (568  1)  per  minute  each  in  the  summer  and  100
gallons (379  1) per minute  each  in  the winter.   Extraction
well number  3  has  a 2-stage vertical turbine pump  capable
of 400  gallons (1,514  1)  per minute although  its  pumping
rate is only 200 gallons  (757 1) per minute  in  summer  and
150  gallons  (568  1)  per  minute  in winter.    Extraction
wells  number 4  and 5  are  fitted  with  2-stage vertical
turbine  pumps capable  of 150 gallons  (568 1)   per  minute
each.  The  present  rate of pumpage from these  wells  is  75
gallons (284 1)  per minute each in the winter  and  zero  in
the  summer.   The higher  rates  of  pumpage  in the northern
wells during the summer  were established  to offset  heavy
pumpage from nearby  irrigation wells located northwest  of
the  site.

     The  carbon absorpt ion  treatment  plant  is joined  to
the  extraction  wells  by 4, 6,  and  8-inch  (10,  15,  and  20
cm)  diameter,  PVC  pipes   rated  at  125  psi   and  with  a
combined  capacity equal to the sum of all  five  extraction
well capacities.  The  treatment unit consists  of 2  upflow
pulsed  bed  contactors,  2 blow cases,  and  a storage  tank
for  spent carbon (Figure  12).  The plant is  arranged  in a
total redundant design  such that only one carbon contactor
is  operational  at  a  time with the  other  contactor  on
standby   in   case  of  failure.  Each contactor  has  20-foot
(6  m)   vertical sidewalls  and  a  10-foot  (3   m)   inside
diameter  capable of holding 40,000 dry pounds  (18,144  kg)
of carbon.   The contactors  are  constructed  of carbon steel
with an  interior coating of  coal  tar  epoxy.   The  spent
carbon  tank, is  also  carbon  steel  with a  coal tar  epoxy
liner.    It  has 10-foot  (3  m)  vertical sidewalls  and  a
10-foot  (3   m)  inside  diameter and  holds  20,000   pounds
(9,072  kg)  of  dry  carbon.   The carbon  blow cases are  6
feet  (1.8  m)  high and  4  feet  (1.2  m)   wide  and  are
constructed  of  unlined  carbon steel.   Carbon is used at  a
rate of  about  5,400 to 11,000  pounds  (2,449 to 4,989 kg)
per month.

     The 2  injection wells  are connected to  the treatment
plant by  12 inch (31 cm)  diameter,  PVC pipe rated  at 200
psi.  Only  one  of  these wells has been in  operation  since
the  remedial action  began in  the summer  of  1982.   The
other well  is  on standby in case the primary well  becomes
clogged or more  injection capacity is needed.   Both  wells
were completed  to  depths of  about  500  feet (152 m)  using
reverse rotary drilling techniques.  In the first 290  feet
(88 m)  of each  well,  there is a 24  inch (61 cm) diameter
bore hole cased with  a  16 inch (41 cm) inside  diameter  by
1/4  inch  (0.6  cm)  thick  high  carbon  steel   pipe.   The

                                     17-29
-------
i
UJ
o
                                                                          CONTACTOB
                                                    I   SPENT FRESH
                                                      BLOWCA5Q BLOWCASE '
                                              	= - •	txj-
                                                                	I	
                                                                                  •Cxh
                                                                           INJECT
                                                                           WELLS
                                        FRATION
                                                      LIQUID PROCESS
                                                      GAG  PIPING
Figure 12.
                                                          Schematic  Diagram of the Granular Activated
                                                          Carbon  (GAG)  Treatment Plant  at  the OGC
                                                          Site  (From Black and Veatch consulting
                                                          Engineers, November, 1981) . _
-------
 remaining 210  feet  (64 m) of  these wells  consists  of a
 15-inch (38  cm) bore hole  cased with 8-5/8 inch (22 cm) OD
 by 3/16 inch (0.5 cm)  thick stainless steel with louvered
 screens at  the  following intervals:

      •  320'  to 328' (97.5  to 100 m)

      •  354'  to 380' (108 m to 116 m)

      •  404'  to 414' (123 m to 126 m)

      •  4281  to 436' (130.5 m to 133 m)

      •  482'  to 492' (147 m to 150 m).

      Figure  13  provides  detailed  specifications  of  the
 injection wells and the well head assemblies.


 COST  AND FUNDING

 Source of Funding

      The entire  remedial  action  was   funded  by  the
 Occidental  Chemical  Company (OCC),  including  alternative
 water  supply  hookups to 28  Lathrop area  residents whose
 ground water wells were  either contaminated or threatened
 with  contamination.  Occidental is making regular payments
 to  the  Department of Health  Services  and  the  Regional
 Water  Quality Control Boards for  their  costs for sampling
 and  testing   as  specified  in  the   consent  decree.
 Occidental also reimbursed  the State and the Environmental
 Protection Agency  for  the  costs  of investigation prior to
 the settlement.   Also,  Occidental  makes  regular contribu-
 tions  to California  universities  for  environmental
 research.

     Under  the   provisions  of  the  February 1981  Consent
 Decree,  OCC  will maintain the  ground  water  treatment
 system until  the year  2001.   As  part of  the  divestiture
 following its recent acquisition of Cities Services, Inc.,
 OCC  sold the  Lathrop   facility  to  the  Simplot  Company.
 However,  the  remedial   obligations  of  the Consent  Decree
 including the  cost of  the  ground  water  treatment  system
 will  continue  to be met by Occidental.    Occidental  will
 retain  ownership of the system, related equipment  and  the
 analytical  laboratory  located  on-site.   The  individuals
 operating the  system  and  laboratory will  be  retained  by
 Occidental.   The sales  agreement  provides  permanent  access
 for  OCC  to  Simplot's property,  to allow  for  system
maintenance.
300.70(d)(2)
provision of
alternative
water supply
                                     17-31
-------
                    1
               '     .81
               hlMMon W«l COMlfudlon PHI*!
                                                                           A-.V-.-t
                                                                           ff  ^^fl^	r	
                                                                           H.    J»l    ^r	
Figure  13.   Detailed Design Specificatoins  for the Injection Wells at  the  OCC Site  (From Lundorff
             and Scalmanini,  December,  1981).
-------
Selection of Contractors

     Contractors were generally chosen on both sole source
and competitive bidding bases, but specific information on
all  major  contracts  was  not  available.    The  drilling
contractor  was  chosen  because  his  familarity ^ with  the
local geology through direct experience was considered the
most  important  factor.   The contract for constructing the
carbon system  was  let  on an  informal  competitive bidding
process  between  two  bidders.    This   contract  was  let
separately  from  the  design  and construction  of the pilot
carbon system.   Contracts  for each phase of the study and
remedial work were  also  let separately,  because  the
Occidental  manager  in  charge  of the project believed that
no  single  contractor  could  offer  the variety of services
needed, but each had a useful  specialty.

Project Costs

     The  cost  information in  this  section  (See  Table 2)  is
based  on verbal communications with involved parties, not
on  invoices.

Testing,  Planning  and Design  Costs
      The  cost  of  the  ground water  modelling  by  Camp,
Dresser  and McKee  (COM) used to  plan the  ground water
extraction  well  placement and prepare  for  the ground water
restoration project,  was about §175,000.  The  cost of  the
soil  and  ground  water  sampling  and   analyses  was  about
$1.25 million.   Most  of  the work was done  by Raltech,  Inc.
Over half  of  the  expense  involved analysis  costs.    The
analyses are now performed on-site  by  the OCC  lab,  which
includes  three  specially-calibrated  gas  chromatographs.
Part of  the total ground water treatment  system  costs  was
devoted   to  design, development   and  construction of  the
system with bench  scale  and pilot scale systems.

Excavation
      The  cost  of  excavation  of  the 4655  cubic  yards
(6088 m  )  of   contaminated material  described in "Design
and  Execution of   Site   Response"  above   and  listed  in
Table 2, was  about  $678,000.  The  primary  equipment  used
for the  excavation was  a Case 450 bulldozer, a Caterpillar
977, and an Case 780  backhoe  with a three  foot bucket.

Transportation and Disposal
      The costs of transportation and disposal were charged
together on a  per-cubic-yard  rate  based on the type    of
material and  the  location.   Since the  site  was  located
directly along  a  highway  1-5,  these  tipping  rates  were
relatively low because of  the  low amount  of wear and tear
expected on the trucks,  compared to what would be expected

                                      17-33
300.70(c)(2)(i)
Excavation
-------
                             TABLE 2.  SUMMARY OF COST INFORMATION-OCCIDENTAL CHEMICAL CO., LATHROP, CA.
Task
Site Investigation
A. Excnv.it Ion

B. Contamination
Transportation and
disposal
I. Class I
1) Extremely
Hazardous

2. Class II-l


Total Removal Cost
C. Groundwater
Restoration
1. Model ling .planning
2. Treatment aystera(b)
Total Capital Cost
D. Operation and
Maintenance
1) Carbon


11) Electricity
ill) Maintenance
Total water treated



Quantity
--
4655 cu.yds. (3, 559m3)

Total:
4655 cu.yds. (3, 559«3)

140 miles (225 km)

735 cu. yds. (562 m^)

15 miles (24 km)
3185 cu.yds (2435 m3)




——



5,400-11,000 Ibs
(11,880-24,200 kg/
month
1749-2000 kwh
—
1.5-2.6 x lOBgallons

(6.8-9.8 x 10B 1)
year
Actual
Expenditure
$1.25 million
$678,000


$247t450



($80,850)


($114,475)

$925.450


$175,000
$1.56 million
$3.91 million


958,320-125, 400/year


$35, 000-40, 000/year
$40,000/year
OiH:$m,320-370-800/
year


Unit Coat
—
$146/cu.yd.
($191/M')





$110/cu.yd.
$144/m3)

$35/cu.yd
($46. »3)



—



90-95^/lb

(1.98-2.09/fcg
4.9 if /kwh
—
0.05-0. 1U
gallon
(0.013-0.029*1)

Funding
Source
OCC (a)
OCC (a)






OCC


OCC




occ
occ
occ


occ


occ
occ


occ

Period of
1979-81
July 1980-
Fcb. 1981





July 1980-
Feb. 1981

July 1980-
Feb. 1981



1980-19C.
1980-1981
1979-1981
'

1980-1981


1980
1980


1980

 I
La
-P-
                 (a) Occidental Chemical Company
(b) Design, Development and construction
-------
 if the  site  required driving along  poorer  quality  roads.
 The thirty cubic (23 m ) yard capacity  trucks  were  filled
 to  between  15-20   yards   (11-15  m  )  because  of  weight
 limitations set by California state  law.   About 274  truck-
 loads of material were  hauled off-site  for disposal.    The
 transportation  distance  to  the Class  I landfill  in
 Coalinga, California was 140 miles (255  km).   The Forward
 Class II-l landfill  in Stockton,  California was  15  miles
 (24 km)  from the site.  The separation of material  into
 Class I  and  II-l disposal  categories  was  based  on  DoHS
 criteria and  best professional  judgement  of the regulatory
 personnel and OCC.   Generally, technical  grade  pesticides
 were  Class  I  and  contaminated  soil  was Class  II-l .
 Containers of   pure pesticides,   including  concentrated
 vanadium pentoxide,  were  further  segregated for  disposal
 as Class I "extremely hazardous."

      The total  cost  for transportation  and disposal  of the
 4655  cubic yards  (6088 m )  of  excavated waste pesticide
 and  contaminated  soil  was  $247,450.    This  estimate  is
 based on the  following unit  costs given verbally by  OCC,
 and an even distribution  of class I materials, noted  by  a
 DoHS  engineer (See  Tables 1,2).   At $110~per cubic  yard
 ($144/m  ),  the  735  cubic   yards  (562  m )  of  Class  I
 "extremely hazardous" material  transportation  and  disposal
 cost  was $80,850.  Aj $75 per cubic yard  ($98/m ), the 735
 cubic  yards  (562 m )  of  Class  I  "hazardous"   material
 transportation  and  disposal cost was  $55,125.    At  $35
 dollars  jjer  cubic   yard  ($46/m ), the  3185  cubic   yards
 (2435 m )  of  Class II-l  material  transportation  and
 disposal cost was $114,475.

 Ground Water  Treatment
      The cost for designing,  developing   and  constructing
 the ground  water  treatment  system  was about  $1.56  million.
 The $175,000  cost for CDM's   ground water   planning   study
 should be  included in the restoration  project  costs.   The
 annual operation  and   maintenance (O.&M.)  costs are  still
 unclear,  but  some estimates were   offered,  and  some can be
 constructed   from engineering data.   Based  on a carbon
 usage   rate   of  between   5,400   and   11,000   pounds
 (11,880-24,300  kg)  per  month and  a carbon cost of 90-95^
 per  pound ($1.98 -  $2.09/kg) the annual  cost  for carbon
 replacement will  be  about  $58,320 - $125,400  per  year.
This  is  based on  the use  of a single  contactor which will
be  changed  to two contactors, and shipping  the carbon to
New York for  replacement  and regeneration.   The  minimum
electricity costs for operating three 7.5 horsepower pumps
 in  the  extraction  wells,   which   draw   at  least  49,090
kwh/year  to  maintain  a  cone  of depression,  is  about
$2,454.  The  estimate of present electricity cost is  about
$35,000  - $40,000/year  for  the entire system.   The annual
300.70(b)(2)(ii)
direct waste
treatment
methods-carbon
absorption
                                     17-35
-------
maintenance  cost  has  been  estimated  at  about  $40,000.
Hence,  the  total  operation  and maintenance  for  treating
1.65  -  2.6  x 10   gallons  (6.8  - 9.8 x 10   1)  of water a
year  (300-500 gallons (1135 - 1893 1) per minute) is about
$133,320  -  $165,400  per  year.   This  is a unit  cost  of
0.05^ to 0.11^/gallon (0.013 - 0.029
     This O.&M. cost estimate is very  tentative since the
system  was  still  being  modified  at the  time of  this
writing (January 1983).  The cost for  carbon regeneration
could increase in the short term when the second contactor
comes on  line.  However,  in the long run this cost should
decrease  as  the  concentration  of the  contaminants  in the
ground  water decreases.   The  replacement  of  the  carbon
system  with  a biodegradation process, which  is now  in a
pilot  scale  stage of  development,  may  also  decrease the
treatment cost  although  the  effectiveness  of  such a
process at  reducing DBCP  concentrations to below  1 ug/1
was  uncertain as  of January 1983.    Finally,  analytical
costs  for maintaining  and  calibrating the  system  should
decrease as  the procedure becomes more streamlined  through
experience.

Alternative Water Supply Cost
     The entire  cost as well as the contracting responsi-
bility  for   the alternative  water supply  system near the
site is being  borne by OCC.  Aside  from the construction
costs, OCC   is paying for  legal fees, right of way acqui-
sition, engineering, state  and  local  permit  fees,  and the
district  connection  fee for  each  resident who  desires a
connection.   After  completion  and  inspection,  OCC  will
turn over  ownership  to  the  Lathrop County Water District.
The  District  will   assume  future  maintenance  responsi-
bility.

     The construction costs are expected  to total  between
$200,000  and  $300,000  when completed  in  February  1983.
This  cost  includes  water main  lines,  services,  fire
hydrants,   and appurtenences  for  two  streets.    An  eight
inch  (20  cm) water  main will  be  installed  along  Louise
Avenue  from  7th Street  west, and north on Harlan Road.  A
twelve  inch  (30 cm) water main will be installed on Louise
Avenue  from  7th Street east to McKinely, and an eight inch
(20 cm) main along McKinely Street south of Louise  Avenue.
A total of 28 residences will be connected.
300.68(i)(2)(B)
Distribution of
costs over time
300.70(d)(2)
provision of
alternative
water supply
PERFORMANCE EVALUATION

     There were  two  types of remedial  actions  at the OCC
site:   (1)  excavation  and  capping of contaminated soils,
and   (2)   ground   water   extraction,   treatment,   and
                                     17-36
-------
reinfection.  The performances  of  these  remedial measures
are discussed separately below.

Soil Excavation and Capping

     The excavation  and  capping of contaminated  soils  at
the OCC  site was done  according  to  specifications  which
were preapproved by U.S. EPA  and  the  State of California.
Since  the  time this  work  was  completed,  frequent visual
inspections  have  shown  no  ponding,   cracking,  or  other
evidences of failure in the capped areas.
Groundwater Extraction, Treatment, and Reinfection

     The effectiveness  of  the ground water remediation at
the  OCC  site  is   evaluated   continuously  through  daily
monitoring of all organic constituents shown in Table 3 in
the  influent  and  effluent   to  the  carbon  absorption
treatment  plant.   DBCP concentration  was  selected as the
key  performance  indicator  after  bench  scale and  pilot
plant  testing showed  it to be  the most difficult pesticide
to remove.  A maximum level of 1  ug/1 DBCP was set as the
performance  standard  for  the treatment system  since the
California  Department  of  Health  services  had previously
established  this concentration as  an "action limit" for
area  drinking water.   This  performance standard was
difficult  to  maintain when   the  ground  water  treatment
began  in July,  1982.

     When  the  system first began  operating,  the average
concentration  of DBCP in  the   treated effluent was about  7
ug/1 with  about a 5  ug/1  fluctuation  about  the mean.  This
was  greater  than a 99 percent reduction over  the  influent
concentrations  which  usually lies in  range  between 1000
and  4000  ug/1.  However, recently  with  the debrigging  go
the  system  completed, US  EPA has  indicated compliance
with  the  consent-degree    mandated  1  ug/1  DBCP  limit.
Further,  the OCC  facility  operator  is  now examining  the
possibility  of  connecting  the  two  carbon contactors  to
double the  carbon  contact   time  and thereby expects  to
reduce the effluent  DBCP concentration below the 1 ug/1
performance  level.

      The  performance  of  the   injection wells  is  evaluated
continuously by monitoring  the piezometric response  of  the
injection  zone.  This  monitoring is  done  through 3  wells
 that were  drilled into the  injection zone.

      In addition  to  evaluating   the performance  of  the
carbon treatment system  and   the  injection wells, OCC  is
required to  monitor the ground water at  over  60 monitoring

                                      17-37
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        TABLE 3.  MONITORING PARAMETERS FOR WELL SAMPLES  COLLECTED  AT  THE
                  OCC SITE.
Major Organic Constituents*
     Alpha BHC
     Beta BHC
     Delta  BHC
     Gamma BHC
Minor Organic Constituents**
     Aldrin
     Chlorodane
     DDE
     DDT
     DBF
     Delnav
     Dieldrin
     Dimetholate

Major Inogranic Const!tuents*
     Chloride
     Conductivity
     Nitrate

Minor Inogranic Constituents**
     Gross Alpha
     Gross Beta
DBCP
EDB
Sulfolane
Heptachlor
Methyl Parathion
Ethyl Parathion
Sevin
Toxaphene
Disyston
2,4-D
2,4,5-T
pH
Sulfate
Uranium
Radium 226
 *Found in significant quantities and/or in a significant number  of wells
**Found in detectible concentrations in one or more monitoring wells
                                  17-38
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wells  around  the  plant.    Table  2  presents  a  list  of
parameters  prescribed  by  the  monitoring  program.    The
major  organics  and  inorganics  shown  in  this  table  are
monitored 3  time per year  and  the  minor  constituents  are
monitored only once a year.  The purpose of the monitoring
plan  is  to  confirm the outputs  of  the  ground water model
on  which  the remedial extraction efforts  are based.   The
model  has  been used  to  predict the  effects  of different
extraction  well  pumpage  rates  and  locations  on  the
movement   of  contaminated  ground  water   plume.    By
continuing to monitor the wells, the OCC facility operator
and the regulatory authorities can determine whether  the
contaminated ground  water is being contained and  removed
according to the chosen configuration and pumpage rates of
the  extraction  wells  (Figures  14  through  16) .    If
descrepancies are found between the predicted and observed
concentrations  of ground  water contaminants,  either  the
model,  the   remedial  design,  or  both  will   have  to  be
adjusted depending on the nature of the  descrepancy.   Thus
far, there is no indication  of a problem with the  present
ground water extraction program.
                                    17-39
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Figure  14.   Predicted Depth Averaged
             (DBCP) After  5  Years of
             Mitigative Pumping
      5>
Reservoir w$$
                                 (From Camp. Dresser, and McKee,
                                  July. 1981).
                            17-40
-------
                                   ^
                              Figure 15.  Predicted,  Depth Averaged
                                           (DBCP)  After 10 Years  of
                                           Mitigative  Pumping
                                      (From Camp, Dresser,  and McKee,
                                       July, 1981).
FEET
                                17-41
-------
"  .'/•X- • -^ •*'  -WE
                 4k OB  *BJ -
               -55" *=M20
                  16.   Predicted, Depth Averaged
                       (DBCP)  After  20 years of
                       Mitigative Pumping
                  (From Camp, Dresser, and McKee,
                   July, 1981).
          17-42
-------
                                  BIBLIOGRAPHY
 Alpert,  Norman,  Hooker Chemical  Company.   December  1982.   Personal
      communcation  with J.  Werner,  Environmental  Law Institute.

 Babich,  H.  and D.L.  Davis   [98],   "DBCP:   A  Review."   The  Science of the  total
      Environment.  Vol 17.   pp 207-221.

 Barr  Engineering Company.   "Assessment of  Environmental  Problems and
      Associated  Cleanup Costs."   Submitted to  Occidental Chemical Company,
      Lathrop, California,  February,  1979.

 Black and Veatch Consulting Engineers.   "Design  Memorandum for  Project  9970."
      Submitted to  the  Occidental  Chemical  Company,  Lathrop,  California,
      November, 1981.

 Camp,  Dresser, and McKee.   "Mathematical Modeling of  Ground  Water Flow  and
      Chemical Transport in  the Vicinity  of Occidental Chemical  Company,
      Lathrop, California."   Submitted  to the Occidental  Chemical Company,
      Lathrop, California,  July,  1981.

 Canonie  Environmental  Services Corporation.  "Development  of Treatment
      Measures for Ground Water Restoration."   Submitted  to the  Occidental
      Chemical Company,  Lathrop, California, July, 1981.

 Canonie  Environmental  Services Corporation.  "Ground  Water and  Soil  Analysis
      Program Near Lathrop,  California:  Phase  I  Study."  Submitted to the
      Occidental  Chemical Company,  Lathrop, California, December, 1980.

 Canonie  Environmental  Services Corporation.  "Soil  Mitigation Measures Western
      Storage Area."  Submitted to  the Occidental Chemical  Company, Lathrop,
     California, July,  1981.

 Caspeel, Roy, Lathrop  County Water District.  January 1983.  Personal
     communication.  J. Werner, Environmental Law Institute.

Dahl, Thomas 0.   "A Hazardous Waste Disposal Problem  vs A  Systematic Approach
      for Imposing Order Into Chaos."  In Proceedings  of the National
     Conference  on Management of Uncontrolled Hazardous Waste Sites,
     Co-Sponsored by the U.S. EPA and the Hazardous  Materials Control Research
     Institute,  October 28-30,  1981,  Washington, D.C.

Dahl, Thomas 0.,  U.S. EPA,  NEIC,  Denver,  CO.   December 1983.   Personal
     communication  with M.  Evans,  JRB Associates.
                                     17-43
-------
Dahl, Thomas 0., U.S. EPA, NEIC, Denver, CA.  January 1983.  Personal
     communication with J. Werner, Environmental Law Institute.

David Keith Todd Consulting Engineers.  "Ground Water Quality in the Vicinity
     of Occidental Chemical Company."  Submitted to Occidental Chemical
     Company, Lathrop, California, September, 1979.

David Keith Todd Consulting Engineers.  "Ground Water Quality in the Vicinity
     of Occidental Chemical Company:  Supplemental Report on Organic
     Compounds."  Submitted to Occidental Chemical Company, Lathrop,
     California, October, 1979.

Harris, John A.  Occidental Chemical Company.  Lathrop, California.  November,
     1982.  Personal communication with M. Evans, JRB Associates.  30

Harris, John, Occidential Chemical Company, Lathrop, CA.  September, 1982.
     Personal communication with J. Werner, Environmental Law Institute.

Hatayama, Howard.  California Department of Health Service.  September,
     December 1982.  Personal communications with J. Werner, Environmental Law
     Institute.

Luhdorff and Scalmanini Consulting Engineers.  "Feasibility of Ground Water
     Injection for Disposal for Treated Effluent."  Submitted to the
     Occidental Chemical Company, Lathrop, California, December, 1981.

Merkley, John, Chemical Waste Mangement, Inc., Coalinga, CA January 1983.
     Personel communication with J. Werner, Environmental Law Institute.

Pinkos, Tom.  California Regional Water Quality Control Board, September
     December 1982.  Personal communication with J. Werner, Environmental Law
     Institute.

Pacific Gas & Electric rate schedule, August 23, 1982.

Schamber, Arnold, R.W. Siegried & Associates.  Stockton, CA., personal
     communication with J. Werner, Environmental Law Institute.

Van de Pol, Ron California Regional Water Quality Control Board, December,
     1982.  Personal communication with J. Werner, Environmental Law
     Institute.

Wheeler, John.  U.S. EPA December, 1982.  Personal communication with J.
     Werner Environmental Law Institute.
                                     17-44
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                                  STROUDSBURG

                                 PENNSYLVANIA


A.  INTRODUCTION                                              NCP Reference

     The  Stroudsburg site  is  located  in the  Borough  of
Stroudsburg, Monroe  County,  Pennsylvania  at  the site of a
historical  coal  gasification plant  (Figure 1-A).   Over a
60-year period EPA  officials estimated that approximately
1-2 million gallons  of  coal  tar  residuals  from  a  coal
gasification plant  were  injected into  nine  well adjacent
to  a  small trout  stream known  as  Brodhead Creek.   Over
time,  the  coal  tar  seeped  from  the  wells  into  the
underlying  gravel  stratum  of  the  streambed.    Erosion  of
the streambed eventually resulted in  the  migration of the
coal tar into the surface waters of the creek.

     In addition  to Brodhead Creek being  widely used for
trout  fishing,  it  is also  a  tributary  of  the Delaware
River  which serves  as the  main  water  supply  to Eastern,
Pennsylvania and as a recreational area.  Due to the broad
usage  of both  the Delaware River  and  Brodhead  Creek,
migration  of coal  tar  into the  creek  posed a  serious
potential health hazard and environmental threat.

Background

     From  1880  to  1940,  Stroudsburg  Gas  Co.  operated  a
coal gasification plant near the  shores of Brodhead Creek.
Coal  tar   residuals   from  the  gasification  process  were
injected into a  well on the  property down into  a  porous
gravel stratum that occurs  approximately 20 feet below the
land surface.   In the early 1900's  the plant also supplied
electricity to  area  residents  via electrical  generators
located on the plant property.

     In 1917,  Pennsylvania Power and  Light  Company (PP&L)
purchased  the electrical  section of  the  Stroudsburg  Gas
plant,  and  acquired  four  or  five  additional  parcels  of
land over the  next 30-year period.  Most  of  this land  was
situated  along the streambed of Brodhead Creek.
                                     18-1
-------
Figure 1-A.  Stroudsburs Site Area and Location Map
                     18-2
-------
     In  1955,  Hurricane  Diane  caused  major flooding along
 the  shores  of Brodhead  Creek,  including  land  owned  by
 PP&L.   In 1960 the Corps  of  Engineers  instituted a flood
 control  program which  involved  straightening  of the creek
 channel  and  construction  of  dikes approximately  50 feet
 high along either side of  the creek.

     During  routine maintenance  of the  dike in the  Spring
 of  1980,  the  State discovered  that  the  s treambed  has
 eroded 6  feet.  This was attributed to  a change in  stream
 flow as  a  result  of  earlier dike construction.  To  remedy
 this problem,  the State began erosion  control work along
 the streambed, placing  the existing riprap  deeper than it
 had been   for  the original  dike construction.   During  low
 water conditions  in October of 1980,  black tarry globules
 (later  identified as  coal tar)  were  observed emanating
 from the base  of the  dike at  an  elevation  of about   375
 feet.   The observed  seepage was in  the approximate loca-
 tion of  the  old coal-gas plant.   The  flow of  the coal  tar
 into the stream  was  nonuniform,  noncontinuous,  and non-
 homogeneous , issuing  from  the  stratum  at  several   points
 along the  side of the  stream,  similar  to springs (Figure
 1-B).

 Syr]opsis of  Si t e _R_esponse

     In  response  to the  discovery  of  the  coal  tar seepage,
 the State  began  investigations to determine the extent of
 contamination  and the level of respon&r   required to alle-
 viate the  problem.   Six months later,    in April of 1981,
 the State and  EPA Region II responded to  the problem under
 the authority  of  Section 311 of the Clean Water Act.  This
 action concentrated  on  oil removal technologies including
 installation   of  filter  fences and   the  construction  of
 inverted dams.

     In September 1981  the State presented its  findings on
 the problem  in  a report entitled the  "Extent of Contamina-
 tion at  Brodhead  Creek."   The  report  recommended  the con-
 struction of a slurry  trench  cut-off wall  to effectively
 contain  the  coal  tar and  prevent  further  migration into
 the streambed.  EPA began construction of the  slurry wall
upon the State's  recommendation.    The  slurry wall  was
 completed in January 1982.

     Concurrent with actions  taken by the  State  and EPA,
PP&L conducted extensive   on-site  geological  and  water
quality  studies  in April  of  1981.   The purpose of  the
studies  was  to answer  questions  concerning the extent  of
contamination  and  the   type of  technology  necessary  for
removal,  not  just  containment,  of  the coal tar.   The
300.63(a)(4)
discovery
300.68(f)
field
investigation

300.65(b)(7)
physical
barriers to
deter spread
of release
                                     18-3
-------
CO
I
-o
                            Figure 1-B.  General  Stroudsburg Site Area
-------
 studies  identified  a  large accumulation  of  recoverable
 coal  tar  in  an  underground   stratigraphic   depression
 located  near the  flood  control   dike.  Based on  this
 information,  PP&L decided that  the most effective means of
 removing the  coal  tar was  to  reclaim  it  as  a  resource.
 PP&L determined  that  the optimum  technology  for  accom-
 plishing this task would be a recovery well  system.   In
 the fall of 1981 PP&L  began  and  completed  installation of
 the system.
 SITE DESCRIPTION

      The Stroudsburg  site plant  is  located  at  latitude
 40°58'50" and longitude 75°llf10", near the urban  area  of
 Stroudsburg,  Pennsylvania,  between the  bridges of  Route
 209 and Route 1-80.

      Surface  Characteristics

      The Stroudsburg  site and  surrounding Monroe  County
 are   located   in   the   Pocono   Mountains   of   eastern
 Pennsylvania.     The  terrain  consists   of  predominantly
 forested, rolling mountains  dotted with  numerous  lakes,
 swamps, and streams.

      The Stroudsburg  site  is located  along one  of the
 lower-most reaches of  Brodbead  Creek,  in  a relatively wide
 valley.  Approximately 200 feet  (61 m)  from the coal  tar
 site,  Erodhead joins  McMichael's  Creek which  flows in  a
 southeasterly  and   then   in   an   easterly  direction  for
 approximately  4 miles, (6.4  km)  eventually emptying  into
 the Delaware  River.

      The  drainage  area of Brodhead Creek  is approximately
 142 square miles  (368  km  ) above the mouth of McMichael's
 Creek.   The  topography of the  watershed   is characterized
 by  moderate to  considerable relief.

     The  average  flow  of  Brodhead  Creek,  based  upon  flow
 records for the past 28 years,  is  2.2  cubic feet (.06 m  )
 per   second   per  square  mile   at  a  point   near  the
 Interborough bridge, upstream of  the site area,  the flow
 of  Brodhead  Creek was  i&easured and was   found  to  be 294
 cubic   feet      (8.2  m  )  per  second.    The  creek  is
 characterized  by  frequent,   yet  brief,   flooding  events
 during  the  7-month  period,   November  through May.    The
highest degree  of flooding,   however,  has been  caused by
hurricane-force storms  that have occurred  during the late
 summer months.  A maximum peak  of  266  cubic feet (7.5 m  )
per  second  per  square mile   was  recorded on August 19,
 1955.  Normal  minimum flows occur in August, September and

                                     18-5
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October and are generally between 5 percent and 10 percent
of  the  average  flow.-3  The ininiinum  flow  recorded  was  0.11
cubic  feet  (.003 m  )  per  second per  square  mile  and
occurred on September 27, 1964.

     The  soils  in the  site  area  are  members  of  the
Holly 300.68(e)(2)(i)(D)  series  and are characterized  by  a
fine loamy texture.  The  hydrogeology  Holly   soils   are
typically deep  (60 inches  (.02 m)  in  factors depth)  and
poorly drained.  These soils were  formed  in  alluvium  that
was derived  from  acid sandstone and shale,  and   occur on
flood plains along major streams.   Slopes  range  from  0 to
3 percent.   Due  to its fine-silty texture,  poor  drainage
and the fact that  they are usually located in flood prone
areas,  construction activities may be  restricted  in areas
consisting of Holly soils.   Excavations can be problematic
due  to  the  high  moisture  content  of  the  soils  and  the
area's  high  flood hazard  potential. The  construction of
embankments, dikes, and  levees  with these soils  requires
addressing  the  problems  that  can  be caused by  piping
(subsurface  erosion).    The   erosion   potential  of  these
soils is low.

     The  local  climate   is   characterized as being humid    300.68(e)(2)(E)
continental.  The average annual daily  maximum and minimum    climate
temperatures  are   approximately  57 °F  (13.9°C)  and  36  F
(2.22°C),  respectively  (3).    The  average daily  minimum
temperatures during the months of  November,  December,  and
January are 29.3°F (-1.67'C), 18.0°F (-7.78°C) and  14.5°F
(-10.0°C)  respectively  (4).    During  the winter  months,
prevailing  winds  blow  from  a  west-northwest direction.
During the summer months,  the winds shift  to  a more west-
southwesterly  origination.    Wind  speeds  average  8   mph
(13 kmph).

     Annual  precipitation ranges between 40  and 60  inches
(>.51 and  1.5 m),  with an average of 45 inches (1.1  m)  per
year.  Average snowfall is  approximately 40 inches (.51 m)
per year.   During the month  of  November,  there is an
average of 3 days  that have  snow cover.   December has, on
the  average,  13 days  with  snow  on the  ground   and  both
January and  February average  18  days each.

     The Stroudsburg site is situated  between the Borough
of  Stroudsburg  to the  west  and  the  Borough  of East
Stroudsburg to the east.   Combining these two areas, there
is a total population  of  approximately  15,000 within a 1.5
(2.5  km)   mile  radius  of  the   site,   which   increases
substantially during the  tourist season.
                                     18-6
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      Hydrogeology

      The Stroudsburg area is  situated   at  the foothills of    300.68(e)(2)
 the Appalachians, in  the Pocono  Mountains  and  is  charac-    (i)(D)  hydro-
 terized by gently rolling terrain,  underlain by  unconsoli-    geological
 dated  valley-fill  glacial deposits.    The  geology of the    factors
 area consists of  at least 60  feet  (1.5 ra)   of  unconsoli-
 dated  sediment   overlying undifferentiated  Devonian  or
 Silurian calcareous  bedrock.  The unconsolidated material
 is  generally  composed  of four different  lithelogics.   A
 typical geologic cross  section consists of  the  following
 units listed  from the top to  the  base  of the stratigraphic
 column; (1)  swamp deposits and  artificial  fill,  (2) coarse
 gravel   alluvium,  (3)  fine   sands   and clayey  silt,  (4)
 ground  moraine or  till,  and  (5)  calcareous bedrock  (See
 Figure  2).  This  section  is locally  quite  variable  and has
 altered extensively  during the  flood control project.

      The material present nearest the  surface is a highly
 variable fill,  consisting of  swamp deposits,  controlled
 fill  from construction of the  dike and assorted "dumped"
 materials.    These  components  occur noncontinuously  over
 the  site  area  and,  in  some  locations,  are  completely
 absent.   Where fill  material  is absent, the  surface  layer
 consists of the  alluvium  material.

      The coarse  alluvium underlying  the  artificial  fill
 consists of  several  sand and  gravel beds  of  varying  ages.
 For the  purposes  of  this report,   however,  the alluvium
 beds  will be  treated as  one  unit.  The  thickness  of  the
 gravel  bed  is  relatively  consistent  throughout most of the
 site  area.  There is  one apparent  pinch-out  or thinning  of
 the bed  occurring  in a  southerly  direction.

      Underlying  the  coarse   alluvium  'are  sediments  that
 range  from medium grained sands  to  fine clayey silt.   It
 is  suspected  that this material  is  a  lake deposit.   Test
 borings  have  revealed gravel  lenses  within this  unit.   The
 lens matrix, however,  is  fine grained.

     The material directly underlying  the coarse alluvium
 and  overlying  the calcareous  bedrock in the   site area,  is
 a  dense gray  ground moraine  or  till.    It  occurs  as  a
 compact  conglomeration of boulders, gravel,  sand, silt,
 and clay.

     The ground water  regime  in the  area  is  controlled  by
 both  the configuration  of glacial  deposits  and   surface
 topography.   Most  of the ground water  that  flows  through
 the glacial material  is  moving  to the  southeast, which  is
 the same general  direction as  surface  runoff.  The  median
groundwater  level  is  typically  10  ft (3  m)  below  the

                                     18-7
-------
 60 ft
(18 m)
                                      Varied  Fill - swamp deposits,
                                      assorted dumped materials, and
                                      controlled fill from dike
                                      construction
                                      Gravel -  coarse gravel alluvium
Sand - medium grained sands to
fine clayey silt with gravel
lenses
                                       Till  -  dense,  grey conglomeration
                                       of  boulders,  gravel,  sand silt  and
                                       clay
                                       Calcareous bedrock
    Figure  2.  Typical Geologic  Cross  Section of  the  Stroudsburg
              Site Area
                                   18-8
-------
natural Land surface and the median saturated thickness is
approximately  65  ft  (20 m)  in  the  region.   With  this
information and the  fact that the overburden  in  the  site
area  is  approximately  60  ft  (18 m)  in  depth,  one  can
expect that most of  the  unconsolidated  material overlying
the bedrock  at the  Stroudsburg  site is  water saturated.
It should  be  noted,  however,  that the term  'aquifer,'  as
used in this  report,  is  meant  to  describe only the  gravel
alluvium.  Water table contours for ground water levels at
the  site   indicate  that  ground  water migration  is  in  a
southeast direction toward Brodhead Creek, with an average
hydraulic  gradient  of 0.015.   Ground water  contours are
based  on  ground  water  level  observations  that  were
recorded in June,  1981.   The ground water  flow rate  from
the site  to  the creek  has  been calculated  using  Darcy's
equation  and   is  estimated  to  be 28  gpra.    The  overall
velocity of  ground  water movement  is  approximately  2  ft
(.61 m) per day.
WASTE DISPOSAL HISTORY

     The   Stroudsburg   coal   gasification  plant   was
constructed  near  the   shores  of  Brodhead  Creek  in  the
middle  1800's.   The plant furnished coal  gas  as fuel for
heat, power and light to residents of Stroudsburg and East
Stroudsburg.   Stroudsburg Gas  Co.  acquired the  plant  in
the  early  1880's  and continued  the  operation until it was
terminated  in approximately 1940.

     The coal  gasification  process at  this site involved
the  destructive distillation  of coal which  left  coal tar
as a by-product.

     Several disposal  methods were  utilized in  the  time
span of  plant  operation.   During  the  plant's  early
operation,  coal  tar,  removed  from  the  reaction vessels,
was  placed in  a  trench  along  the  eastern  edge  of  the
property,  adjacent  to Brodhead  Creek.   The waste products
that  accumulated  in the  holding tanks  were occasionally
"blown down" to the ground.

     During the  late  1800's  and  early  1900's,  technology
developed  to the  extent  that  it  became  possible to remove
commercially valuable  material   from  the coal  tar  waste.
The  residue  from the  recovery  operation  was  disposed  of
through  an injection  well,  Located  in  the  northwestern
quadrant of the plant property where the facility's boiler
house  previously  stood.   The  well  was  constructed  such
that  residuals were  injected  into  the  gravel  alluvium
stratum  that underlies  the  plant  area   and  is  delineated
approximately 20  ft (6.1 m) below the  land surface.  This

                                     18-9
-------
 disposal  method  represented  a state-of-the-art technology
 and  was  an accepted  practice  during  that  time  period.
 Waste  injection was  practiced  at  the  Stroudsburg  plant
 until  its  closing soon after World War IT.

     The  total quantity of coal tar residue in the contam-
 inated  groundwater plume present at the Stroudsburg  site,
 is,  currently  estimated  at  1.8  million gallons  (6.8 x
 10   1)  and  is generally confined  to the gravel  stratum.
 An   underlying  fine  sand  layer  provides  an  effective
 barrier  to  further   downward  migration.    Investigative
 studies have shown the contamination  to  be  spread  over  an
 area approximately 8  acres.  The  largest  concentration  of
 coal tar  has been  located  on the inside  of  the  west  bank
 levee,  in  a   stratigraphic  depression   formed   by   the
 confining  layer of fine silty sand.

     The  coal  tar residue  at Stroudsburg  consists of  a
 light  fraction  that  floats  on water and  a  heavy  fraction
 that sinks.   However,  when  slightly  agitated  in  the
 presence  of water,  the tar breaks  up into  three  phases;
 the  light  and  heavy phases  and a  third  phase of near
 neutral  buoyancy,  that  remains  dispersed   in  the water
 column.   When strongly agitated,  all  the  tar constituents
 dissolve  to a  degree  to  form an emulsion  which  is  very
 slow to separate.

     The  chemical  constituents  of coal  tar  residue  will
 vary depending upon the coal from which it is produced  and
 the  production process utilized.   Coal tar is a mixture  of
 many chemical  compounds,  of  which,  polynuclear  aromatic
 hydrocarbons (PAHs),   cyanides and ammonia,  often  exist  in
 significant  concentrations.    These   compounds  have both
 acute and  chronic health  effects,  some of them known  and
 suspected  carcinogens.    Table  1  describes  the  partial
 analysis  of a  coal   tar  residue sample taken  from the
 Stroud&burg site.
300.68(e)(2)
(i)(B) amount
and form of
substances
present
DESCRIPTION OF CONTAMINATION

     As a  result of the  severe  flood damage  caused by
Hurricane  Diane  in 1955,  a  flood  control program was
initiated by  the  State in  1958.   The program was  insti-
tuted  by the  U.S. Army  Corps  of Engineers under the
State's supervision and consisted of rechanneling Brodhead
and  McMichael fs  Creek slightly  to the  west  of  their
original course and placing the channel within a floodway
lined  with  stabilized  levees.    The levees  which   stand
approximately 50  feet  (15 m)  in  height were  constructed
along the east and west banks of  Brodhead  Creek  and  along
the north and south banks of McMichael's Creek.   The  con-

                                     18-10
-------
  TABLE 1.  PARTIAL ANALYSIS OF THE STROUDSBURG COAL TAR
PARAMETER
Naphthalene
Fluoranthene
Phenanthrene
Anthracene
Dimethyl Naphthalenes
Trimethyl Naphthalenes
Methyl Phenanthrenes
Trimethyl Benzene
Fluorene
Acenaphthylene
Acenaphthene
Pyrene
Benzo( a) anthracene
Chrysene
Benze(a)pyrene
Other

Acidity
PH
Free Carbon (.Carbon I)
Ash
Total Carbon
Total Hydrogen
Total Nitrogen
Sulfur
Chloride
Ammonia
Cyanide
Iron
Copper
Manganese
Zinc
Nickel
Cadmium
Lead
Arsenic
Aluminum
Vanadium
Barium
VALUE
3.60
3.20
2.30
2.30
2.15
1.78
1.50
1.30
0.98
0.74
0.72
0.56
0.31
0.31
0.10
7.84
TOTAL 29.69
0.62
4.6
<0.01
0.00
90.77
8.12
0.17
0.65
50.
0.26
0.18
50.3
2.48
2.11
0.13
0.19
0.01
0.5
12.7
22.4
1.6
0.5
UNITS
7.
fa
"L
to
%
%
%
%
%
%
%
%
%
%
%
%
%
%
%
rag KOH
standard
%
%
%
%
%
%
ppra
ppra
ppm
ppm
ppm
ppra
ppm
ppra
ppm
ppm
ppm
ppra
ppm
ppm
Source:  Villaune, J.F., Lowe, P.C. and Unites, D.F., Recovery of
Coal Gasification Wastes:  An Innovative Approach, Presented at:
The Third National Symposium and Exposition on Aquifer Restoration
and Ground Water Monitoring, May 25-27, 1983, Columbus, Ohio
                           18-11
-------
struction was  completed  in 1960.   The  levee construction
along the shores of Brodhead Creek had a major effect upon
the stream's morphological  processes  and  that  was  to con-
strict its  lateral migration and prohibit the development
of meanders.   This resulted in rapid downcutting  of the
stream channel,  lowering  the channel  6  ft (18 m) over the
next 20  years  and  endangering  the  integrity of  the levee
by undercutting  the  rip-rap placed  along the toe  of the
levee.   By  1980  the  creek had downcut below  the level of
the  rip-rap,   and  action  was  taken  by   the  Pennsylvania
Department of  General  Services  (DCS) in  cooperation with
the municipalities and  the Corps of  Engineers,  to extend
the rip-rap  downward  an additional  10  feet (3  m).   Con-
struction began  in October 1980 and  involved  the  excava-
tion of a trench along the toe of the levee on the western
shore of Brodhead Creek.   During a  low  water condition,  a
black substance, later identified as coal tar residue, was
observed emanating from  the base of the  dike at an eleva-
tion of  375  feet (114 m) .   The  flow  of the  coal tar into
the creek was nonuniform, noncontinuous, and nonhomogenous
and entered the water from several points along  the stream
channel  (Figure 3).

     DCS  completed  the   restoration  and  reported  the
incident   to   the   State   Department  of   Environmental
Resources  (DEP),  Bureau  of Water  Quality  and  the  Fish
Commission.

     In  response  to  the  coal  tar discovery, the State
began investigations  to determine the extent of contamina-
tion and the level of response  necessary  to alleviate the
problem.  An initial preliminary assessment  of the situa-
tion was  made  in March  of 1981.   At  this  time,   it, was
estimated that 3 to 8 million  gallons (11 to  30 x 10  1)
of, co^l  tar was underlying an  area  of  11  acres   (4.5  x
10  m ) along Brodhead Creek and within  a year there would
be significant  leaching  into  the creek.   Based on these
conclusions,  it was  recommended  that  a  more detailed
hydrogeologic investigation be  conducted  to  ascertain the
extent of pollution.

     In March-April,  1981, DER  requested the assistance of
the  U.S.  Environmental   Protection  Agency  (EPA),   in  the
further investigation  of the problem.  It  was also  at this
time  that  PP&L  and  other  affected  property  owners  were
informed of the situation  and ordered by  EPA to  undertake
an investigation of  the  extent of  contamination.   Only
PP&L complied.

     The   investigative   field   studies   that   followed
involved three major  areas; (1)  the hydrogeology  of  the
site  area,  (2)  the  impact of the  coal tar on  stream

                                     18-12
300.68(f)
investigation
-------
Figure 3.  Extent of Contamination at the Stroudsburg Site
                          18-13
-------
quality and its biological community and (3) the erosional
behavior of the stream.

     The  hydrogeologic   field   work  conducted   at   tbe
Stroudsburg site  involved  several  phases;  (1)  test  pit
excavation,  (2)   a  contamination  survey  including  test
borings  and  additional   test  pits and  (3) a  groundwater
monitoring program.

     A  total  of  23 test pits were  excavated during  the
second  and  third  week of  April,  under State  supervision
with  assistance  from the  EPA  Technical   Assistance  Team
(TAT).  The excavations  were made using a  tractor  mounted
backhoe and a  tractor mounted  shovel.  Coal  tar was  dis-
covered  in  nine  of  those  pits.   The  tar  appeared to  be
confined to the  gravel  and cobble layer and  was  particu-
larly  concentrated  on  top of  the  fine  sand  bed  that
underlies the  gravel stratum.

     As a  result  of  the  test  pit findings,  an  extensive
contamination  survey  was  undertaken  by the State  and EPA
in  May,  1981, to  determine  the  extent of  contamination
present and the geological  conditions  affecting  the move-
ment  of the  contaminants  and  their  entry into  Brodhead
Creek.   This  survey was  conducted by  PP&L and  their  geo-
logic  consultant  TRC.   The  subsurface  investigation  that
followed involved additional test pits, test  borings, and
an  electrical resistivity  survey.   Results indicated  that
the contamination extended over an 8-acre   (3.3 x   10  in )
area.  Tbe largest concentration_of coal tar_  an estimated
50,000-100,000 gallons (1.2 x 10  - 3.8 x  10  1) was found
on  the  inside  of the west  bank levee  in  a stratigraphic
depression  underlain  by  a  confining  layer  of  fine  sand
(see Figure 3).

     The depression  is  located  near the old injection
well.   Movement   of  the  contaminants  through  the porous
gravel  appears to be primarily  controlled by  the hydro-
static  gradient  and  the configuration of the  sand  bed.
Movement is generally in the same direction as groundwater
flow which is to  the  southeast,  however,  groundwater  flow
is  not  the predominant force behind  tbe coal  tar's migra-
tion pattern.   If this   were  the  case, a  much  larger tar
concentration would be found downstream and  to the south-
east.   Thus the  specific  gravity  of  tbe coal  tar seems to
have  had  a greater  effect on  its  movement  than  did the
groundwater flow direction.

     A  total of  17  test  borings  were drilled  to determine
the extent of contamination.  At critical   depths,  continu-
ous spoon  samples  were taken.   In  general, the holes
extended at least  10  ft (3 m)  beyond the  last noticeable

                                      18-14
-------
 phenolic  odor  in the  sand.   There  were  several borings
 that  required  an extra 20 ft (6 m) of drilling beyond  the
 sand-gravel  interface.   Eight additional  test  pits were
 also  excavated.

      With the  data collected  from  the  test  pits  and test
 borings,  the extent of  contamination was  estimated.   One
 of the  most  noticeable differences  between the preliminary
 assessment  and  the estimates made  following  the completion
 of the field  investigation  was  the much  smaller  size  of
 the depression  behind  the west bank  levee, which  conse-
 quently lowered  estimates  of the coal tar volume.

      The  calculated  volume  of coal tar in  the  main sub-
 surface reservoir of coal  tar  using the most  recent  boring
 data,  is^etween 26,000  and  103,000 gallons  (9.8 x 10^  and
 3.8 x 10   1) as opposed to the earler estimate of 100,000
 to 150,000  gallons  (3.8 x 10*  and  5.75 1).   The coal  tar
 existing  outside this reservoir  is  not  concentrated  in
 large  depressions.   The coal  tar  found outside  the main
 reservoir either migrated over  the depression lip  or  it
 was disposed of  over  the  entire site  area  and  found  its
 way into subsurface strata.   No  conclusive evidence  has
 been  found to  support  either one of these possibilities.

      The  contaminated  areas   and volumes  of  coal   tar
 present have been estimated and are given in  Table 2.

     The  groundwater  sampling  and  analysis   program
 instituted  at   the   site  revealed  that  polynuclear
 aromatics, benzene, toluene  and  ethylbenzene were present
 in the  shallow groundwater at  either the part-per-billion
 level  or  within  the  range of  known  solubilities of  the
 individual  chemical   species.    The  principal  inorganic
 contaminants,  ie, iron,  aluminum,  manganese  and  cyanide
 were detected at  levels as high as 460, 218,  25.5 and 0.30
 mg/l.   These  contaminants are  responsible   for  the high
 conductivity  readings taken  from  the  water   samples
 collected at the  site.

     The  conclusion  drawn from  the sampling  program is
 that there is a contaminated groundwater  ring surrounding
 the  coal  tar deposits.   The   studies  conducted to date,
 indicate  that the extent of this contamination is  not much
beyond  the main  primary contamination  plume due  to the
absence of drinking water  wells  in the site  area,  it  was
 felt  that the  only  potential  impact of  contaminated
groundwater  would be  on  the  stream,  and because  ground-
water  flow  in  the  area  is  only about  I/5,000th of  the
stream  flow,  the potential  hazard  of  the  contamination
appears negligible.
300.68(e)(2)
(iv) environ-
mental effects
and welfare
concerns
                                     18-15
-------
                TABLE  2.  A REAL AND VOLUMETRIC ESTIMATES OF
                          CONTAMINATION AT THE STROUDSBURG SITE
Subareas
Area inside the dike
( includes area under
the dike)
Area outside the
dike
Island Area
TOTAL
Known Contaminated
Area, in Sq. Ft.
(m2)
210,000
(19,900)
90,000
(8,400)
35,000
(32,000)
335,000
(or 7.7 acres)
(3ha)
Estimated
Thickness
in Ft.
(m)
2 to 15
(0.61 to 4.6)
1
(.31)
1
(.31)
Contaminat ion
Volume
in Cu. Ft.
(m3)
1,642,000
(47,000)
90,000
(2,600)
35,000
(10,000)
1,767,000
(or 130,889 tons
assuming 1 ton =
1/2 ydJ)
(30,400)
Source
     Concurrent with the extent  of  contamination  surveys,
an additional  series  of studies  was  conducted to  assess
the environmental  impact  of the  coal  tar on  the  aquatic
community  and  water  quality  of  Brodhead  Creek.    The
performance  of  the  studies   was  undertaken   by  the
Pennsylvania Fish  Commission  (PFC),   PP&L,  and  PA  DER.
During the  period  from  April-August,   1981,  these  groups,
individually and  in conjunction  with  one another,  con-
ducted various sampling and  analyses  efforts  to determine
the effects, if  any,  of the  contaminant  plume on stream
quality.

     From the  results of the  various studies and surveys
conducted  on Brodhead  Creek it  was  concluded  that  the
stream's water  quality and  biological community  had not
been adversely affected.  However the  presence of the coal
tar  on-site,  a highly  toxic substance,  was  a potential
hazard  to  the  stream1s  integrity  in the  future.   The
potential for detrimental  long  term effects  from  coal tar
seepage  remained  and  the  possibility of a  catastrophic
release  of  tar directly  into  the  stream1s  waters  was  a
primary concern.

     The  third study conducted  at  the  Stroudsburg site
investigated  the  morphological  processes  of Brodhead
300.68(e)(3)(i)
water pollution
problem
                                     18-16
-------
Creek, with particular interest in determining the reasons
for the rapid downcutting that has  occurred  over  the  last
20 years.   Knowledge of  the  mechanisms  involved  and  the
resulting changes in  the  stream's morphology was  of major
importance because the one greatest potential hazard posed
by the  coal  tar is  its  sudden release  in  large  volumes,
caused by down-cutting of the stream bed.  To evaluate the
situation, PP&L  contracted  its  consultants  to report  on
the present  day processes  that  are  determining  Brodhead
Creek* s evolution.

     The investigation concluded  that most  of the channel
down-cutting has occurred as a result of the rechanneliza-
tion  project.   Brodhead  Creek has  a  wide  channel  and  a
relatively  shallow   cross-section   with  alternate  bars
occurring  throughout its  natural  and   man-made  reaches.
These bars  are what produce  the  low amplitude,  long
wavelength  meanders  characteristic  of  Brodhead  Creek.
Straightening of  the stream channel  produced  an  increase
in  stream gradient  which  has  been  documented  to  cause
significant  channel  downcutting.   The  rip-rap  that  was
placed  along  the  levees,  then  perpetuated  the  channel
downcutting  process  by  prohibiting the  channel   to  move
laterally and form meanders.

      It is the opinion of those involved in  the investiga-
tion  that the  channel   morphology  is  close  to  reaching
equilibrium,  although the  channel  gradient  may  still  be
too   great.    It  is,  however,  difficult  to  determine
present-day  rates  of downcutting because  of  the  lack  of
historical and  current  data on  stream  bed  configuration.
Two recommendations   for  monitoring and  limiting channel
instability that were made are listed below:

      •  The  channel   should  not  be  re-aligned,  for  this
        would result  in renewed downcutting

      •  Channel  cross-sect ions  should  be  measured  and
        monitored to determine  if downcutting  is  con-
        tinuing at high rates.
PLANNING THE SITE RESPONSE

jjiitiation of Response

     Once  preliminary assessment revealed that 3  to 8
million gallons of coal tar were underlying Brodhead Creek
and  the  threat  of  continued  coal tar  seepage  into  the
creek  existed,  DER  requested  funding  from  EPA and  the
Coast  Guard  under  Section 311 of  the Clean  Water Act,  to
                                     18-17
-------
 intercept  the  discharge.   Funds  were granted because navi-
 gable water was threatened by the release.   The  immediate
 measures  consisted of filter  fences  and sorbent booms  to
 intercept  the  coal tar moving from  the back channel  area
 into  the  stream.   Additional  studies,  confirmed  by  the
 Pennsylvania  Fish  Commiss ion,  DER  and  PP&L,  determined
 that  the coal  tar  plume is toxic  and  potentially  hazardous
 to  the  ecological  integrity of the stream.   Consequently,
 all  parties agreed  on the  need  to develop  a  long-term
 remedial response  program.   The  result  of the program was
 the  construction  of a slurry  trench  cut-off wall and the
 installation of a  recovery well system.

 Selection  of Response Technologies

      The selection of remedial techniques  at  the Strouds-    300.68(g)
 burg  site  proceeded  under   the  influence  of  complex    development
 interagency   decision-making,   monetary  and   political    of alternatives
 limitations  and  the incertitude  of  the  problem  at  hand.
 Results from the numerous  surveys and studies conducted at
 the site were  not  easily  compared due  to varying degrees
 of control  and  the use of  differing  study methods.   Thus,
 the  difficulty  in forming a single  opinion as to the
 nature  and  extent  of  the  problem, was  complicated  by the
 fact  that  there  were  data  discrepancies  between  the
 studies upon  which  decisions  were to be  based.    The
 remedial  actions  taken  reflect  a  technically  complex
 situation in which there was a continually rising sense of
 urgency due to  (1) the possibility of a sudden release of
 coal  tar  into  the stream  and (2) the  time  and financial
 constraints  involved  in  selecting response  technologies.
The  following  section describes  the  rationale  that  lay
behind   the   selection   of   remedial   techniques   at
Stroudsburg, Pa.

     Remedial actions  at  the Stroudsburg site consisted of
the following:

     (1)  Placement of filter fences and  sorbent  booms to
          intercept backchannel discharge into stream

     (2)  Inverted  dams installed in  sequence with  filter
          fences

     (3) Excavation   of  numerous  recovery  trenches  and
          installation of recovery wells

     (4) Storage   and  disposal  of  drummed  contaminated
         materials

     (5) Installation of  a  slurry  trench  cut-off  wall
         along  the bench of  the west  bank levee
                                     18-18
-------
      (6)  Installation  of a  recovery  well  system  in the
          area of  the coal tar reservoir.

      The  first  action taken in an  attempt  to control the
 contamination problem at  Stroudsburg was by EPA in April,
 1981, under Section 311 of the Clean Water Act (Public Law
 92-500).  The  emergency  action  taken was   initiated as a
 Federal removal activity  and involved the installation  of
 filter fences, sorbent booms, and an inverted  dam  in the
 backwater channel  to  intercept the discharge of coal tar
 and  contaminated  water into  Brodhead Creek.   The filter
 fence  measure  proved  inadequate  when light  rains caused
 the  sheen to  flow around  the  fence.  At this point it was
 dec ided  to  include an  add it iona1  measure and  instal1  an
 inverted  dam.  Thus  the  backwater  channel  was further
 excavated  and  a  filter  fence  and  inverted  dam  were
 installed  in  such   a  way  as  to allow only water to be
 released, preventing  the  flow into the  stream  of  the oil
 sheen  on  the surface and the  insoluble coal  tar  on the
 bottom  (Figure  4-A).   When  one  of  these  inverted  dam/
 filter fence combinations proved only partially effective,
 three additional  filter  fences were  placed  downstream in
 the  backwater  channel  and  another  inverted dam  and two
 filter fences were installed within the  flood gate channel
 (Figure 4-B).   The pipes within each dam,  through which
 clear water flowed, were  emplaced  such  that  the submerged
 ends  were  downstream.  This  containment  technique  was  a
 success until heavy rains caused  the  complete flushing of
 the  backwater  channel,   destroying  the  dams  and  filter
 fences alike.

      It  became   apparent  from   the  occurrences  just
 described, that more  permanent measures would  have to  be
 taken to  prevent  contaminant  release.   With results  from
 the hydrogeological studies,  it  also became apparent  that
 the contamination  at  Stroudsburg  could  not  be  cleaned-up
 in a  relatively short period  of time,  as,  for example,  an
 oil spill could be.   The  coal tar  problem at Stroudsburg
 warranted years  of containment  and  capture.   Funds  for
 remedial actions  at  Stroudsburg  were passed from  Section
 311 to CERCLA (Superfund).  Beginning on November 9, 1981,
 funds  were  appropriated   under  Superfund,  establishing
 Stroudsburg  as   the  first   site   to  recieve  Emergency
 Superfund monies.

     Concurrent   with   activities   involving  the inverted
dam/filter fence installations and  as part of the  "extent
of contamination"  studies, a recovery trench was construc-
 ted  on  the west  bank of  Brodhead Creek to intercept  coal
 tar  that  was  thought  to  be  migrating  into the  stream.
During  construction of  this  trench  no  significant
300.68(e)(l)
initial
remedial
measure
300.70(b)(l)(ii)
surface water
control
300.70(b)
drainage
ditches
                                     18-19
-------
                                                                OILY SUF.RN
OO
 I
to
O
           WATER LEVE!
                                                                           INSOLUBLE COAL TAR
               Figure 4-A. Schematic Diagram of the Filter Fence/Inverted Dam Combination

                           Used at the Stroudsburg Site
-------
Oo
I
N)
             (Inset from Figure  1-B.)
             Figure 4-B.  Schematic  Diagram of Filter Fence/Inverted Dam Installations
                           at the Stroudsburg Site
-------
accumulations  of  coaL  tar  were  discovered,  though  the
ground water did have a phenolic odor.  A 4-hour pump test
of the  recovery  trench  was  conducted  during which pumping
rates  varied  between 53 gallons (200 1) per minute (gpm)
and  157  gpra.   The  water  level was  drawn down  near  the
trench bottom.   No significant  accumulations  of  coal  tar
were  observed  flowing  into  the trench.   Throughout this
phase approximately 20 test pits were excavated in various
locations  along  Brodhead  Creek  to   intercept  coal  tar
migration into the stream.

      In  conjunction with  the excavation  of  test  pits,
recovery wells  (RW's)  were installed  to determine where
recoverable  quantities of  the  coal  tar  were  located.
PP&L's  geotechnical consultants,  TRC,  explored the area
south of  the  recovery trench on the  bench just  above the
backwater channel.   Since  coal  tar was emanating into the
backwater  channel, it  was  thought  that a  recovery well
might  prove  successful in  intercepting  any  contaminant
that  was  reaching  the channel.   Small amounts  of coal tar
were  observed  during  drilling  and  installation  of  the
well, however, recoverable quantities of coal  tar were not
encountered.

      A  second well  was  then  drilled  on  the west side
(interior)  of the west  bank dike  in the  area  where the
stratigraphic depression was  thought  to exist. During the
drilling  process,  increasing quantities of  coal  tar were
encountered  until  the   surface of  the  sand layer  was
intersected.    Below the  sand  layer,   coal   tar  was  not
encountered.   Data  from the  second recovery well (RW2)
confirmed  that  a subsurface  depression  exists   at this
location  and  contains  a  relatively  large  coal  tar
reservoir.   The reservoir  thickness  at RW2 was estimated
to be 10  feet (3 m).

      Different methods  of pumping  from  RW2 were tested and
evaluated to determine  the  feasibility  of  recovering large
quantities  of coal tar  from the reservoir at  a sustained
rate.   It was determined that  it  was possible to  recover
relatively  pure  coal  tar  «1% HO), however,  the  physical
characteristics of the  coal  tar and the  fact that  it is  in
contact with groundwater  limited the  usefulness of  many  of
the  pump  configurations tested.  The  heavy  fraction of the
coal  tar is  slightly denser than  water  and  although  it
separates from water  and will settle  at  the well bottom,  a
minimal  disturbance  will cause  a  mixing of  the  coal tar
and  the water, which produces  an  emulsion that is  highly
300.70(b)(l)
(iUXO
ground water
pumping
                                      18-22
-------
viscous and  resembles  a brown-orange  paste.   Several  of
the pump configurations tested are described below.

     •  Diaphragm suction  pump -  satisfied minimum  dis-
        turbance conditions and  low  shear at pump  intake
        but  maximum   operating   heads were only 20  feet
        (6 m).

     •  Peristaltic  pump  - effect ive  in satisfying  low-
        shear  conditions  and  increased  operating  heads,
        however,  attainable  pump  rate  <.25  gpm  was
        considered insufficlent for recovery purposes.

     •  Gas-powered  suction  pump -  use  of  high  speed
        impe Her   caused   disturbance   at  intake  and
        perpetuated mixing and  horaogenization through
        pump.   Also   flow  rates  of  this   type  of  pump
        difficult to regulate.

     •  Submersible  pump  -  feasible  for recovery  if
        provided with  automatic  shutoff  to  keep  tar/water
        interface above intake.

The  recovery well "system"  installed  at the  Stroudsburg
site  was   initially   powered  by   a  submersible  pump  as
described  above,  however,  due  to problems  that will  be
discussed  in  the  next  section,  it  was   replaced  by  a
nonsubmersible centrifugal electric pump.

     The  debris  and   contaminated  materials  generated
during the Section 311 activities at  the Stroudsburg site,
were  contained  in drums  and  stored  on  site through  the
month  of   November,  1981,  pending final disposal.    The
greatest  number of drums  stored  at one  time was  approxi-
mately  200.   These  included  steel  drums  that  contained
liquid coal  tar and fiber  and  steel  drums that  held solid
waste materials.   Initially the  drums were  stored  on the
ground, in the  open,  with no labels or  other  identifying
markings.   Eventually they were placed on pallets,  covered
with plast ic sheet ing and stored  in a fenced-in area.

     The  materials  generated   during  the  Section   311     300.70(c)(l)
activities  were  disposed  of  at  SCA,  Model  City, NY,     off-site
beginning in  November, 1981.   Contaminated  soils produced     transport
during slurry wall installation were  sent to the  SCA land-
fill  in Niagara Falls, NY, and material  generated  during
the excavation of the  backwater channel during  slurry  wall
construction was disposed of at GROWS,  in Morrisville, PA.
                                     18-23
-------
     On November 9, 1981, remediation funds were appropri-
ated  to  the Stroudsburg  site  under Superfund.   The coal
tar  could  no  longer  be  considered  oil  for  clean-up
purposes.  Remediation of the situation required more time
and money  than  what was  available under Section 311.  The
following  day,  on November 10,  1981,  EPA awarded  a con-
tract  to  the construction firm,  ICOS,  to install a  slurry
trench cut-off  wall  at the site.   The  filter fences how-
ever,  continued  to be  maintained by  the  contractors,
Environmental  Cleaning Specialists, and  Section  311 con-
tinued to  fund  disposal activities.

     The  decision on the  type  of containment system to be
used  resulted  from a  thorough  investigation  of  numerous
alternatives.   Table  3  describes  the  most  prominent  of
these  alternatives,  in  addition  to  the final  measures
taken to  stabilize the situation.

Extent of Response

     The  cleanup response  at Stroudsburg consisted of two
steps.  First,  coal tar seepage  into the creek  was inter-
cepted to protect "navigable  water"  from  contamination.
The  filter  fence,  sorbent boom, and  inverted dam set in
the stream adequately achieved this goal.

     Second,  the  response  officials'  long-term  primary
goal was  to  contain  the  coal tar  plume  such that further
seepage into  the  stream  was  prevented.   The  purpose  of
constructing the  slurry  wall  was to achieve  this  goal  by
creating a barrier between the coal  tar  reservoir and the
stream.   The  barrier wall  essentially cut  across  the
gravel  stratum  which   serves  as  the  pathway  for  the
contaminants.   Other  than  the  minor  excavation of con-
taminated soil  in the  back channel,  once  the barrier wall
was  complete,   the  goal  of  the   response  action  was
achieved.   Continued migration of coal tar into the stream
has been  arrested.  The  effectiveness  of  the barrier wall
is  discussed   in  the   Performance   Evaluation  Section.
Through the operation  of the  recovery well  system,  it  is
anticipated that 50% (approximately 37,000 gallons)  of the
coal tar  present within  the  subsurface reservoir will  be
recovered.   To this date  about   7,500  gallons have been
recovered.  As  such,  the  recovery operation will continue.
300.68(e)(l)
initial
remedial
measures
DESIGN AND EXECUTION OF SITE RESPONSE

     Slurry Trench Cut-off Wall

     The completed slurry trench cut-off wall is 648 ft in
length,  1 ft  wide  and 17 ft (5 m) deep (Figure 5).  The

                                     18-24
300.70(b)(l)
-------
                   TABLE  3.    ALTERNATIVE  RESPONSE  TECHNOLOGIES  FOR  THE  COAL TAR PROBLEM
                                  AT  STROUDSBURG,  PENNSYLVANIA
           Response Technology
              Alternative
                                                    Description
                                                                                      Rational* for  Rejection/Acceptance
                                                                                                    NCP
                                                                                                    Reference
         Filter  Fence/Recovery
           Hell  System
           (Rejected)
Consisted or filter  fences placed at seepage
point* along stream)  recovery well system
Installed In coal tar reservoir area to ulti-
mately remove all coal tar] at tine of proposal
filter fences already on  site and several
recovery wells already installed) in terms of
cost, this system would have required compar-
atively little additional funding.
   Required that PPtL resume responsibility
   and Maintenance of filter tencesj  PPsL
   opposed proposal based on filter  fence
   failure to adequately and consistently
   contain contaminants]

   Complete removal of coal  tar could not
   be accomplished within 6  months specified
   by Superfund policy.
300,70(b)(1)(11)
surface water
control and
300.70(b)(1)(lli)(c)
ground water pumping
         Treatment Plant System
           (Rejected)
O5
 I
Locate treatment  plant on site at one end of
backwater-drained recovery trench) coal tar
and contaminated  water would be pumped and fed
to treatment  system
•  Remedlatlons performed  under Supecfund
   must be complete within 6 months and
   within a 1  million dollar budget treat-
   ment of contaminant could not be
   completed within 6 months]

•  Proposed location foe treatment plant l
   a bank that Is covered  with water 6
   months out  of year

•  Very costly.
300.TO(b)(2)(11)
direct treatment
methods
        Sheet Piling Barrier
           (Rejected)
   Interlocking steel sheet piling to be
   installed along eastern and southern
   boundaries of site and on west side of dike
   to mln. of 15 ft. below surface gradient

   Piles driven to mln of 15 ft. below surface
   gradient or 5 ft below sand/gravel Interface

   Linked to concrete sluiceway on downstream
   side and retaining wall on upstream side

   Area between sheet piling and rip rap toe
   reinforced within concrete cap

   Minimum of 4 monitoring operations to be
   located between sheet piling wall and dike

   Time required for Implementation is
   2 months) well within specified program
   restrictions
   Hot compatible  with  site geology) glacial
   till consists of very coarse gravel type
   material)  problems Inevitably would arise
   due to presence of boulder-siie material

   Pounding Involved In Installation was
   cause for  concern) could change structure
   of aggregation  In flood control leveea
   and disruption  could result
300.70fb) (1)
                                                                                                                                    plume
                                                                                                                                    containment
        (Source:   JRB Associates)
                                                                                                                                             (continued)
-------
                                                    TABLE  3.    (continued)
          Response  Technology
            Alternative
            Description
                                               Rationale for Rejection/Acceptance
                                                                                                    NCP
                                                                                                    Reference
        Steel  Piling  Barrier
          (continued)
Total cost fot job less than
$1,000,QOOt within program
specifications

Recommended that a contaminant removal
program be instituted In conjunction with
barrier
        Building Up and Capping
          Stream Banks
          (Rejected)
Build stream banks up and out into stream
bed

Ensure Impermeability by then capping the
banks with clay material
Temporary in nature) length of time that
situation would be stabilized not
predictable

Very costly
300.70(b)
(D(ilHA)
surface seals
CO
 I
ro
        Slurry Trench Cut-off
          (Accepted)
Cement-bentonite slurry wall  (S.H.)
installed by EPA

Installation along bench on outer face of
west bank levee

Downstream end keyed horizontally into
pressure grouted curtain and  upstream end
keyed  into existing sheet piling wall below
concrete flood wall

Slurry wall la 648 feet long,  1 foot wide
and 12 feet deep) it is keyed 2 feet into
sand stratum underlying the coal tar bearing
gravel at elevation of 365 feet

Top elevation of wall Is 380  feet along
entire length except at one location where
the top elevation of the gravel layer is
higher
Completion of Installation possible
within Superfund policy restrictions
(6 months and one million dollars)

Time was crucial since Superfund money
was being used, a decision had to be made
and construction begun

Cement-bentonite used based on (1)
compatibility test results) (2)
insufficient room onsite for mixing
soil and bentonite and (3) unavailability
of fines on site for a soil-bentonite
mixture
300.70(b)(1)
(iii)W(D
slurry walls
                                                                                                                                                   (continued)
-------
                                                    TABLE  3.    (continued)
           Response Technology
             Alternative
                                                     Description
                                                   Rationale  for  Rejection/Acceptance
                                                NCP
                                                Reference
         Cement-Benton ite
           Grout Cuetain
           (Accepted)
        Recovery Hell System
           (Accepted)
CO
 I
N)
 •  Forms  the  final downstream  segment
    of  the slurry wall}  serves  as a
    continuation of th«  wall  to the dike

 •  Keyed  into clay core of the dike at one
    end and the Blurry wall at  the other

 •  Approximately 50  ft  in length

 •  Constructed using cement-bentonite grout
    and the Method of pressure  grouting
    through a  series of  vertical holes in
    the ground and through the  dike

 •  Recovery project a separate  action fron
    S.M. installation

 •  Four well clusters each containing one
    control well and three surrounding wells

 •  Located  behind west  bank levee to remove
    coal tar from atratigraphlc  depression

 •  Wells contain comparative probes to sone
    tar-water  interface, sending signal to
    controller which turns pump on or off
Excavation of a trench in close
proximity to the dike could have
Impaired dike integcityi decision
therefore made to continue wall to
dike by another means besides a slurry
trench wallj grouting was the most
technically and economically feasible
alternative
PPdL wanted to clean up the site, not
stabilize itj  (EPA was charged by
law to stabilize the situation, not
clean it up)

Realized that any containment barrier
would be complemented by a removal
system
300.70(b)
Uii)(A)(2)
grout curtains
300.70(b)
                                                                                                                                       ground water
                                                                                                                                       pumping
        Excavation of
        Backwater Channel
           (Accepted)
•  Complete excavation of backwater channel

•  Excavated area   350 feet long, 10 feet
   widei 7 feet deep

•  Contaminated materials drummed and disposed
   of G.R.O.W.S. Landfill, Morrisvllle, Pa.

•  Channel then developed and fitted with
   uncontamlnated clay soil and a stone
   rip-rap
Backwater channel was one of the most
highly toxic areas at the site
300.70(c)
(2)(1)
excavation
                                                                                                                                                (continued)
-------
                                       TABLE  3.   (continued)

Response Technology
Alternative
Disposal of Contaminated
Materials
(Accepted)
Polyethylene Liner
(Rejected)
Monitoring Hell*
(Accepted)
Description
• Initially, contaminated materials (solid
and liquid) drummed and e toted on site
• Fiber and steel drums utilized
• Drums stored on pallet and covered with
plastic sheets
• Three landfills used Cor final disposal
{1J BCA Model City, NY
(2) SCA, Hiagra Falls, NY
<3) G.R.O.M.8., Mocclsvllle, PA
• To be placed In slurry wall trench during
construction for added wall strength
• Bight monitoring wells | four located on
either side of wall
• For purpose of monitoring 8.H. performance
and groundwater sampling
Rationale for Rejection/ Acceptance
• Three different disposal facilities used
because of difficulty In locating sites
that (a) would accept the wastes and
(b) would pass Pa. DBR standards and
(c) were within activity financial limits
• Unable to properly place in trench due to
its great length sod weight
• Necessary to determine effectiveness
of wall
—
NCP
Reference
300. 70 (c) (1)
oCf-site
transport
for secure
disposition
300.70(b)(1)
IliiMDlOt
liners

00
t
NJ
00
-------
                                               Groundwater
                                               level
              Figure 5.  Cross-Section — Brodhead Creek

Source:   ELI  report (1982)
                           18-29
-------
slurry wall extends down  through the  gravel stratum that
bears  the  coal  tar  and  is  keyed  2  ft  (-6  m)  into  the
underlying sand  layer.   It was  not necessary  to  key  the
wall  into  an  impervious  aquiclude, due  to  the  floating
nature  of  the  coal  tar contaminants  on  the  sand  layer.
The overall surface elevation of the wall  is approximately
380  ft  (132  m)  above sea level.   The  upstream end of the
wall is keyed into a sheet piling gate that is part of the
existing  flood dike.   The downstream  end of the  slurry
wall  is horizontally  keyed into  an impermeable  ceraent-
bontonite grout  curtain.   The curtain  was  constructed to
form  the final  downstream segment  of the  barrier  wall
because  it  was believed  that  trench excavation  in close
proximity  to  the  dike  would  have  impaired  the  dike's
integrity.   The grout  curtain was  installed by pressure
grouting through a series of vertical holes in  the ground.
The curtain  is approximately 50 feet long.

     Pre-excavation  for the slurry wall installation began
on November  16,  1981 and  actual wall construction commen-
ced  9  days   later.   A ramp was  constructed  as an access
road  for heavy equipment used  during  project  operations.
During  trench excavation earth  was removed  with a backhoe
and  the  contaminated material was  separated,  and hauled by
a  track-mounted bucket  loader to  a small  storage basin
on-site.  The stored material was  periodically  loaded onto
a sealed truck and transported to  SCA Disposal  Services in
Niagara  Falls, NY.

     In  excavating  the slurry  trench, a  calculated risk
was  taken regarding containment  of  the  coal  tar plume.
The  plume  configuration was such  that  there were  several
areas  extending  out  under  the stream bed.  Initially, EPA
suggested  excavation  of  the  areas,  but   the  PA  Fish
Commission opposed,  claiming that  excavation  would be more
detrimental  than taking no action.   It  was  decided that
instead  of  excavating,  the 'lost1 plume areas  were capped
and  rip-rapped.   (See Figure 6).

     Under  EPA  supervision,  compatibility  testing was
conducted  to determine the  most  appropriate slurry wall
composition.   The decision to use a cement-bentonite mix-
ture  was based upon three  factors;  (1) the  compatibility
test  results,  (2)  the lack of  area for  on-site  mixing of  a
soil-bentonite  backfill  and  (3)  the  unavailability of
local  clays  for  use in  a soil-bentonite  backfill.   The
cement-bentonite  slurry mixture,  used  both as the  slurry
to  keep the  trench open  during  excavation  and  as the
cut-off wall materials  itself,  was prepared  using  four
standard sized  bags  of  bentonite  and 11 bags  of cement per
3  cubic yards.   The selected mixture has a design permea-
bility of  1  x 10    cm/  sec  and  is considered  sufficient  to
slurry walls
300.70(b)
(iii)(A)(2)
grout curtains
300.68(i)(2)(E)
adverse  effects
                                      18-30
-------
                             Lost  Plume  Areas
Figure 6.   Lost  Plume  Areas  After  Slurry Wall
           Installation  at the  Stroudsburg Site
                      18-31
-------
contain the  coal tar.   This judgement,  is  based  on  the
assumption that  the  contaminant  moves slowly  through  the
gravel stratum, and the gravel material has  a  much  higher
permeability than the cement-bentonite.   The  original wall
design included the use of  a  polyethylene  liner  along  the
wall's interior for added impermeability.  The length  and
weight of  the material,  however,  caused  problems  during
attempted installations and  as  a result the material  was
never utilized.

     The cement-bentonite slurry trench cut-off  wall  was
installed  in  sections.    Construction  initially   began
downstream (see Figure  7) near the  drainage  way, however,
problems arose  due  to  the   narrow  bench  from  which  the
trench was being excavated  and the  cohesionless  nature of
the  random  fill that  had  been  used to  cover  the levee
core.   Instability on the upslope side of  the  trench
caused  several  sections to collapse  repeatedly.   The
decision was made to  continue upstream  as  far  as the ramp
and when the  ramp was reached,  construction  activity then
began at the  downstream end once again,  but  this time the
bench was widened  and relocated farther from  the  control
levee to minimize the possibility of collapse.  Following
wall  completion  at  this  end, construction  began  at  the
upstream end  near the retaining  wall and  moved downstream
towards the  ramp.   The  section  containing a gas line  was
excavated by  hand.   The final  section to be  completed was
that which contained the access ramp.

     Over   the   course   of   construction,   cold   weather
conditions  including rain  and  ice  storms,  periodically
hampered operations but never entirely halted  construction
activities.

     The slurry  wall  was  completed  on  December  15, 1981,
at which time drilling  for the grout  curtain,  installation
at  the  downstream  end of the wall  had  been  completed and
grout  injection  had  begun.   The  cement-bentonite grout
curtain was completed within 7 days.

     The wall design that  was  finally chosen  for con-
struction at  the Stroudsburg  site had a surface elevation
of  380  feet  (116 m).   This design  dimension  caused some
disagreement.   The  viewpoint held  by the  State  at  the
time, was that the wall surface  elevation should have been
lower (approximately  378  ft)  (115 m) to allow groundwater
to  flow over  the  wall.  The rationale  was  that  by  not
allowing  flow over  the  wall and  impounding   the   ground
water behind  the barrier, there was  the  possibility that
the  coal  tar would  build up and eventually discharge  in
the  swamp area  behind  the  levee,   forming  a  small lake
which could  then drain  through the  floodgate tributary and

                                      18-32
-------
tf 3SO-0
                                                      CteeX.
                         EI36GO
                                                                                         a
                                                                                         i'
                                                                                         
-------
into Brodhead  Creek.    In  support of the  lower  elevation
design,  there  was  no  evidence  provided  by  the  stream
quality  studies  that  there had  been  stream  degradation
caused by contaminated groundwater.  It was therefore felt
that ground water  flow over the wall and  into  the stream
was  not  a  potential   hazard  to  stream  integrity.    The
State's primary concern was to  contain  the coal  tar which
existed at the lower portion of the groundwater column.

     EPA  representatives,  on  the  other  hand,   were
concerned  about  the  contaminated  groundwater   issue  and
recommended a   wall with   a  surface elevation  of 380 ft
(116 m), to prevent groundwater flow over  the  wall.   This
design was eventually implemented.

     The  surface  elevation is  380  ft   (116  ra)   over  the
wall's length  except  for  a 100 ft  (30  m) section in the
northern  area  of  the site (see Figure  7).    The gravel
stratum  elevation  along this segment  is higher  than any-
where  else  and therefore  the  wall surface was constructed
at  382 ft (116 m).   The wall  bottom elevation  is 365 ft
(111 m)  everywhere except  along a section  that is  approxi-
mately 170 ft  (52  m)  long,  where  the  gravel  stratum is
extended  to  a  greater  depth.    This wall  section  is
adjacent  to  the stratigraphic depression behind  the levee
to  the west.

     The  following  task involved restoration of  the  levee
bench  in order  to  permit  the  installation of  monitoring
wells.  Once  this  was completed,  eight monitoring wells
were   installed in  support of  a state  supervised ground-
water  sampling program to  determine groundwater  quality in
the vicinity of the  wall. Four wells  are located on the
stream side of the wall,  three wells are situated on the
 inland side of the wall,  between the wall and  the  levee,
and one  well  is  located behind  the  levee and behind  PP&L1s
 retaining wall.

      Excavation
      The next  phase  in  the  Stroudsburg operation was the
excavation  of  contaminated  materials   from the backwater
channel.  The  excavated area  was 350 feet  (107 m) long,  10
 feet (3  m) wide and 7  feet (2  m)  deep.  Approximately 280
 cubic yards of contaminated material were removed, drummed
 and disposed  of at  a secure  landfill  in  Morrisville,  PA,
 The excavated  channel was then dewatered and  backfilled
 with  approximately 600 cubic yards of  uncontaminated clay
 capping soil.  In addition, about 300 cubic yards of access
 ramp  material were   then  placed  over the  clay  capping
 which,  in  turn,   was  overlain  by stone  rip-rap.    In
 concurrence  with  the channel  excavation/backfilling
300.70(c)(2)(i)
excavation
                                      18-34
-------
 process,  several  other  restoration  activities  were
 underway and  these included  the  following:

      •   Restoration of  the  flood control dike

      •   Hydroseeding of dike and other areas disturbed by
         site  activities

      •   Asphalting the  private  road  (Union  Gas  property)
         used  by  site activities.

      By   the  end  of January,   1982,  demobilization  and
 general  clean up  had been  completed at  the  Stroudsburg
 site.

      Recovery Well  System
      The   recovery  well   installation  project  at  the
 Stroudsburg   site  was initiated  and completed privately by
 PP&L.  This   part   of   the   response   program did not fall
 under  Super fund   funding  due   to  restrictions  inherent
 within the Immediate Removal Program.   Actions under this
 program  are   implemented to  stabilize  or  control problems
 but  not  necessarily  solve  them.     Stabilization  of  a
 problem must  be  accomplished with less than $1,000,000 and
 within a  6-raonth period, and operation and maintenance may
 not be  provided  after the end  of  the  6  months.  The coal
 tar  recovery  system clearly  did  not  fall   within  these
 specifications.    PP&L  felt  however,  that  any  amount  of
 contaminant  that  was   feasibly recoverable  should  be
 removed  and   thus  installed  a  recovery  well system.   It
 should be noted  here that  neither  the slurry wall nor the
 recovery well  system  could  have  properly  solved  the
 problem  alone.   The wall  stabilized  the  situation but was
 not  installed with  the  intention that  it  would eliminate
 the  source  of the  problem.    The  recovery wells,  on  the
other hand,  were  installed  to  remove coal  tar from only
one  location, leaving  other  contaminated  areas  without
 remediation.    These points  and others  will  be  further
discussed in  the next section, "Performance Evaluation".

     The  recovery  well  system consists  of  four  well
clusters  located  throughout the  stratigraphic  depression
that contains the  reservoir  of  coal  tar  (Figure 8).   Each
well cluster  has been installed  in a  30-inch (91-cra)  hole
and consists  of four 6-inch (15 cm)  gravel packed, slotted
PVC pipes for  recovery,  centered around one 4-inch slotted
PVC pipe  used for monitoring  (Figure 9).  The  pump  con-
figuration originally selected to power the  recovery well
system was a  submersible pump with an automatic  shutoff.
This choice,  however, did not prove  to be  suitable because
the  coal  tar rapidly   destroyed  the  pump  and  several
300.70(b)(2)
UiiXc)
groundwater
pumping
                                     18-35
-------
00
I
                  Slimy Wall
                                                                                8ILTY SAND
                 Figure 8.  General Cross  Section Through the Stroudsburg  Coal Tar Site
                                 (Source:  Paper by J.F. Villaume  1982)
-------
00
I
U)
                                                                     Monitoring Control Well
                                                                     Recovery Well (4 Total).



                                                                     Pump Control Sensors
                     SII.TY SAND
       Figure  9.   Generalized Cross-Section Through A Typical Coal Tar Recovery Well  Cluster
                        (Source:  Papers by James F. Villaume   (PP&L)  1982 &  1983)
-------
replacement  pumps.    It  was  then  decided that  a nonsub-
mersible centrifugal  pump  be  used.  The  pump  is provided
with automatic  level  control  features.   Two  pump control
sensors  are  located  in the  central  monitoring well  to
sense the  tar-water interface.   A  signal  is  sent from the
sensors to the control device on the pump.  The pump turns
on  when the  interface  reaches  the upper  sensor  and  it
turns off  when  the  interface  drops to the lower  one.   In
this way,  the  tar-water  interface  can  be maintained above
the  well  intake point and  virtually  pure coal  tar «11%
H00) can  be recovered.   The  recovered  coal  tar  is then
stored on-site in a 10,000 gallon  (37,000 1)  holding tank.
PP&L had originally planned to use the coal tar as fuel in
their  own  facility,  but  due to  public opposition they
sought  other alternatives.   Allied Chemical  of Detroit,
Michigan  signed an  agreement with  PP&L to  purchase  the
coal tar  for use in  their  plants.   Allied  presently pays
for  the  transport  of  the  coal  tar  plus  40  cents  per
gallon.

     There are differences between the original design and
the  "as-built"  recovery  system.   Charges  were  made  to
increase  the  efficiency  of  the  system.   As  mentioned
earlier,  the type  of pump used  to  power the system was
changed  due  to  the  corrosive  nature  of  the  coal tar.
Originally it was anticipated that all four clusters would
be  operating.   Presently,  however, only RWl  is  recovering
coal tar.  When  the system's  operation began,  the movement
of  the  coal  tar  water interface  was not  induced  to  enhance
recovery   rates.    The  interface  level  was   allowed  to
recover  at  its  own  rate.    About  6  months  after  the
recovery  operation  began,  PP&L decided  that  perhaps
pumping  ground  water  in the vicinity of  the recovery well
would   increase  the  rate  of  coal  tar recovery   and
initiated  a ground  water  pumping  test  program using RW2,
to  determine  the  effect  of  ground water pumping on the
coal tar  recovery  rate.   Pumping tests did, in  fact,  show
that recovery  rates could  be  enhanced.   Due  to the  density
difference between  the water  and the coal tar, as water  is
removed  from  a  designated  area, the   coal  tar  surface
actually  rises  in  that area.   This produces stress  on the
system  and causes  the coal tar  to flow  toward the  pumping
point  or  well  at  an  increased  rate.    Testing  continued
over the  next  3-month  period  until  the system was  shut
down for  the winter  in November  1982.

     In the  spring  of 1983  the system  resumed  operation
and ground water is  being pumped  through one of  the  four
wells  in RWl,  as coal tar  is  recovered through another one
of the  four wells  in RWl as shown in Figure 9.   Two pumps
are being used, one  for  coal tar recovery  and  the other
                                      18-38
-------
 for  ground water  pumping.   The  water pump  is  a nonsub-
 mersible  centrifugal  pump  and  is  operated  continuously.
 Ground water  is being  removed  at a  rate  of  about  5 gpm.
 This  has  resulted  in a 10-15 times  improvement in the coal
 tar  recovery rate.  The  coal  tar  pump being used is  the
 same  nonsubraersible centrifugal  described earlier.    The
 ground  water is  discharged  to  a leach field  located about
 65  feet upgradient  of  RW1, near  the old coal  tar  injection
 pit.  The field  is an  excavated pit, approximately 6 ft x
 12  ft x  6 ft (1.8  ra  x  3.6  m  x  1.8 m)  backfilled with
 gravel.
COST AND  FUNDING

Source of Funding

     To date,  the  total cost of the site response  actions
taken  by all  parties  at  the  Stroudsburg  site  comes  to
approximately  $594,500.  EPA  and  the owner  of the  site,
Pennsylvania Power  and  Light,  have spent the bulk  of  this
amount (see Table 4).

     The  removal   of  coal  tar  which  had  seeped   into
Brodhead  Creek was  funded by EPA and  the Coast  Guard  under
Section 311 of  the  Clean Water Act.   The  slurry wall  and
grout  curtain,  a more  permanent  response,  were funded  by
the  Super fund  Immediate Removal Program.   PP&L installed
the  recovery wells  on its own  initiative.  The  entire  coal
tar  recovery operation  is expected to cost $190,000.

     The  available  cost  information  allows  discussion  of
the  costs of  only  the  slurry  trench  cut-off wall   and  the
recovery  well system.   Costs of other activities are  shown
in Table  4.

Selection of Contractors

     The  selection  of contractors  in an emergency response
situation such as the Stroudsburg  case,  is  made by the  on
scene  coordinator   (OSC) ,  who  consults  the  EPA  list  of
available contractors  and makes  a choice based  on "best
judgement."   In  this  case  the OSC  talked  with   several
firms  and  solicited  bids.    ECS  was  selected   for   the
emergency removal  operation and  for  the  construction  of
the  slurry  wall.   The inherent uncertainty  and  the
emergency nature of this type of  operation  were  cited  by
the OSC as  the  reasons  the  final  cost  of  the slurry wall
increased  to  $326,000  which  exceeded  planned costs   by
$88,000.    The  project  was completed  in  45  days,  well
within the  specified period  of  performance of 60 days.
PP&L contracted  with  TRC,  Inc.  in compliance  with EPA1 s

                                     18-39
-------
                       TABLE  4.   SUMMARY OF  COST  INFORMATION-STROUDSBURG,  PENNSYLVANIA
1-Utfk
Slurry
Wall

Recovery
Well System


1- liter
Tern' us
So r bunt
Booms
Inverted
flack Channel
Excavation,
Transporta-
tion and
Restoration
(c)
Total
Actual
Quantity
648 x 17 x ft:
11,016 ft3
(198 x 5 x 0.3m:
308 m3)
7,500 gal.
28,291 I.





280 cu.yd.
(215 m3)

	

Estimated
S 238,000









—

Actual
Expenditure
$326,000(a)

Held study:
$130,800
instill Imunt :
$110,000
additional:
$40.000
$43,500


$60,QOO

$15,000
$725,300
Variance
$88,000
(+372)




.


-._

—

Unit Cost
$29.59/ft3




	


$214/cu.yd.
(219/m^)

—

Funding
Source
Superfund
Removal

PP&L (b)


FUl'OA
Section 311


Superfund
Removal

Superfund
Removal

Performance
ll/fll-1/82

11/81-ongoing


4/81-7/81


1/82-3/82

4/82-5/82

00
I
(a)  Includes excavating tlie trench,

    transporting and disposing con-

    taminated sail


(b) Pennsylvania Power and Light
                                                              (c) clean fill, grading and seeding
-------
 request,  to  perform the investigative  studies on the site
 in  April  of 1981.   A direct  procurement   contract  was
 signed  between  the  two parties.   The  original  estimated
 cost  for  the studies was $125,000, which was  exceeded  by
 $5,000,  bringing  the  total  cost  of  the  studies  to
 $130,000.

 Project Cost

 Slurry Wall
     The  total cost of  the slurry wall was $326,000.  This
 corresponds  to  a unit  cost of  $29.60  per  installed cubic
 foot.   The  allocation  of  the  total  expenditures  for  the
 slurry  wall  operation  is uncertain.   The material cost  of
 the wall  was between  $5.00 and  $8.30  per cubic foot.   The
 remaining costs were  associated  with  the excavation,
 transportation and  disposal  of the trenching  waste,  with
 the  latter  two  estimated  at  $105.00  per  cubic yard
 ($136.50  per cu  tn) .   Included  in the  total cost  is  the
 $20,000  spent  on  grouting  at  the  downstream end  of  the
 trench.   The entire  slurry wall  operation  was  funded  by
 the  Super fund  Immediate  Removal  Program.   It  seems  the
 excavation of the  trench incurred a large portion  of  the
 total  cost due  to the  difficulties  of trenching  in  wet
 contaminated soi1.

 Recovery Well
     Total expenditures  to date by PP&L  for  the recovery
 well  system including investigative  studies  and well
 installation,  are   $240,000.    It  is   estimated  that  an
 additional  $40,000  will be  spent  before  the  system  is
 fully operational.  Of  the $240,000,  $130,000 was spent  on
 investigative studies and, $110,000 on well  installation.

     In the  fall of 1981, PP&L signed  a direct procurement
 contract  with EMTEK out  of  Amherst,   New  Hampshire  to
 install the  well system.  A procurement contract was  used
 as  opposed  to   open-bidding  because   PP&L  had  procured
 EMTEK1s  services  in the  past  with  effective  results.
 Original  estimates  for total  cost   of the  system were
 $150,000.

     The  est imated  cost  for   the  development   of   a
demonstration well  and its operation was $7,500.   However,
due  to unanticipated  problems  an  additional $10,000
expense occurred.   Thus the  total cost for  phase  one was
$17,500.  The second phase which involved the installation
of  the  final  four wells  and   an  enhancement program  to
 insure  maximum  coal  tar recovery, has cost  $92,500   to
date.   Installation has been  completed but  the  system  is
not  yet  fully operational.   Inclement  weather  over the
past 3  months  has  prevented the  continuation of work  on

                                    18-41
-------
the  wells.     PP&L   plans  to  develop  and  institute  an
enhancement  program.   The estimated  expenditure  for  the
final part of the second phase is $40,000.

     The  installation  of  the  recovery  well  system  was
undertaken in  two  phases.   In  the first phase,  a single
test  well  was  installed  in  order   to  determine  its
effectiveness.   Several problems arose due to three of the
four pipes becoming  clogged with silt  and  preventing the
well from operating.   Once this  problem was corrected the
second phase began which entailed  the  installation of the
four wells proposed  in the system design.
PERFORMANCE EVALUATION

     The  slurry  trench  cut-off  wall  at Stroudsburg  was
installed to  stabilize  a situation in which  coal  tar was
entering a  biologically  active and healthy  surface water
body.  Data collected from the eight wells used to monitor
ground water conditions on either side of the slurry wall,
indicate  that  the  wall has been  successful  in preventing
further  horizontal  contaminant  migration  into  Brodhead
Creek.  The values  for ground  water levels  on the outside
of the wall (i.e.,  the stream-side) have been consistently
lower  than  those for  ground  water on  the  inside  of the
wall (see Table 5).  This suggests that the wall is indeed
acting  as  a barrier  to  horizontal ground  water movement
and, consequently,  coal tar movement towards the stream.

     Visual inspections have been routinely made along the
stream  bed  to ensure that  the coal tar  seepage  has been
successfully eliminated.   Surface  water sampling analyses
also show positive results regarding stream water quality.
Thus,  it  appears  from  f o 1 lowup  inve s t igat ions  that  the
slurry  wall has  been effective  in  preventing coal  tar
contaminants  from  entering  the creek.   There is, however,
some apprehension  on  the part of both  the  State and EPA,
regarding the  seemingly   complete stoppage  of contaminant
migration.   (Note:   the term  'contaminants'  is  used here
with reference to  coal  tar  constituents within the ground
water   as  well  as  the  coal  tar  itself.)    It  seems
reasonable  to  assume that the coal tar,  itself,  has been
contained behind the  wall  for there are  no  further signs
of  seepage  along the  stream  bed and  it  was demonstrated
during  the  'extent  of  contamination1  studies  that  the tar
does not  penetrate  the  underlying sand to any significant
degree.   The issue  that  has  sparked concern  is possible
vertical migration of contaminated groundwater.  There has
been regular  groundwater  level monitoring in the vicinity
of  the  wall  and  regular  surface  water sampling, but there
                                     18-42
-------
                                 TABLE 5.
MONITORING WELL GROUND WATER ELEVATIONS ON EITHER SIDE OF WALL
WELL
No.
I
2
o
3
I
4.
»
5
o
6
o
I
0
DATE
Hell To* (tx» of
st«ti cap) Elm-
tie* in (.) E Ft.
(119.01)
390.01
(118.46)
387.70
(118.46)
383.68
(117.82)
388.50
(117.86)
386.56
(117.92)
386.89
(118.06)
387.34
(117.85)
386.85
1-28-82
2-4-82
2-17-82
3-10-82
4-20-82
5-27-82
Ground Water Elevations in Feet (m)
-
:u5.i2)
377.70
1115.56)
379.16
(115.58)
379.20
(115.08)
377.56
(114.92)
377.04
(115.41)
378.64
(114.60)
376.26
(115.85)
380.15
(115.55)
379.10
(115.86)
380.12
(115.87)
380. 16
(115.52)
379.01
(115.42)
378.69
(115.74)
3 79.74
(115.21)
378.00
(115.69)
379.55
(115.24)
378.10
(115.68)
379.53
(115.70)
379.60
(115.19)
377.91
(115.06)
377.49
(115.59)
379.24
(114.87)
376.86
-
(115.15)
377.30
(115.35)
378.45
(115.67)
379.50
(115.11)
377.66
(114.92)
377.04
(115.58)
379.19
(114.81)
376.66
;il5.84)
380.05
;il5.3U
378.30
:i!5,76)
379.78
;il5.34)
380.05
;il5.28)
378.21
;il5.12)
377.69
115.73)
379.69
114.90)
376.96
(115.69)
379.55
(115.12)
377.70
.(115.61)
379.29
(115.65)
379.42
(115.10)
377.62
(114.90)
376.96
(115,55)
379.09
(114.70)
376.32
6-2-82

(115.84)
380.05
(115.44)
378.75
(115.63)
379.38
(115.64)
379.40
(115.39)
378.56
(115.23)
378.05
(115.81)
379.94
(114.81)
376.66 :
  o - Scream-side  or oucside  of Slurry wall; -
  I - Inside or in land of slurry wall

Source:  Department of Environmental  Services
        Wilkes-Barre, Pennsylvania
Locaced behind  PP&L's retaining
wall
                                  18-43
-------
has  never been a  follow-up  groundwater sampling  and
analysis program implemented, which is a major  concern to
the  leading  agencies  involved.   The  question  has  become
whether the only discharge  point  for  the ground water in
the  site   area  is  Brodhead  Creek or  whether  there  is
vertical movement  down through the underlying  sand  strata.
If  there  is  vertical  ground water  movement,  soluble
constituents  of the coal tar,  such as  polyaroraatic  hydro-
carbons, benzene,  cyanide,   and  naphthalene  (PAHs),  will
not be  confined to  the  sand layer and the  possibility of
deeper  aquifer  contamination  exists.   If  this were  the
case, an area such as East  Stroudsburg might  be affected.
The water  for  this  area is  drawn from an  aquifer  that is
700 feet below the ground surface.

     In response to their own concerns, EPA has decided to
conduct an additional  hydrogeologic investigation to
supplement the information that is already available.  The
primary  objective  of  the   study  will  be  to  sample  the
groundwater that exists within the sand strata.  In autumn
of  1982,   four  to  six  additional monitoring wells  were
installed  and  used  to  sample the ground water  present
within  the sand unit.   When data collection  is  complete
EPA will be  able  to make a  complete  and  final assessment
of the current situation at  the Stroudsburg site.

     The coal tar recovery rate originally anticipated for
the recovery well system at  Stroudsburg, was approximately
100 gallons (378  1) per  day.   This rate,  however,  has not
been maintained due to  the  fact  that  only one of  the  four
wells  in  one of  the  four  clusters,  (cluster #1)  (Figure
8),  has been  in operation,  recovering coal tar at  a  rate
of 20-25 gallons (76-95  1)  per day.   The reason the other
wells are  not operational is because the level of pumpable
coal  tar   does  not  extend  to  them as  originally  thought
based  on  split-spoon  samples.    The  coal   tar  in  the
vicinity of the other wells  is associated with a consider-
able  amount  of free  water,  preventing  the recovery  of a
nearly  pure  product.    Initially during  the  operation of
the wells, problems arose due  to silt clogging several of
the  pipes  and preventing their  operation.   However,  even
following  the correction  of  this   problem,  coal  tar
recovery was  only possible  using  one  of  the clusters.  It
was  soon realized by  PP&L,  that  the  amount of "pure"  coal
tar  available  for  recovery was  much  less than had  been
originally calculated,  and  this  was  the  reason only one
well could be utilized.  The remaining three well clusters
could  only recover a tar-water  mixture,  due  to the  fact
that there wasn't recoverable  coal tar in these locations.
Despite  the   use  of  only  one  well   in  one  cluster,  the
original   67  feet  (20  m)   of  "pure"   coal   tar   in  the
                                     18-44
-------
 reservoir has been  greatly  diminished  to  a  thickness  of 4
 feet  (I  m) ,  after  approximately  8  months of  well  opera-
 tion.  A total  of  7,500  gallons  (2.8  x 10  I) of coal tar
 has been  recovered  to date.

      Al though  the  dec is ion-making  processes  were  not
 always  well-coordinated   between  the  agencies  and  indi-
 viduals  involved  with  the  Stroudsburg  case,   the  final
 remedial  actions  taken  have complemented each other  in a
 very  advantageous  manner.   The  slurry cut-off wall  was
 emplaced to block further coal tar migration into Brodhead
 Creek and  accomplished  just that.   The  intention  behind
 the   wall  installation  was  to   stabilize  a  potentially
 hazardous situation.   The predominant  fear at  the  outset
 of  the  site  investigations  was that  a  severe storm might
 cause the rapid downcutting of the stream bed, releasing a
 large quantity  of  coal tar  directly  into  the  stream.   The
 slurry wall  was installed  to  prevent  further  seepage  of
 the  coal tar to areas close  to  the  stream bed  where the
 potential  for   release   was  greatest.   This  remedial
 technique,  however, did not  eliminate  the subsurface
 reservoir  of coal  tar and  this  was  the  issue  that  PP&L
 sought to  address.   PP&L felt  that to solve  the  problem
 permanently,  some  action had  to  be  taken  to  remove  the
 coal  tar  from   the underlying  reservoir.    They,  then,
 designed and   installed  the  recovery well  system  and
 although the system has not  operated at the level that was
 initially  anticipated,  it  has  operated  sufficiently  and
 coal  tar has been recovered  at a steady rate.

      One  technique,  the  slurry  wall,  was  utilized  to
 alleviate the immediate  problem,  that of  coal tar  seepage
 into  the  stream,  while  the  other remedial  technique,  the
 recovery  well  system,  was   installed  to  ensure that  no
 future problems would arise  due to coal tar movement.   The
 two  actions,  taken under  different  authorities,  have
 created  what  would seem   to be  the  ideal conditions  at a
 remediated  site;  amendment  of  the  present and  immediate
 problem  coupled  with  continued elimination of  the  source
 of the problem.

      The applicability of any remedial technique at  a site
 depends  upon the  summation of  surface,  subsurface,  and
 waste type conditions and for  this  reason  it  is  difficult
 to make  any  type  of judgement  concerning  general applica-
 bility.   There  are, however,  some guidelines that  can  be
 offered which are briefly discussed  below.

      A  recovery  well  system  is   most  applicable  in
 situations  where  a  large  enough  quantity  of material
exists such  that  it is mechanically  feasible  to recover.
The recovered materials must often be  marketable in order

                                     18-45
-------
that  the  system be  economically  feasible.    Recovery  of
material from beneath the  surface  is  a  costly process  and
it must usually continue over a period of several years.

     The cement-bentonite slurry wall has  a much more
diverse applicability  than the  recovery  well  system  and
for  this  reason  it is  being used more  often at other
sites.  A  slurry wall  can be placed downgradient  of  the
contaminant source as it was  in  the Stroudsburg case.   It
can  be placed  upgradient   of  the  contaminant  source  to
divert  flow  of  groundwater  away  from  or  around  the
contaminant source  or a wall can be  installed around  the
contaminant  source,  for complete   containment.   In  most
cases, there must be an impervious  layer or aquiclude into
which  the  wall  is keyed.   This is  an  important criteria
unless the wastes to  be  barred  are  floating or  their
vertical migration is prohibited, as they were by the sand
strata at  the  Stroudsburg  site.    A cement-bentonite  wall
is  used  in  situations  where  either  (l)   the  wastes/
leachates present are not compatible with a soil-bentonite
backfill  or (2)  there  is  insufficient room  on site  to
perform the mixing of soil-bentonite backfill.

     The nature of the wastes and leachates and whether or
not they will be in direct contact with the wall are major
factors in  (1)  the decision  to  apply  the  wall technique
and  (2)  the decision between  use  of a soil-bentonite  or
cement-bentonite mixture  for the  final wall  composition.
Site-specific  compatibility  testing  must  be  conducted
prior  to making any decision to  install a slurry wall.

     These  are  simply  general   guidelines  concerning  the
use  of recovery  well   systems  and slurry  trench  cut-off
walls, and  prior  to making any  decision  concerning their
applicability  at  another   site,  thorough  investigations
must  be  conducted  to  determine  the  surface,   subsurface,
and waste type conditions  at the particular location.
                                      18-46
-------
                                  BIBLIOGRAPHY


 Barry, Barrett.   Personal communications.   1982.   Pennsylvania Dept.  of
      Environmental Resources,  Bureau of Water Quality Management,
      WiIkes-Barre, Pennsylvania.

 Clements, Robert.  Personal communications.   1982.  U.S.  EPA Headquarters,
      Washington,  D.C.

 Environmental Law Institute:   1982.   Draft Interim Report on Case  Studies and
      Cost Analysis of  Remedial Actions  at  Uncontrolled Hazardous Waste Sites,
      Environmental Law Institute,  Washington, D.C.

 Lehman,  Jerry.  1982.   Pennsylvania  Dept.  of Environmental  Resources,  Bureau
      of Water Quality  Management,  Wilkes-Barre,  Pennsylvania.

 Massey,  Thomas.   1982.   Personal  communications  and  file  information.   U.S.
      EPA, Region  III,  Philadephia, Pennsylvania.

 McGill,  Kenneth.   1982.   Personal  communications.   U.S. EPA,  Region  III,
      Philadelphia, Pennsylvania.

 Pennsylvania  Department  of  Environmental Resources.   1981.   Brodhead  Extent  of
      Contamination Report,  September 11, 1981.   Department  of  Environmental
      Resources, Wilkes  Earre,  Pennsylvania.

 Pennyslvania  Power and  Light Company.   1982.   Laboratory  and Aquatic  Survey
      Results  - Stroudsburg  Coal Tar  Site,  CCN 773097/001.   Pennsylvania Power
      and  Light Co., Environmental Management  Division,  Allentown,
      Pennsylvania.

 Ratzel, Lyn.   Personal  communications.   1982.  Pennsylvania Power  and  Light
      Co., Environmental Management Divisiion,  Allentown,  Pennsylvania.

 Schwartz, F.W., J.A. Cherry and J.R. Roberts.  1982.  A Case Study of  a
      Chemical  Spill and Polychlorinated Biphenys (PCBs) .  2. Hydrogeological
      Conditions and Contaminant Migration.  Water  Resources Research,  Vol. 18
      No.  3.  June  1982.

Soil  Conservation  Service.  1980.  Soil Survey of  Monroe County, Pennsylvania.
      U.S. Department of Agriculture, Washington,  D.C.

TRC Environmental Consultants,  Inc.  1981.  Phase II-Pennsylvania Power  and
     Light Stoudsburg Contamination Study.   TRC Environmental Consultants,
     Inc., East Harford, Connecticut.

Villaume, James,  F and  P.C.  Lowe.   1983.  Coal Tar Recovery from a  Gravel
     Aquifer:   Stroudsburg,  PA.  Conference on the Disposal of Solid  and
     Liquid Wastes.  April 28-29,  1983.
                                     18-47
-------
                           BIBLIOGRAPHY (Continued)


Villaume, James, F.  Personal communications 1982.  Pennsylvania Power and
     Light Co., Environmental Management Division, Allentown, Pennsylvania.

Villaume, James, F.  1982.  The U.S.A.'s First Emergency Superfund Site.  In
     Proceedings of the Fourteenth Mid-Atlantic Conference on Industrial
     Waste, 1982.
                                      18-48
-------
                               QUANTA RESOURCES

                               QUEENS, NEW YORK
INTRODUCTION

     The  Quanta  waste  oil  processing facility  occupies
about  1.8  acres  (0.74  ha)  in an old inudstrial  area  in
Queens  about  450  feet  (137 m)  from the Newtown Creek,
which  leads  into the East  River (see Figure 1).   About
500,000 gallons  (1.89  x 10° 1)  of wastes were  stored  on
site  in tanks (see Figure  2)  awaiting re-refining  when
the company abandoned  the  site in late  1981.  The wastes
on-site included PCS contaminated  waste oil,  cyanides,
heavy  metals  and  low  flash point  (82°F,  28 C)  chlori-
nated  organic solvents  such  as  methylene  chloride  and
trichloroethylene.    The  City  and  State  of  New  York
believed  that there was  a great  potential  for  a  major
release of hazardous  air pollutants such as  dioxin from
a fire.

Background

     The  waste  oil  recovery  facility at  37-80  Review
Avenue  in  an  old industrial area of Long Island  City  in
Queens, New York City  (NYC) was  originally built in the
early  1900*s.  It  was  owned and operated by a variety  of
companies  and individuals  who processed  and sold  waste
oil.   No  clear records were kept on the types  of wastes
processed  and  stored  on-site,  but a site survey  in June
1982  revealed about 500,000  gallons (1.89 x 10   1)  of
wastes  including PCB contaminated  oil,  cyanides,  heavy
metals  and chlorinated  solvents.   The potential  threat
to  public  health  from  fire  and  toxic   fumes  became
imminent  when the owner,  Quanta Resources Corporation,
which  had  bought the site  in  July 1980, filed  for  bank-
ruptcy  on October  6,   1981,  and abandoned  the  site  on
November 21,  1981.  At  this time,  the  immediate issue  of
site security  to prevent  arson or vandalism,  which  could
cause   toxic   air  and   water   emissions  from   fire  or
leakage, became  very  important.  While hazardous wastes
remained  on-site,  the  city  and  state  believed  that  the
extent  of  the  threat was indirectly  related  to  the  level
of site security.
NCP
Refererences
300.65(a)
(3) Fire
and/or
explosion
300.65(b)
(3) Security
                                     19-1
-------
Figure 1.  Quanta Resources, Queens, New York, NY
                      19-2
-------
Figure 2.  Quanta Resources Site Plan
                19-3
-------
     The site  discovery process underwent several  steps
involving  different   state  and   city  agencies  with
different  levels  of  information.    On April  25,  1980,
investigators  from  the New  York  State  Department   of
Health  (NYSDOH)  and  the  NYSDEC inspected  the site  and
reported  health  complaints  from  workers  in adjacent
facilities,  and   noted  that  they  suspected   on-site
disposal of  hazardous wastes.  They  also noted  leakage
from  a  tank of  what  they  were  told  was lubricating
oil.    On  July 30,  1981,   NYSDEC  sampled  19  tanks  and
found PCB  contaminated  oil, estimated at 65,639  gallons
(248,443 1).   The U.S. EPA subsequently tested  another
tank and labeled it after  finding that  its  contents were
PCB contaminated.   The state and the site owner  settled
on  a  consent   decree with   a  compliance  schedule  for
repairing    leaks    and    for    general    permitting
requirements.    In   1981,   the U.S.   Attorney   in  the
Southern District Court  of New York indicted  the Quanta
plant  manager   for  conspiring  to   illegally  dispose   of
hazardous  wastes,   including  cyanides  and  contaminated
oil,  into  local sanitary landfills.  With this knowledge
of the site hazards, NYSDEC  and  the  NYCDEP  were very
concerned  about  the  potential  for fire and pollution
when they  were informed on Friday  May  7, 1982 that  the
trustee  for  the bankrupt  corporation planned to remove
site security  from the  property.   Because  of city  and
state objections, the trustee maintained  a guard  on-site
until  June 8,   1982,  when  the  U.S.  Bankruptcy Court  of
New  Jersey  granted  the trustee's motion to  remove  all
security from  the site due to  lack of funds.  Security
was  provided by  NYSDEC guards and  NYC  police  patrols
until  the  city  contracted  with  a guard  service following
a  declaration   of   a  site  emergency   by   the  NYCDEP
Commissioner on June  16,   1982.   The  discovery  of  the
exact  problem  on-site was  further  made  during a survey
by  the  NYCDEP  and  NYSDEC in  June 1982.   This  survey
identified and quantified  low  flash  point  (82 F,  28 C)
liquids  and  PCB contaminated oil  in leaking tanks,  which
provided the impetus  for the  subsequent clean-up  work.

Synopsis of  Site Response

     The site  response had three main  phases  - two site
surveys  and a surface  waste  removal  operation.  With
assistance from NYSDEC,  the NYCDEP  took 142 samples from
92 tanks between June 15-25, 1982.  A NYCDEP contractor,
0. H.  Materials (OHM),  took 378 samples from 106  tanks
between August  13-20,  1982.     These   surveys  found
approximately   150,000  gallons   (567,750  1)   of  PCB
contaminated oil and sludge,  266,000  gallons (1.007 x
10    1)  of  contaminated  water   and   121,000   gallons
(458,000 1)  of uncontaminated oil.
300.63
Discovery
300.65(b)(3)
security
300.64(a)
preliminary
assessment
 300.65(b)(5)
 sampling
                                      19-4
-------
      The wastes were  removed  from the site by OHM under
 contract  with  NYCDEP  between  September  and  December
 1982.  Liquids  were  pumped into tank trucks and trains,
 and sludges were solidified with  lime and  transported by
 truck  for  disposal.   All  wastes were  disposed  of at
 licensed  hazardous  waste   facilities.     Following  the
 removal,  the tanks were cleaned with water followed by a
 diesel   fuel    rinse   and   aeration.      A   subsurface
 investigation is pending as of January 1983.

 SITE DESCRIPTION

 Surface Characteristics

      The  Quanta Resources  waste  oil  processing facility
 (see Figure 2) consisted of four buildings and about 100
 storage  tanks,  which  contained  about  640,000  gallons
 (2.4 x 10  1) of waste oil, sludge, chlorinated solvents
 and cyanide.  One  of  the  buildings  encloses  a cracking
 tower for re-refining  waste oil  in a 4  story corrugated
 steel  section,   located  near  the  main  gate  at  the
 northeast corner of the property.  A one story warehouse
 containing  pits and  tanks   is  located at  the  southeast
 corner of  the  property.    Two small boiler houses that
 were between  these  buildings were  removed  during  the
 1982 clean-up.   Most of the 100 storage tanks were large
 above  ground steel structures  between 10  -45  feet (3-14
 m)  tall,  with capacities between  5,000  -  51,000 gallons
 (18,925-193,035  1).   Some   of  the tanks were  converted
 railroad  tank cars.   The  largest  tanks,  labeled  "K" in
 Figure  2, are surrounded by a matrix of 4 foot  (1.5 m)
 concrete  dikes.    There were  also two buried  tanks  and
 three  recessed  effluent sumps.    The  ground  is  paved
 asphalt near the front and  compacted  oily  dirt  near  the
 rear.

     The  1.84   acre   (0.74 ha)   facility  slopes   down
 slightly  from its  204  foot (62 m) long fenced  frontage
 on  Review  Avenue.    The   Calvary  Cemetary  is  located
 directly  across  Review Avenue.    On  the east side,  the
 site   is   separated   from   the   Guiness   Harp  beer
 distribution  warehouse  by   a   392 foot  (119  m)   steel
 fence.   The original 4  foot (1.5  m)  fence on this  side
 was  replaced by a  10  foot  fence  in  1982  by NYCDEP,   A
Long  Island Railroad  (LIRR) line  runs  along the  fence
 near  of  the site,  which  is  about  450  feet  from  the
Newtown   Creek.    The   Nanco   (construction)  Equipment
Company  is  located  on the  west   side  of   the property,
 separated by  a 10 foot barbed-wire fence.  The closest
 residences are located  about 500 yards south, across  the
Newtown  Creek  in  Brooklyn,  and  about  800  yards west
along 45th St.
  300.65(b)(6)
  removal
300.65(e)(2)
(i)(A)
population
at risk
                                     19-5
-------
     The Quanta  site  is  located  in an  old industrial
area  of Long Island  City  section  of  Queens   in  the
approximate  center of  New  York  City  at  73   56'  15"
longitude and 40°  45'  6" latitude.   The gently  sloping
surface was  formed by a  combination of  the retreat of
the Wisconsonian Glacier about 10,000 years  ago,  and the
relatively   recent  use  of artificial  fill,  during  the
19th  century.   (see  Figure  3)    The  average annual
temperature is 54.3  °F (12.4°C),  and  the average daily
minimum  and maximum  temperatures are  47.4 F.   (8.5 C.)
and  61.1°F.   (16.2°C.),  respectively.    Average   January
and  July  temperatures,  which are the extremes  of the
monthly  averages,   are   32.1°F   (0.05°5)   and  76.7 F
(24.8°C),    respectively.        The    average    annual
precipitation  is  41.61  inches  (105.7  cm).  Winds  are
usually out  of  the west northwest,  at an average speed
of 12.2 miles (19.6 km) per hour.

     Newtown Creek, which lies 450 feet  (137 m)  south of
the  site,  and the East River,  into  which it flows, are
both  classified  as  "SD" in the  New York  State usage
designation.   Class  SD waters  are  defined as:    "All
waters   not   primarily   for   recreational  purposes,
shellfish  culture  or  the  development of  fish  life and
because  of  natural  or  man-made  conditions cannot  meet
the requirements of these uses."

Hydrogeology

     The information in  this section was  drawn primarily
from  a paper published  in  1971  by  the U.S. Geological
Survey   (USGS).    No  hydrogeological  study had   been
completed on  the  site as of January  1983;  the NYCDEP  is
preparing  to  let  a  contract  for  a study.    Relevant
information   is  summarized  and  extrapolated  from  this
paper  and geological maps of Queens  County.

      In the  area  of Queens where  the  site is located
there  are  three aquifers consisting of sand and gravel
from  the  Later  Cretaceous  and  Pleistocene,  overlying
Precambrian bedrock  (see  Figure 4).    The  uppermost,
Pleistocene aquifer  is  presently water-bearing and  an
additional  aquifer  lies  nearby.    The  two  Cretaceous
aquifers  have  receded from the  site area.    The  site
rests   on   shallow  artificial   fill  over ^ Pleistocene
glacial drift from the Wisconsinian glaciation.  Within
this  Upper  Glacial  Aquifer,  water  table  conditions
(unconfined  aquifer)   exist  at  about  20  feet (6  m)
deep.      This  layer   of   primarily  undifferentlated
Pleistocene  deposits  extends  to about  50 feet  (15  m)
deep.   A  section  of the Jameco Aquifer lies nearby the
 site directly beneath  the  Upper  Glacial Aquifer.   This
 lower Pleistocene Unit occurs occasionally throughout
300.68(e)(2)
(i)(E)
climate
300.68(e)(2)
hydrogeological
factors
                                      19-6
-------
             Figure 3.  Queens Surficial Deposit and Section Locator - Quanta Site
 QUANTA
LOCATION
                                                                              Artificial Mi
o Public  supply well in use  (1961)
0 Public  supply or other high
    capacity  well in use after  1961
o Industrial,  institutional  or
    observation well
                                                                                    —
-------
                           Figure  4.   Geohydrologic Sections, Queens County, New York
00
                APPROXIMATE LOCATION
                QUANTA RESOURCES SITE
                      Vertical Exaggeration  X20
                                                                         5 miles
                                                        SCALE
                                                                                       i u
                                                                                       M «
t »*
M
      Su
  Ul aeonsin
  Glaclatlon
  (undlfferentlated)

  Gardinera Clay

  Jaaieco
  Gravel

  Hagothy Formation
  Hatawan Group

8 Clay Member
          Lloyd Sand
          member
                                                                                                 Bedrock
                          Qu
                          Qc
QJ

Kim


Krc

Krl
                                                                                       Approximate poaitton of the
                                                                                       40 mg/1 chloride line    —

                                                                                            Water Table       —
-------
 the  county in buried valleys.   The Magothy is the second
 aquifer  underlying  the site.   It occurs directly beneath
 the  glacial  drift  layer  in   the  Magothy  Formation  -
 Matawan  group.   This layer  was  deposited during  the
 upper  Cretaceous,  and extends  to  about  175  feet  (53
 m),   The hydrologic communication between  the  uppermost
 aquifers  is  very good.  The first of  two members of  the
 Raritan  group is a clay member  extending  from  about  175
 feet  (53  m)  to 350  feet  (106  m).   The  second  member is
 the Lloyd  sand member, which extends  from about 350 feet
 to 450  feet  (106-137 m).    Precambrian bedrock  underlies
 the site at a  depth  of about 450 feet  (137 m).

 Upper Glacial Aquifer

     This  aquifer  is   presently  the   only  actual  water
 bearing  unit  under  the   site.    It  consists  of  some
 glacial  outwash sand and  gravel deposits, but  mainly of
 ground moraine deposits at  the  site,  which  is north of
 the  terminal  moraine.    This  aquifer  has  a  porosity of
 about  40%, and  a coefficient  of  permeability  (rate of
 flow water,  in gallons per day, through one  square foot
 under  a gradient of  100  %)  of about  1,000  gallons/-
 day/square foot (40,743 I/day/m  ).

 Jaraeco Aquifer

     The  Jameco Aquifer  is a  lower  Pleistocene  buried
 valley consisting of  coarse sand  and  gravel- with  small
 amounts  of silt and clay.   It extends  primarily north-
 south, but a  section  of  it underlies  an area near  the
 site.  Since  this is  a relatively  shallow water-bearing
 unit, its  proximity  may be relevant to  the  ground  water
 quality.   In addition,  this  aquifer  has  the  highest
 permeability  in the county, with  coefficients  as  2,000
 gallons/day/ per  square foot (81,485 1/day/m  ).

Magothy Aquifer

     The cloaest  extent of the  Magothy  aquifer  in  1968
was about  1   /2 miles  (2.4 km)  to  the  southeast of  the
 site.   Subsequent to  the  last  USGS  study,   the  aquifer
has  receded  further  to  some  extent.    This  Magothy
 formation  is  in the  Matawan Group and  consists  mainly of
 intercollated beds and lenses  of clay,  clayey  and  silty
 sand, fine to  course sand,  and gravelly sand.  There is
a basal unit  of  sand in the aquifer, about 50 - 100 feet
 (15-30 m)  thick.  This variety reflects  the  fact  that it
was  deeply  eroded  prior   to  the  deposition  of  the
Pleistocene units.   The porosity and permeability of  the
 formation  vary widely, and are as  yet  unclear  at  the
 site  location.    The unit's  coefficient of  permeability
varies from aboout  500 -  1,450 gallons/day/  square  foot


                                     19-9
-------
(20,371-59,077 I/day/ m2) and a porosity of about 30%.

Lloyd Aquifer

     The closest extent  of  the Lloyd aquifer  in  1968  was
about  !1/2  miles   (2.4  km)  to  the  southeast  of  the
site.   Reduced infiltration  and  increased pumping have
decreased  the  extent since  the  1968 USGS  study.  This
aquifer  consists   of the  Upper  Cretaceous  Lloyd Sand
Member  of  the Raritan  Formation,  and  is  the  lowermost
major  aquifer  unit  in  Queens County.   It  is  confined
between the  underlying bedrock  and the overlying  poorly
permeable  Raritan   Clay  member.    The  Lloyd   aquifer
consists of  beds  of sand and gravel intercollated with
beds  of  clay  and  silt.     The  sand  and  gravel beds
commonly  contain  varying  amounts  of  interstitial clay
and  silt.    The average  permeability of  the aquifer  is
about 500 gallons/ day/square foot (20,371 I/day/ m ).

WAST?: DISPOSAL HISTORY
     The  date  of  the  first  processing   of  hazardous
wastes  at  the  Quanta site is  unclear, but  the age of  the
facility   suggests   that   it  paralleled   the  use   of
petroleum products  through  the 20th  century.   The NYCDEP
estimates  that the Quanta  facility was  built in  the
early  1900's.   The Newtown Creek area is the  oldest  oil
refining   center   in  the  country.     Whale   oil   was
previously  refined by early  plants in  the area  during
the  18th  and 19th centuries.   -The  last  wastes were
brought   on-site   before  November  1981,  when  Quanta
Resources abandoned  the  property.

DESCRIPTION  OF CONTAMINATION

     Of  the three  sampling  programs  carried  out   at
Quanta,  the  Phase   I  site  survey program carried  out by
0.  H.  Materials  (OHM)   in  August  1982  was  the most
extensive.   Air,  solids  and  liquid wastes  were sampled,
but  liquid waste  analysis  was the  primary task.  This
survey   included   378  samples   taken  from  107  tanks,
separators,  basins  and drums  and was largely verified by
a  quality assurance program  conducted  by ClUM  Hill,  as
well  as frequent  spill  samples analyzed by  NYCDEP.  The
results  of the sampling program are  summarized in Table
1,  and  the  methodology  is  described  in  "Design  and
Execution  of the  Site Response."  The waste stream cate-
gories  listed  reflect   the  minimum regulatory ^ disposal
requirements of the wastes.   Most tanks  contained only
one  waste  stream  each.   But uncontaminated material that
could   not   be segregated  from  an  adjacent   layer  is
included in the total for  the  contaminated waste stream
category.   The survey determined  the  location, contents
and  condition of each  tank  on site.
300.64(b)
data review
300.65(b)(5)
sampling
                                     19-10
-------
            TABLE 1.   TYPES AND AMOUNTS OF WASTES AT QUANTA (August 1982)
Non-Contaminated oil
Oil contaminated with chlorinated
solvents
Oil contaminated with PCS*
(less than 500 mg/1)
PCB oil (greater than 500 ug/1)
Non-contaminated water
Water contaminated with
heavy metals
Water contaminated with
volatile organics
Water contaminated with PCB
Caustic
Non-contaminated sludge
Sludge — flammable
PCB contaminated sludge
Solids — non-contaminated
Solids — toxic
121,150
75,267
97,742
22,502
3,072
200
211,412
24,570
29,881
32,391
162
9,722
49
31,283
161
18
5
gallons (458,553 1)
gallons (284,886 1)
gallons (397,953 1)
gallons (85,107 1)
gallons (11,628 1)
gallons (757 1)
gallons (800,194 1)
gallons (92,997 1)
gallons (113,100 1)
gallons (122,600 1)
cubic yards (124 m )
gallons (36,798 U
cubic yards (37 m )
gallons (118,406 1)
cubic yards (123 m )
3
cubic yards (14 m )
3
cubic yards (4m)
*  Includes  some  (9%)  non-contaminated oil  and  sludge
that  could not be  separated  cost-effectively  from  the
contaminated layer during transfer.

    Source:   Compiled from reports by NYCDEP, OHM and
              CH2M Hill.
                                     19-11
-------
     Each  category   included  an   aggregation  of   more
specifically analyzed components.   The  non-contaminated
oil  and  sludge were found  to  be  RCRA  non-hazardous
according to their constituents  and properties.   The oil
and water contaminated with chlorinated  organic  solvents
primarily       contained      methylene      chloride,
trichloroethylene,    (TCE),    benzene,   xylene,   1,1,1-
trichloroethane  and  tetrachloroethylene   (PCE).     The
vapors  from  these   contaminants caused  the  low  flash
points,  which  were  as  low  as  82°F  (28°C).     Oil
contaminated  with   PCS  was  defined  as  having   PCS
concentrations between 50 -  500  mg/1, while PCB  oil had
concentrations  over   500  mg/1.    Non-contaminated  water
met  pretreatment  standards for  the  city sewage system
but was later pretreated with other aqueous waste before
disposal.   The  primary  heavy  metals were zinc,  mercury,
chromium,   lead  and  barium.     A   radiological   survey,
performed  by  a NYCDEP  contractor,   Radiac,  found  no
measurable radioactivity onsite.

     During the  OHM  survey,  spillage occurred  from two
above  ground  tanks  and  a sump  tank.   Tank  JSEP   3,  a
final  oil separator  basin at  the lower  southwest end of
the  site,  was brimming  with  oil water.   Stains around
JSEP 3  suggested that it had overflowed  previously onto
the  LIRR  tracks.   Tanks J10 and  J44 were  found  to  be
slowly  leaking  oil  from pipe fittings  onto  the ground
below  them.    Also,  15  full   drums were  found   near
building  A.    A  six inch  (15  cm)  barge  loading  pipe
leading  from  the  site  to the  Newtown Creek  had  one
leak.   Another  6 inch (15 cm)  sewer  line led under the
LIRR   tracks  to  the  Creek.     No detectable  off-site
organic   air   emis s ions   were  measured,   us ing mob ile
infrared    analyzers   (MIRANS)     and    photoionization
detections (PID) .  Detection  limits were set  for TCE and
PCE  at 4 mg/m  .   No air contamination  was measured in
the  established "clean area", except  inside and  near the
laboratory   because   of   reagents.       Explosimeter
measurement showed combustible  gases  only at  the lid of
chlorinated solvent/oil tanks.

PLANNING THE SITE RESPONSE

Initiation of Response

     Generally,  responses were  initiated  at  Quanta to
prevent   fire,  which would  have produced  toxic  air
pollutants.    The  NYCDEP and   NYSDEC  agreed that  the
threat of fire required  mitigation.   But,  the  response
was   not   initiated  until   after   the  NYCDEP   took
responsibility  for the site clean-up.
     There  were  two primary  decision  periods   for the
initiation  of work  at  Quanta to prevent  fire and   toxic

                                     19-12
-------
air  and  water  emissions.    The first  response actions
were  taken by  the  city  following  the  declaration of
emergency  on  June  16,   1982   when   the  Department  of
General Services  (DCS) contracted  for site security and
the  NYCDEP began  a  site  survey and  sampling program.
The second response was  initiated in  later July when the
NYCDEP  released  a   request   for  proposals   (RFP)  and
contracted with  OHM  to  perform another  more  extensive
site survey and sampling program, which subsequently led
to  the  clean-up  actions  in  September-  December  1982.
Throughout  the   decision   making   process,   there  was
extensive  media  coverage  of  the site by all major New
York   newspapers,  magazines,   radio   and   television
stations,  which  created  added  pressure  on  government
decision makers to begin a clean-up.

     The  NYC  Department of  General  Services  contracted     300.65(b)(3)
with  a security  service  for  site  security on June  16,     security
1982  to  prevent  arson or vandalism that  would result  in
toxic  air emissions   from a  fire  or  off-site  surface
water  releases.    The  city,  rather  than  the  state,
initiated  this  action because the  NYSDEC believed  that
it  did  not   have  the necessary  resources  to  provide
continuing  guard  services.    The  NYSDEC  had  provided
guards  following  the  bankruptcy court's  granting  of the
trustee's  motion to  remove its  guards  due  to  lack  of
funds.

     The  NYCDEP  initiated  a  site  survey  and sampling     300.65(b)(5)
program  on June  15,  1982  to provide  a more accurate     sampling
assessment of the site hazards than that provided by the
July  1981 NYSDEC survey.   The NYCDEP was  attempting  to
obtain federal  or state assistence for  a site clean-up,
and intended  to  use the results of a site survey to make
its request   for  assistance more  specific.    The NYCDEP
initiated the site survey instead  of the  NYSDEC or the
U.S.  EPA because the other agencies believed that they
did not  have  the  necessary  resources  to  perform the
survey.

      This site   survey  clarified  the   physical  threat
posed by  the site,  which  provided  the impetus  for  a
clean-up.  The NYCDEP identified the primary threat as
the potential for  fire  from wastes  with flash points as
low  a 82°F  (28  °C).    The  combination  of  these low
flashpoint wastes,  with the presence of  large  volumes of
PCS  contaminated  wastes   in  leaking  tanks,  created  a
potential for hazardous  air emissions.   This threat of
fire was further heightened  by the use  of oxy-acetylene
welding  torches by an adjoining equipment company  about
20  feet  (6.1 m)  from  the Quanta  tanks.    Two  of the
buildings en-site  were  old  and  were  highly  flammable
with  the  waste  oil  stored inside.   The city and  state

                                      19-13
-------
 believed  that   low  temperature  combustion   of  PCBs
 produces dioxin emissions and  were very concerned about
 this public  health threat.

      The NYCDEP continued to  try to  compel the U.S.  EPA
 or the NYSDEC  to  provide  assistance  for the site survey
 and clean-up.     The NYCDEP  was continuing  to request
 funding or assistance  from  the U.S.  EPA  and the NYSDEC
 through administrative channels when, on  July  16, I982y
 a  representative of the Mayor  of New York City directed
 the NYCDEP  to  initiate a  clean-up  of  the  site.   This
 directive  followed  a  request  by the  New  York  State
 Select  Committee on  Crime dated July 14,  1982,  for  the
 mayor  "to convene a  task force to  address  immediately
 the Review Avenue situation."   On  July  20,  1982,  the
 NYCDEP  held  a meeting to draw up a request for proposals
 (RFP),   which  was   released  on  July  22,  1982.    The
 commissioner  of  the NYCDEP  made  the last requests  for
 federal  or  state  assistance,   prior  to initiating  city
 clean-up actions,  to the Regional Administrator  for  the
 U.S. EPA and the NYSDEC Commissioner on July 30  and  26,
 1982,  respectively.    The  U.S. EPA did not  provide  any
 CERCLA  funding  for the  site.

 Selection of  Response Technologies

     The NYCDEP  removed above  ground  wastes because  this
 was  the  level  of  response  necessary  to  eliminate  the
 threat  of  fire  and toxic air emissions.   The only other
 alternative  considered  was  the  use  of  a new PCB  oil
 decontamination  system  using   sodium and  catalysts  to
 precipitate  and filter out the PCB from the oil.  This
 alternative  was not  chosen because  the NYCDEP  on-scene
 coordinator   (OSC)   was  not   confident  of  its   proven
 practicality  for decontaminating oil in a thorough  and
 legal manner.   A subsurface clean-up  was not  included in
 the  site response because  it  was  beyond  the  necessary
 action  to mitigate the immediate threat of fire.  Also,
 a   subsurface  clean-up  would  have  required  a  hydro-
 geological study  and design,  which would  have  increased
 the time of the potential for fire.

     In  addition,  NYCDEP made  three  decisions  regarding
more specific response technologies.   First, the  NYCDEP
 decided  to use  lime dust  to  solidifiy  the waste  sludge
because  it was  more cost  effective  and more dependably
 available than  the alternatives  of cement kiln dust  or
 fly  ash.   The  exact  ratio was based  on on-site  testing
 performed by OHM chemists.

     The  NYCDEP's   selection   of on-site waste  water
 pretreatment   was   the   second   specific  technology
                                                 300.65(b)(6)
                                                 removal
                                                300.70(b)(2)
                                                (ii)(B) chemical
                                                treatment
                                                methods
choice.
The   alternative  of   off-site  commercial
                                     19-14
-------
pretreatment was not selected because  the  on-site  system
was  adequate  for, most wastes  and was  less expensive.
Cyanide wastes  were  commercially treated because  NYCDEP
and  OHM believed  the  on-site system  was  inadequate  to
treat them.

     Third, NYCDEP decided,  as  an  overall site policy,
to  dispose  of all wastes,  hazardous and  non-hazardous,
at permitted hazardous waste disposal  facilities because
it  was  concerned  about  public  reaction  to  disposal  of
any  waste  from  this  well  publicized  hazardous  waste
site.    The  alternative  of  sanitary  landfilling   of
solidified  non-hazardous  sludge at  no  charge  at city
owned landfills  was  not  chosen because of the  potential
public reaction  in the wake of recently publicized cases
of  illegal hazardous  waste  dumping  in  city   sanitary
landfills.   Similarly, the  NYCDEP was  concerned about
reaction   to   standard  boiler   incineration  of  non-
hazardous  oil  because of  recent publicity  about toxic
emissions  from  the  use  of  contaminated  oil   in city
apartment buildings.

Extent of Response

     Generally,   there  were   two  dec is ion  areas   for
determining  the   extent  of   the  response:  extent   of
material removed  and waste  water treatment  levels.   The
focus of the removal was on the  liquid wastes and  not on
the  potentially heavily  contaminated  soil  because  the
hazard  that initiated  the response  was  the  threat  of
fire and toxic  emissions, not  ground  water contamination
or  soil erosion  (e.g,  runoff  or  contaminated dust).   The
clean-up  action entailed  removal of  all  wastes  stored
on-site,  in  addition  to  the  low  flashpoint wastes,
because of  the  significant  economies of undertaking  the
full removal at the  same time since all wastes  had been
characterized.       The   tanks   were   emptied    and
decontaminated  until  they  were "squeegee  clean",   and
inspected  for  Gas-Free certification.   The disposal  of
the  uncontaminated  sludge  was at   a   standard  above
regulatory  requirements  because  city   officials were
concerned  about public anxiety   over  disposal   of waste
from a site known  to contain contaminated materials.

     The   levels  of  contaminants   permitted   in   the
wastewater  before disposal  into the  sewage system  are
shown in Table 2.  These levels  for pretreatment were
 300.65(b)(6)
 removal
 300.65(c)
 completion
 of  immediate
 removal
300.67(a)(l)
substantial
cost savings
300.70(b)(2)
conventional
wastewater
treatment
                                     19-15
-------
                  TABLE 2.   NYC INDUSTRIAL DISCHARGE CRITERIA
Parameter
PCS
Cadmium
Chromium (hexavalent)
Copper
Cyanide
Nickel
Zinc
Bromine, Iodine, Chlorine
Discharge Criteria
less than 10
less than 5
less than 5
less than 5
less than 2
less than 3
less than 5
less than 100
ug/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
tog/1
    Source: NYCDEP, 1982.
set by  the  NYC  Sewer Authority for two reasons.  First,
they have been  determined to have no detrimental effect
on  the  system's  biological  sewage  treatment process.
Second,  these  levels  ensure  that,  with  dilution,  the
system's  final  discharge will  comply  with  its   NPDES
permit standards.

DESIGN AND EXECUTION OF SITE RESPONSE

     The NYCDEP managed  three general site responses  at
Quanta:   initial  site  survey and protection,  OHM  site
survey, and removal.

Initial NYCDEP Site Survey and Protection

     On June  15,  1982 following  verbal notification  of
the NYCDEP  Commisioner's Declaration of  Emergency,  the
NYCDEP  Bureau of  Science and Technology's  (BST)  Field
Investigation unit  had the NYC Fire  Department cut  the
lock  on  the  front  gate.    The three   BST   employees
immediately began  sampling  and  recording the  size  and
condition of  the  tanks.   On June 22,  1982,  two NYSDEC
employees  assisted   the   BST  workers  on-site  with  the
sampling.   They also  assisted on June 24 and 25,  when
the sampling  was completed.   A total  of 142 samples were
taken from 61 tanks and analyzed by the NYCDEP lab.

     The  NYSDEC  and  NYS   Department  of Health   labs
analyzed  23  duplicate  samples.    On July 16,  1982,  a
NYCDEP   contractor,   CECOS   International,    collected
samples  from tanks that  were inaccessible  because  of
300.64(a)
preliminary
assessment
                                     19-16
-------
shaky  catwalks  or bolted lids.  A  leak  in non-hazardous
tank   10  was   plugged   by   the   NYC  Fire  Department's
Chemical  Response Unit.   The  NYCDEP and  the NYC  Fire
Department  also  spread  sorbent  material  around  leaky
tanks.

     When  the   site  emergency  was  declared  on June  15,
1982,  the NYCDEP  also requested that  the  NYC  Department
of  General   Services contract  for  security  guards  and
fence  repair.   Two  24  hour,  armed commercial  security
guards were hired on June 16,  1982.  Additional  security
was  provided  by  regular  NYC Police patrols.   A  10  foot
(3 ra)  galvanized  steel  fence with  razor barbed wire  was
erected around  the entire site.   Existing  lengths  of 10
foot  (3  m)  fence  on  the  north  and south  sides  were
repaired and barbed.

     On July  12,  1982,  the NYCDEP sampled air  on-site
with  an  organic vapor  analyzer  (OVA)  and a H-NU meter.
Levels  above  background  were  found  only  inside  the
laboratory building.

Phase  I - OHM Site Survey

     Following  the  signing  of a Letter  of Intent  with
NYCDEP on August  11,  1982,  OHM moved a mobile  analytical
laboratory,    decontamination   unit,   backhoe,    office
trailer,  crew/galley trailer and a vacuum skid  unit  to
Quanta, and set up on August 12, 1982.  Local hospitals
were  contacted  to identify  the  nearest  burn and poison
treatment centers.    Adjacent  facilities  and  the  local
fire   department   were   briefed   about   the  project.
Laboratory  instruments  were warmed and  calibrated.   To
soak  up  recent  run-off from  tank  JSEP3  and   prevent
runoff flows, OHM immediately  spread 30 bags of  sorbent
material around the  separator  and along  the  LIRR  tracks,
and  pumped  its  contents into tank  J17,    The   oil  was
found  to be uncontarainated.

     The  primary  task of OHM's  survey was liquid  waste
sampling.    But  air  samples  were  also  taken  daily  to
ensure safe ambient  levels  in the  "clean" on-site  areas
and  off-site,  and  several  soil  samples  were analyzed.
To   optimize   the   use   of   mobilized   equipment   and
personnel,  OHM  sampled  12  hours/day,  seven days/week
from August 12  -  25, 1982.   A "hot (contaminated)  zone"
was  delineated  with  luminescent  engineering   tape   on
August  13,   and  air  and  tank  sampling   began.    All
personnel  passing   into  this  area  south  of   the  lab
trailer (see Figure  2)  wore a minimum of  a hardhat with
face  shield,   respirator with  R-563  filter  cartrige,
tyvek  suits, Rabor  boots,  and rubber gloves.  Personnel
who were  opening  tanks  for  sampling wore  self-contained
300.65(b)(7)
physical
barriers

300.65(b)(3)
security
300.65(b)(5)
sampling
 300.71
 worker
 safety
                                     19-17
-------
breathing apparatus  (SCBA),  and Saran coated tyvek suits
with  hoods.   On  August  14,   electrical  power  (triple
phase  440  volt,   single  phase  220  and  110  volt)  was
established on-site.

     A  mobile  infrared   air   analyzer  (MIRAN)   and  a
photoionization  detector  (PID)   were  used  to   sample
ambient  air daily.   The two  PIDs used were  calibrated
for  benzene,   but  were   sensitive  to  most   organic
vapors.  A  PID monitoring  grid was established on August
13,  consisting  of 13  spray  painted  spots in the  clean
zone and 21 in the hot  zone, and  are shown as  solid dots
with letter/number codes  in Figure  2.   Throughout  the
survey  air  sampling  was  performed  on these  spots  at
least  once  daily.   Other  areas  that were  regularly
sampled  as  wind  and  work  activity  conditions  changed
were:  the  portajohn  area  near  the  south  end  of  the
decontamination  trailer;  the  SCBA  bottle filling  area
near the north side  of the  decontamination  trailer,  the
area in  the building A filter room,  and  the inside  of
the  lab  trailer.   Sample  crews sampled air inside  each
tank upon opening  it.   Since the  MIRAN's were  mounted on
carts,   only  about   half  of   the  grid  points   were
accessible for simultaneous sampling with the PID.

     Two  MIRAN1 s   with  chart   recorders  were  used  for
qualitative ambient  air  scans  and  for  specific  vapor
analysis.   One   was   calibrated   for  trichloroethylene
(TCE) and the other for tetrachloroethylene  (PCE).   Both
were capable  of  a lowest detection  limit  of 4  mg/m .
The maximum allowable  exposure  for TCE and  PCE  set  by
OSHA  is  100  mg/m .    Two  explosimeters  were used  to
measure combustible gases inside tanks.

     Upon initiating the  liquids  sampling  on August  13,
OHM  performed  an  inventory   and  inspection  of   the
tanks.    A  magnetometer  (metal  detector)  was  used  to
locate  buried  tanks.    Because of  metal structures  and
appurtenances,  excavation  was   necessary  to check  metal
detector  readings.   This survey  revealed  tank   H-220,
which was found under the south end of building H.

     A total  of  378  samples were  taken from 106  tanks
and  two  diked areas  at an  average rate  of 12  tanks/-
day.    Samples  were  split  for  NYCDEP  and  CH2M  Hill
verification.     Volumes  were  estimated  by  measuring
tanks,  and  liquid  layer depths  were measured and  sampled
with a bacon  bomb sampler.  Brass tools were used  when
necessary for  opening  tanks without  sparking.    Sludge
was sampled with  an  aluminum hatched  scoop  on extension
poles.    Sampling  equipment  was  decontaminated  between
samples  by  scrubbing  with  reagent hexane  and  rinsing
with  acetone.     Sampling   of  tanks  without   product

                                     19-18
-------
layering  was  performed by  lowering  an open quart  glass
jar  with  a nylon  string.   Duplicate one quart  (0.95  1)
aqueous  samples were  obtained  for  PCB  and  RCRA  metal
extraction  procedure  (EP)  testing,  as  well as  split  40
ml/amber vial samples for volatiles  analysis.

     On-site  sample analysis  work  began  on  August  15
following  connection  of  electrical power  to  the OHM
analytical  laboratory trailer by  NYCDEP.  The  analytical
methods used by OHM at Quanta were generally the minimum
testing necessary  to accurately  classify  the three  waste
types—oil,  aqueous  and  sludge—into  regulated   waste
stream categories.  This scheme provided the  background
for  an  efficient  removal  and disposal  operation.   For
example,   PCB  oil   and  sludge  required different removal
methods.     The  waste   stream   categorization  decision
matrix is summarized by the following outline:

    I.   Oil
         A. PCB oil (over 500 mg/1)
         B. PCB contaminated oil (under 50-500 mg/1)
         C. Non-PCB contaminated oil (under 50 mg/1)

              1.   Chlorinated  solvent  contaminated oil
                   (over 1% chlorination)
              2.   Non-contaminated   oil    (under    1%
                   chlorination)
                   a.    high sulfur saleable fuel oil
                   b.    low sulfur saleable fuel oil

    II.   Water
         A. PCB contaminated (at or over 10 ug/1)
         B. Non-PCB contaminated (under 10 ug/1)
              1.   Contaminated  with volatile  organics
                   (at  or over 1 mg/1)
              2.   Non-contaminated     with     volatile
                   organics (under 1  mg/1)
                   a.    contaminated   with  heavy metals
                        (at or over 5 mg/1)
                   b.    uncontaminated  water  (under  5
                        mg/1)

    III.  Sludge
         A. PCB contaminated (at or over 50 mg/1)
         B. Non-PCB contaminated (under 50 mg/1)
              1.   Flammable  (flash  point  at   or  under
                   60°C)
              2.   Non   Flammable  sludge  (flash  point
                   over 60°C)
                   a.    Toxic   (EP   toxicity   for   RCRA
                        metals-positive)
                   b.    Non-toxic (EP  toxicity for RCRA
                        metals-negative)

                                     19-19
-------
     All  analytical  protocols followed  appropriate  U.S.
EPA,  American Society  for the Testing  of Materials  or
National  Institute  for  Occupational  Safety  and  Health
procedures.  A Tracor  560  gas chromatograph was  used for
PCS and  volatile organics analysis.   Flash points  were
determined  with   a  Seta-flash   flash  point  detector.
Metals  analysis  was  performed with  an  IL single  beam
atomic absorption  spectrophometer.   Blanks or standards
were used for all  analyses.   Instruments were calibrated
at the change of each shift or analyst.

     Split samples taken by NYCDEP were  passed on to its
consultant, CH-M Hill  (Hill),  for the  quantity assurance
(QA) program.  The Hill engineer chose  samples  randomly
for analysis  by  Hill's Montgomery,  Alabama- laboratory,
amounting  to  about  15%   of   the  total.   Four  spiked
samples  were  also submitted  to  OHM and Hill's   labs  by
NYCDEP.    No  significant  differences   in  analytical
results were found between OHM and Hill's labs.   Aqueous
results  varied  slightly because  of  OHM1s  re-filtering
of samples.

Phase II - Removal

     The  actual   removal   and clean-up   operation  (see
Table  3:  "Quanta  Waste  Removal  Summary")  began  on     300.65(b)(6)
September 2,  1982.   Following the end of the survey  on     removal
August  25,  OHM  compiled  a  survey  report,  and moved
clean-up  equipment  to Quanta in  preparation  for  the
Phase  II  operation,   for  which  it  was  negotiating  a
contract with NYCDEP.   The four  main activities  of the
removal  operation  were:   (1) waste  consolidation,  (2)
waste removal and  transport,  (3)  on-site waste treatment
and off-site  disposal, and  (4)   tank,  dike,  separator,
piping,  and  building  decontamination   and  certifica-
tion.       Other    tasks    performed   by   OHM    included
recommendation   of   available   disposal  facilities,
sampling and  analysis  of  wastes  and  treated  water,  and
manifest preparation.

     Consulting services were  provided to NYCDEP by  CH^M
Hill during Phase  II.   The Hill  engineer maintained the
site diary and verified the amount of  wastes treated and
removed,  as  well  as  OHM's time  and  materials  charges.
Every third discharge  to  the  sewer was  verified by  Hill
analysis.  Disposal  sites  were inspected as necessary by
Hill field offices  to  verify  materials  arrival  or check
site compliance prior to transport.

On-Site Waste Consolidation and Transfer
     To  facilitate efficient  truck and train loading,  as
well  as  to allow  for  tank decontamination, wastes  were
consolidated  according to waste  stream  category  in the

                                     19-20
-------
 tanks  and separators  shown in  Figure 5  and  listed  in
 Table 4.   The  equipment used for transferring each waste
 stream category  is  listed  in Table 4.   Since non-aqueous
 wastes  filled  about 25% of the  1.5 million  gallon (5.7
 million  1) tank  capacity,  well  over  half of  the  tanks
 could  be  emptied  and  cleaned before  off-site  disposal
 began.   The  need  for  this capacity  will be  discussed
 briefly  in "Transportation  and Disposal".

     Since  non-pumpable  sludge  was   disposed  of  at  a
 permitted  hazardous  waste  landfill,   RCRA  regulations
 required  solidification.    Lime  dust  was  chosen as  the
 solidification material based on  on-site  tests by  OHM
 chemists.   A  lime: sludge  ratio  of  1:1  by weight  was
 based  on  OHM on-site   testing  to  meet  RCRA  landfill
 requirements.  Sludge was  mixed  with a total  of 893 tons
 (810 Mt) of  lime  dust in the KF  mixing area,  (see Figure
 5)  and  consolidated  on  and  covered  by  polyethylene
 sheets.

 Transportation and  Disposal

     Waste removal  began  on September  12  and ended  on
 December 1,  1982.   A total of 424,993 gallons  of  waste
was   transported   off-site   as    listed   by   category,
 transport  vehicle  volume,  date  shipped  and  disposal
 facility in  Table  3.   Wastes were loaded  using  the same
methods    noted   in    Table  4   in    "consolidation".
 Contamination of exterior vehicle  surfaces was  generally
 avoided, but spillage  was  wiped  off  before  departure.
After filling, all  closed valves and hatches  were sealed
with  evidence bands.    Variations  from  the  plan  are
 discussed  in "Project  Costs"  to  the  extent that  they
 affected costs.

Decontamination and Certification

     Following    waste    removal,    all    tanks    were
decontaminated using methods corresponding to whether or
not  they  were  PCB  contaminated.    Non-PCB  tanks  were
cleaned  according   to  American   Petroleum   Institute
practices,  using a  Butterworth System.  A Butterworth is
a  stainless  steel  unit   that  sprays   water   at   high
pressure   in  all   directions  by    spinning   on   two
perpendicular axes.   The unit is  lowered and raised  in
the  tank until  the walls  are  "squeegee" clean.    The
tanks were then  vented with  an  electric blower;  most
tanks were further ventilated bv  cutting  holes in  the
side about 10 square feet (10.9 m ) in area.
                                     19-21
-------
I
NJ
to
                     LEGEND

                   ig Tank and Site Identification Number

                   •  Air Monitoring Stations
                                        Figure 5.  Major Waste  Transfer/Storage  Stations
         SOURCE: O.H. Miterl.li
-------
                       TABLE 3.  QUANTA WASTE REMOVAL SUMMARY
Material
Category
Oil contaminated
with PCB (a)
PCB Oil (b)
Waste Oil with
Chlorinated
over 10,000 ppm
Non-contaminated
Waste Oil
Flammable Sludge
Pumpable Sludge
Contaminated with
PCB
Transport
Vehicle
Rail
Truck
Rail
Rail
Truck
Rail
Non-pumpable Truck
Sludge Contaminated
with PCB
Cyanide Solution
Non-pumpable PCB
Sludge over
500 ppm
Contaminated
De c on t ami na t i on
Liquid (Diesel
Fuel)
Nonhazardous
Sludge
Truck
Truck
Truck
Truck
Volume
Removed
38,716 gal
(146,540 1)
1,163 gal
(4,402 1)
78,920 gal
(2987 1)
119,830 gal
(453,557 1)
5,000 gal
(18925 1)
57,000 gal
(215,745 1)
430 tons
(390 Mt)
9,425 gal
(35674 1)
13 drums
(1,705 gal)
(6,453 1)
1,100 gal
(4,164 1)
886 tons
(804 Mt)
Dates
Shipped
10/21/82
10/22/82
09/29/82-
10/05/82
09/21/82-
10/05/82
10/13/82
10/15/82
11/09/82
11/10/82
12/01/82
12/01/82
11/13/82-
11/16/82
Disposal
Facility
Rollins, TX
Rollins, TX
SCA, ILL
SCA, ILL
Rollins, TX
ENS CO, AK
SCA, NY
SCA, NJ
Rollins, TX
Sea-Bright, KY
SCA, NY and
BFI, MD
(a)       PCB between 50-500 mg/1
(b)       PCB over 500 mg/1

     Source:    CH2M Hill Report 1983
                             19-23
-------
 TABLE 4.  PUMPABLE AND MECHANICAL WASTE TRANSFER AND REMOVAL EQUIPMENT
TRANSFER/REMOVAL EQUIPMENT
1500 gallon Vacuum Skid-Unit
Caterpillar 215 Backhoe
3000 gallon Vacuum Truck
Caterpillar 955 Front
End Loader
Diaphram Pumps
Bobcat Front End Loader
Submersible Pumps
Case 580 C Backhoe
Hydraulically Operated
Centrifugal Pump
WASTE TYPE
Aqueous
X

X

X

X

X
Oil
X

X

X

X

X
Pumpab le
Sludge
X

X

X




Non-pumbable
Sludge
X
X

X

X

X

Source: CH2 M Hill Report 1983.
                            19-24
-------
      Diesel  fuel  was used to decontaminate PCB-oil tanks
 X  2X and X3X, by triple rinsing.   Using  a  1,500 gallon
 (5,678  1) vacuum  skid  unit,  about 1,000  gallons (3,785
 1)  were  used  to  rinse  these  two  tanks.  Following  the
 diesel  fuel rinse,  a  fire  hose was  used to  rinse  the
 tanks with city water.

     Piping  and appurtenances  were  decontaminated with a
 high  pressure  water  laser.   Four crews wore  hard hats,
 saranex  suits  with  hoods,   splash   suits,   full-face
 respirators, protective gloves and over boots,  to clean
 contaminated   piping  after   cutting   it  into  workable
 lengths.   The cracker  tower  building and the warehouse
 building  were  cleaned manually  in a similar manner.

     All  tanks were certified "clean  and  gas  free" by a
 licensed  marine  chemist from  Marine  Chemists  Inc.   of
 Hoboken,  N.J.    An  explosimeter and  visual  inspection
 provided  this  certification  on the  first attempt for  all
 tanks.

 On-site Waste  Treatment

     The  166,469  gallons  (630,085  1)  of contaminated  and
 non-contaminated  water,  which was   in  tanks,   dikes,
 separators  and building  basements, was treated  on-site
 before  discharge  into  the  NYC sewer  system.   This  on-
 site pretreatment  reduced costs by avoiding high priced
 disposal  or  off-site pretreatment.   Some treated  waste
 waters  were used  for tank rinsing  in  the decontamination
 operation   and  retreated.     The   water  was   treated
 according   to   NYC   discharge   guidelines,    which   are
 discussed in the  "Extent  of  Site Response" section.   All
 treated effluent  as  tested by  the OHM lab for discharge
 approval  by  the  NYCDEP  OSC.    Every  third water sample
 was split with CH2M Hill for verification.  The  results
were not  significantly different between the two  labs.

     The  aqueous  treatment sytem was  a two step process:
 oil/water  separation,  and  physical   clarification  and
 filtration.     The  system was  set  up  on  August  31  and
September 1  before  other removal  activities  began  and
 consisted of  five 10,000 gallons  (37,850  1)  pools,  two
 chemical  mixing  tanks,   a  clarifier,  a  pressure sand
 filter,  two  carbon contact units,  and several types  of
pumps (see Figure  6  for  layout  and  location).   The first
5,200 gallon  (19,682 1)  batch of  water was  treated  on
September 3>  1981 at a  rate  of about 20  gallons/minute
 (76 I/minute).

     The  following  process  flow  description  describes
 the   system   at   Quanta.     Oily  water   from   tanks,
 separators,  and containment dikes was pumped into pool 1
300.71
worker
safety
300.70(b)(2)
(ii)(B)
chemical
treatment
                                     19-25
-------
           LEGEND
        MM Tank §nct Sit* Idintlflcttlon Number
       C/«  Air Monitoring Stitlcmi
SOURCE: O.H. Mittrlih
                           Figure  6.  Onsite  Waste  Water  Treatment  Facility
-------
Co  allow  the  free  oil  to  separate  from  the   waste
water.   The  waste water from  pool  I was pumped to pool
II where it was acidified  to about  pH 4  to  break any oil
emulsion and  allow the oil  to separate from  the water.
Waste  water   from either  pool  I  or  II was  pumped  to
Chemical Mix  Tank I  (CMT I) and treated with  caustic  to
raise  the pH  to  11-12.   A polymer was also  added to aid
in  the agglomeration  of  flocculant  formed in alkaline
solution.   After  pumping  this alkaline  waste water  to
Chemical  Mix  Tank  II  (CMT  II)  from  CMT  I,   it  is
acidified to  pH 6-9 to be  compatible with the  storage  in
pools  III, IV and V and the  sewer  system.   A  clarifier
tank was then used to  allow the  solids,  heavy  metals and
PCB to  precipitate and settle.  Finally, a  sand filter,
filled  with  uniformly graded  sand,  was  used  to filter
out any flocculant solids  or other particulate matter
that  did  not settle  out  in the  clarifier.   The carbon
contact  units were  not  used  because  adequate  PCB  and
volatile organics  removal  was  achieved in  the  preceding
physical/chemical treatment.

COST AND FUNDING

Source of Funding

     All project  costs were borne by  the NYCDEP, except
site  security, which  was paid by  the NYC Department  of
General  Services  Real Property  Division.   On December
29, 1982, the NYC  Corporate Counsel  petitioned the  State
Supreme Court to  set  aside the NYSDEC's denial of  state
Superfund money,  and  to  direct  the state   to  reimburse
the city for  expenditures  of about  $2.5 million for the
Quanta  response.   The  city  has alleged,  inter  alia, that
the state  violated its mandated responsibilities  under
the state Environmental Conservation Law (ECL) and that
the state's denial of  the  city's State Superfund request
was "erroneous,  arbitrary  and capricious".   The  state
contends  that Quanta  does not  qualify  as  an inactive
hazardous waste site  under the state  Superfund Law;  and
the NYSDEC  lacked  the resources  to  respond  to Quanta
under the ECL.  The case is pending  as of February  1983.

Selection of Contractors

     Major contractors were  selected  by  a competitive
bidding process.   Time and  material  contracts  with  price
ceilings were used.   This section  only  discusses  the
selection of  the main survey and removal contractor.

     On  July 22,  1982,  following   the  Mayor' s  July  16
directive, the  NYCDEP released  a  request  for  proposals
(RFP),  "to  furnish  all   labor, equipment and  skills
necessary to  accomplish  the removal  and disposal of PCB

                                     19-27
-------
 contaminated  oil, solvents,  chemicals,  water  and  other
 materials  uncharacteristic of  waste oil products  which
 are  a hazard to  the  public and  the environment  located
 at  the Quanta...  Long Island City."  Six proposals were
 submitted by  the  July 29,  1982  deadline.

      The proposals were  evaluated by NYCDEP and its man-
 agement consultant, CH2M Hill,  of Reston Va.  On July 29,
 1982  the NYCDEP released a "Special Report"  on proposed
 criteria  for  evaluating proposals.   A description  of
 each  criterion was  given,  and  the relative weight  of
 each  criterion was  itemized  (see  Table  5).   All  six
 proposals were  evaluated by NYCDEP  BST, and  on August 2
 a  report was  sent  to  the  Deputy  Commissioner.    The
 report  considered 14 aspects  of  the  OHM and  the  first
 runner-up proposal, including  financial,  management,  and
 technical approach.  Other proposals received decreasing
 scrunity proportional  to  their non-responsiveness.   If
 the   proposals  were  believed  by  NYCDEP   to   contain
 excessive  "boiler plate"  and  inadequate  specific  site
 considerations,   they  were   considered   non-responsive.
 The OHM proposal  was  specifically believed by  NYCDEP  to
 show  OHM  to be "uniquely  qualified" based on  technical
 and   operational   abilities,   program  management,   and
 transportation  and disposal proposals.   Recommendations
 on details  like permits verification  were  also made  in
 the NYCDEP proposal evaluation.

     On  August   9,  1982,  CH2M  Hill   submitted  their
 proposal evaluation to  NYCDEP.   Two proposal  evaluation
 teams  independently  reviewed proposals.   Two  of the  6
 proposals were  considered  non-responsive and were  given
 detailed scrutiny by only  one  team.   Scores between 1-10
were  given  to each proposal  for 43  different  criteria.
The  general  criteria  categories and  weighting  were:
 general  responsiveness   to RFP  (5%,  3  criteria),  ex-
perience and  qualifications (20%,  9  criteria),  technical
 approach  (50%,  23  criteria),  financial considerations
 (25%,  8 criteria).    These  criteria  were  established
 through  discussions  with  NYCDEP  about   its  projects
 needs.  Both  evaluation  teams picked OHM for  recommenda-
 tion,  with  no  significant  differences  in   the  total
 scores.

Project Costs

     The  total   cost   of   $2,398,959  for   the  Quanta
Resources  clean-up  includes  tasks  listed  in  Table  6.
This  total  exceeded  the initial  rough estimate of  $1.5
million made  in July  1982, partly because of delays  and
price  increases  during   the  transportation  and disposal
phase.  This  phase was  the  largest  single cost  item  of
 the project.

                                     19-28
-------
    TABLE 5.  NYCDEP BST PROPOSAL EVALUATION CRITERIA FOR QUANTA - July 29, 1982
Criteria"                              100% Weight
Part One
General Program and Plan                       20%
    a. Outline of project and objectives
    b. Problem areas

Detailed Technical Approach                    60%

    a. Timetable 10%

    b. Public safety, monitoring and
         site security 10%

    c. Testing and quality assurance 10%

    d. Legal removal, transportation and
         disposal 20%

    e. Equipment and decontamination 10%

Company experience and Qualifications          20%

    a. Qualifications 12%

    b. Past performance 8%
Part Two

Financial Details                              100%

    a. Overall cost estimate 30%

    b. Time and Material costs 40%

    c. Company's resources (bonds, sureties, insurance) 30%
    Source: NYCDEP BST bid proposal evaluation special report
                                     19-29
-------
       TABLE 6.  SUMMARY OF PROJECT COSTS - QUANTA, QUEENS, NEW YORK
A,   Clean-up Contractor

     1.   Site Survey                   $  217,395

     2.   Transportation and
          Disposal (Table 5)            $  645,728

     3.   Tank Decontamination, Water
          Treatment, etc.               $1,236,877

                         (Subtotal      $2,100,008)

B.   Management Consultant              $  176,015
     (Proposal Evaluation, On-Site
     Monitoring, Analysis, Quality
     Assurance)

C.   Site Security                      $   73,920

D.   Electricity                        $   13,600

E.   Emergency Medical Service          $   20,000

F.   Miscellaneous                      $   15,424


                         Total          $2,256,377
                                  19-30
-------
 Transportation and Disposal
      The  costs   of   transportation  and  disposal  are
 summarized in Table 7-  The total cost listed in Table 6
 includes  an  additional   $64,149    for  miscellaneous
 transportation   related   costs,   such   as   facility
 inspection and  delivery  monitoring.    Also,  the  costs
 listed include a  15%  subcontractor handling  fee.   Both
 trains and trucks  were  used for  transportation.   Train
 tankers  held about  20,000 gallons (75,700  1).    Tank
 trucks  for   liquids  held  3,000  -  5,000  gallons  while
 slide-off  dumpsters for solidified  sludge hauled 12 - 14
 cubic yards each.

      Four  problems  occurred  during  the transportation
 and   disposal  phase  that  increased costs.   First,  an
 additional transportation cost of'$4,313 was incurred in
 September  1982  for  double  handling  of  non-hazardous
 oil.     This   extra  handling   cost  occurred  when  on
 September  9,   1982  two   tanker  trucks,  which had  been
 loaded  and   inspected   for  shipment,   were   unloaded
 following  a  phone  call  from  NYSDEC  to  NYCDEP.    The
 NYSDEC halted the planned  100 mile  (161  km)  shipment to
 a  rotary  kiln  in  Marion,  NY,  south of  Albany,  becuase
 the   faci 1 ity' s permit might  have  been  revoked in  the
 future.   The   transportation  and disposal  of  the  oil to
 the  hazardous waste  incinerator in Chicago  (818  miles,
 1316  km) also added  some marginal  cost  compared  to the
 Marion option.   The second problem  that  occurred  during
 transportation  was   leakage   from  two  train  tankers.
 While on  route   to  the  incinerator  in  Arkansas,  a
 pressure valve  on  one  tank car carrying PCS contaminated
 oil  allowed the substance  to splash on the sides  of the
 tanker.    On  another  car, substances  splashed from an
 unplugged  air vent valve  and  an ungasketed man-way.   A
 third car arrived intact  and  sealed.    The  volume  of
 spillage  was   unclear,  because  substances had  expanded
 due  to  temperature  changes.    The  NYCDEP's  consultant,
 CIUM  Hill, travelled  to   the  facility  to inspect  the
 cars,  as well as  renegotiate  the incineration price,  due
 to the unexpectedly high heavy metal content of the oil.

      The   third  extra  cost  was   incurred   for   extra
handling  of   non-hazardous  sludge when  it  could not  be
 received by  the Rollins  facility  in Bridgeport, NJ  for
 technical  reasons.   On  October 13,  1982,  about  7,800
gallons  (29,523  1)  of non-hazardous  sludge was pumped
 into  two  tank  trucks,  but upon  arrival in  Bridgeport
they  could not be  pumped  out by the  facility's pumps.
One  Canker was  emptied  with  difficulty  but  the  other
 truck  was  returned and unloaded  to  pool 6 and tank  J42
because Rollins believed  that  the sludge would clog  the
incinerator screens  and  appurtenances.   This  sludge  was
recategorized an non-pumpable.

                                     19-31
-------
                         TABLE 7.   SUMMARY OF 1982 TRANSPORTATION AND DISPOSAL (a) COSTS
                               QUANTA RESOURCES,  LONG ISLAND CITY, NEW YORK
Material
PCB contaminated (l>)
oil
PCB oil (over 500 mg/1)
Oil with over 10,000mg/l
ilorinated organius
Non-contaminated oil
.ammable Sludge
Pumpable PCB contain!-
gated sliuhu- (10 	
Non-pumpable PCB
Contaminated Sludge
Cyanide Solution
Non-pumpable 1*08 Sludge
Contaminated diesel
fuel (from decontamina-
tion)
Nun-liaiiardmifi Slud^<;
II sen Itanium's
Total
Quantity
38,716 gallons(146,540 ].)
1,740 miles (2,800 km)
1,163 gallons (4,402 1)
1.740 miles (2,800 km)
78,920 gallons(298,712 1)
818 miles (1316 km)
119,830 gallons(853,557 1)
818 miles (1316 km)
5,000 gallons (18,925 1)
100 miles (161 km)
57,000 gallons(215,745 1)
1,420 miles (2,285 km)
430 cubic yards (329 m3)
400 miles (644 km)
9,425 gallons(35,674 1)
100 miles (161 km)
1,705 gallons(6,453 1)
1740 miles (2,800 km)
1,100 gallons(4,164 1)
1340 miles (2160 km)
838 tons (760 Mt)
48 tons (44 Mt)
185 miles (295 km)
NA
Actual Expenditure Combined
(Transportation/Disposal)
$83,330
($42,678/$40,652)
$7,607
(S6.386/S1.221)
$36,466
($29,837/$6,629)
$45,254
($39,262/$5,992)
$8,105
($2,960/$5,145)
$113,521
($57.661/$55,860)
$86,410
$15,495
($2,771/$12,724)
$22,885
$4,416 (3)
$149, 7 30
(SQ1 .070/S58.6601
$8,280
($5,640/$2,640)
$64,229
UNIT COST
Transportation (d)
0.06d/gallon/mile
(O.OU/l/kra)R
.32# gallon/mile
(0.05<
-------
      The fourth  extra  transportation cost  was incurred
 during  the  transportation  of  non-hazardous  sludge  to
 landfills  in Maryland  (Browning Ferris  Industries)  and
 Niagra Falls,  N.Y (SCA).   Initially,  NYCDEP had planned
 to  dispose of  solidified non-hazardous  sludge in city-
 owned  sanitary   landfills.    But  because   of  long-term
 public concern  about illegal hazardous material disposal
 in  city-owned  landfills,  as  well  as  illegal  hazardous
 material  incineration  in  apartment  building  boilers,
 NYCDEP decided  that the Quanta  disposal  policy would be
 to  dispose  of   all  material,  RCRA  hazardous  and  non-
 hazardous,  at  permitted hazardous  waste  facilities.   On
 November 3,  1983,  8 trucks transported  solidified  non-
 hazardous  sludge  to the  BFI  facility  near  Baltimore.
 After one  truck was  unloaded,  the  State  of  Maryland
 contended  that  the material was hazardous  because  of  a
 low   flash  point,  and  halted  unloading   the  other  7
 trucks.   The waste  was  recharacterized  by  OHM and  CH M
 Hill,   with   the  latter,   an  independent   consultant,
 providing  results  showing  it  to  be  non-hazardous  on
 November  9,   1982.     Both  used   chromatograph   mass
 spectrometry to  identify  the volatile organics.   On the
 same   date,  the  State   of  Maryland  sent   a  letter  to
 NYSDEC,    noting    that    a    gas    chromatograph/mass
 spectrometry  characterization  would   be  needed.     On
 November 16,  1982 the State  of Maryland concurred  with
 NYCDEP's   analysis,   and   allowed  disposal.     In   the
 intervening  weeks,  838  tons  (924  Mt)  of  non-hazardous
 sludge  was  sent  400 miles (295 km) to Niagra Falls  to  a
 permitted  hazardous  waste landfill at  a  cost  of  $1,000
 transportation  per  truckload  and  $70/ton   ($77/Mt)  for
 disposal,  compared  with  $700  transportation per  truck
 load  and  $55/ton ($61/Mt)  disposal  for  the  185 miles
 (298  km) to BFI.   The NYCDEP's consultant, ClUM Hill,
 concluded   that,   "After   a   thorough    review   of   the
 circumstances related  to  the  disposal  problems  at  BFI,
 it  is   apparent   that   the rejection  of   Quanta  non-
 hazardous  sludge  had   less   to   do  with  the  waste
 characterization  data discrepancies as with inter-state
 regulatory political factors."

Management Consulting

     The sum cost of $176,015  for  management consulting
by   CH-M   Hill   included  assistance   for   proposal
evaluation, contract  negotiations,  inventory assistance
and  on-site  engineering.    The  $10,000  cost  of   the
proposal evaluation  work  is  the only  cost  that can be
 segregated from the other tasks.

     Services performed  by various city  agencies  cannot
be precisely tallied, but  some estimates  on  the level of
effort  were  made.   The Department  of  General  Services

                                     19-33
-------
paid for  electricity,  which was estimated at $8,100  for
90  days   at  $30/day,  and  $5,500  for  the installation.
The  Department   of  Health   and   Hospitals  paid   for
emergency  medical   services.     This  sum  includes   a
specially   equipped   mobile   first-aid   station   and
supervisor,  special  transportation arrangements and  the
maintenance  of  medical profiles.    About  $20,000  was
spent  on  equipment,  and  2,140 hours  of personnel  time
(54%   overtime)    and   246   hours  of   overhead   were
estimated.  The  NYC  police  provided about  2,000  hours of
site surveillance.

     Two  24  hour/day  armed security  guards,  each  with
trained attack  dogs, cost  about  $73,000.   The  site  was
guarded for  about 22 weeks  by a security service  hired
by   the  NYC  Department of  General Services from  about
June  16  - December 1,  1982.    The unit  cost   for  this
level  of  security  was $3,360/week  or about $10/guard/
hour.   The  services  provided by NYCDEP  BST can not  be
accurately accounted for,  but  level  of effort  by  hours
can  be estimated.    A total  of about  4,000  hours  was
spent  by the   NYCDEP  personnel  on   the  preliminary
assessment  (1,100  hours)   and  survey/removal   contract
monitoring   (3,000  hours).    Over  half  (53%)   of  the
contract  monitoring  was done on overtime.  Miscellaneous
NYCDEP  expenditures  totalled  $15,424  including  fence
repair, flashpoint analysis equipment,  preliminary tank
sampling,  safety  coveralls,  electrical supplies,  waste
drums   and   cans,   rain   coats,   portable    toilets,
radiological  survey  and lab  coats.

Future Cost

     The  future  costs of work at Quanta are  unquantified
as  of  January 1983, but involve two primary tasks.  The
first  is  a hydrogeological  study to determine  the extent
of  subsurface  contamination  and  remedial  needs.    The
second  potential  cost  is   the   implementation   of  a
subsurface clean-up.

PERFORMANCE  EVALUATION
     The   NYCDEP  site  response  accomplished  what  it
intended  to  accomplish—prevent  a fire  and  toxic  air
emissions and  remove  hazardous wastes  from  the  site.
After   its   initiation  in  July   1982,   the   clean-up
operation was  performed  effectively  and  rapidly with
only a couple  of  relatively  brief delays.   Primarily,
NYCDEP's  meticulous  and  assertive oversight,  and  0. H.
Materials'  technical expertise  and equipment,   served to
expedite  this removal operation in a highly professional
manner.   The NYCDEP1s  management  consultant,  CH2M Hill,
helped resolve  delays  by  providing  an independent view
 of problems  and solutions.

                                     19-34
-------
     Three relatively minor  technical  changes could have
improved   the   efficiency  of   the  removal   operation.
First,  the off-loading  pumps at the disposal  site  to be
used  for  non-hazardous  sludge  were  less  capable  of
pumping the  sludge  than the contractor's  on-site  sludge
pumps.  If  the contractor had  anticipated this  problem,
the cost  of  returning  and  off-loading the wastes  could
have been  avoided.   Second,  the expansion of waste oil
in  the  tank car  traveling  to  Arkansas caused  spillage
through  vents  that   could   have  affected   sensitive
populations  en route.   Extra  head  space   to  anticipate
the spillage might have prevented this occurrence.

     The  third,  and somewhat  more  general,  technical
improvement  could have  been made by undertaking a  level
of   anlaysis   that   matched   the   selected   disposal
alternative.     Since   the   policy   decision   was   made,
because of  public concerns,  to dispose  of all wastes,
hazardous and  non-hazardous, at licensed hazardous  waste
facilities,  the precise characterization  at  13  distinct
waste  streams  for  disposal was  unnecessary.   A  lower
level of  waste characterization,  sufficient  to analyze
PCS, non-PCB and  cyanide  wastes, and  segregate  pumpable
and  flammable  wastes   would   have  been  more   cost-
effective.    The  preliminary   site  survey,  which  cost
NYCDEP  about $2,000  and 1,000  hours of staff time,  may
have   been  adequate   for   this    purpose .  with   some
supplemental testing.   The  OHM survey, which  cost  about
$217,000  and  created  an  extensive  categorization  of
specific waste  streams, was  beyond  the needs  of general
manifest   requirements   and   PCS    vs.    non-PCB   waste
categorization.   The   specific analysis  necessary  for
disposal cost  determination  could have been left for the
disposal site  operator  to  perform,  with  independently
analyzed split samples.

     The   general   problem   of   determining   response
authority and  responsibility,   which will  be settled  in
court through  the pending law  suits,  is  largely beyond
the  scope   of   this   technical   evaluation,   but   it
significantly  affected  the public  health  risk.   During
the several  months  when  the  various  parties discussed
their  site  response   obligations,  the   public  health
threat  at  the  site  remained   imminent.    The  need  for
parties  to  have  clearly   delineated authorities  and
responsibilities  is  as  important   in  protecting public
health  as   the  technical   innovation   and  expertise
employed at the site.

     In sum, however,   the  site response  was  successful
in  removing  the imminent public health threat.   Future
work at the  site will  involve assessing and  possibly
mitigating   surface,   subsurface    and   ground   water

                                     19-35
-------
contamination.     Also,   the  on-site  structures   will
probably  be  removed  for  the  site  to be used  in  the
future.
                                      19-36
-------
                           BIBLIOGRAPHY
 Bureau of National Affairs.  1982.   State Water Laws.

 CECOS International.  October 5, 1982.   Correspondence to NYCDEP.

 CH2M Hill.  December 1982.   "Draft  Engineering Services Report/
      Quanta Resources Site  Clean-up."  Reston, Va.

 CHjM Hill. 1982.   Correspondence, Reston Va.

 Chojnowski,  Kathy. 1983.  Personal  communication with  Environmental
      Law Institute.   U.S. EPA.   New York,  N.Y.

 Kuntz,  Glen.  1983.  Personal communications with Environmental
      Law  Institute.    U.   S.  EPA  Office   of Toxic  Substances,
      Washington,  D.C.

 Long Island  Railroad.   September 20,  1982.  Correspondence  to
      0.  H. Material  about hauling prices.  Long Island City, N.Y.

 National  Weather  Service, 1981.  Local  Climatological  Data,
      Annual  Summary  With Comparative  Data  - LaGuardia  Field.
      New  York, N.Y.

 New  York  City Fire Department. June  1982.  Correspondence.
      New  York, N.Y.

 New  York  Magazine. July 19,  1982.  "Hazardous  Waste Abandoned in
      Long Island  City."

 New  York  City Law Department. 1982.  Memoranda and correspondence,
      New  York, N.Y.

 New  York  City Department of Environmental Protection 1982, 1983.
     Memoranda, correspondence,  special reports,  field  notebook,
     manifests, mailgrams,  invoices, requests  for proposals.
     New York, N.Y.

New York Times.  Business Day Section.  April  1982.  "Toxic Waste
     Entrepreneur."

New York State Department of Environmental Conservation (NYSDEC)
     "Hazardous Waste Disposal Sites in New York State, Volume 1,
     June 1980"  Albany, N.Y.
                                19-37
-------
NYSDEC 1980 - 1982.  Memoranda and correspondence.  New York, N.Y.
0. H. Materials. 1982-1983.  Site Survey Report, proposal,
     correspondence.  Findlay, Ohio.

Ott, Gary. 1982.  Personal communication with Environmental
     Law Institute.  NYCDEP, New York, N.Y.

Soren, Julian. 1971.  "Ground Water and Geohydrologic Conditions
     in  Queens  County,  Long  Island,  New York;   U.S.  Geological
     Survey Water Paper 2001-A."  U.S. Government Printing Office,
     Washington,D.C.

Sprague, Bruce.   October 26, 1982.  Pollution Report.
     U.S. EPA, Edison, New Jersey.

Starks, Thomas.   January 1983.  Personal communication with
     Environmental Law Institute.  Rollins Environmental Services,
     Deer Park,  Texas.

Stearns, Nancy.  1983. Personal communication. N.Y. State Attorney
     General's Office New York, N.Y.

Supreme Court of the State of New York.  December 29, 1982.
     "Petition 1996S/82- The City of New York v. Robert F. Flacke,
     Commisioner, NYSDEC.

U.S. District Court, Southern District  of New York 1982.
     Indictment U.S. Kenneth Mansfield  New York, N.Y.

Vickers, Amy. 1983. Personel communication with Environmental
     Law  Institute. NYCDEP, New York, N.Y.

McEnroe, W.F.,  1982, Correspondence with Nolan, Bell & Moore, Esq.,
     Newark, N.Y.

Weiss,  Carey. 1982. Personal  communication with Environmental Law
      institute.  NYCDEP, New York,  N.Y.
                                  19-38
-------
                           RICHMOND SANITARY SERVICE

                             RICHMOND, CALIFORNIA
 INTRODUCTION

      Richmond   Sanitary  Service (RSS)  is a  commercially
 operated  350-acre  (142  ha)   landfill  in  Richmond,
 California.  A  15-acre (6 ha) area of the site is used for
 disposal  of  Class  I  (hazardous)  wastes, while  the
 remainder  of  the   landfill  is  used  for  Class  II  (non-
 hazardous)  waste  disposal.   In  1975,  the California
 Regional  Water  Quality Control  Board  (RWQCB)  and  the
 California Department of Health (DoH) found that  the Class
 I  area  did  not  meet   new   state  regulations  regarding
 hazardous  waste facility  design  and operation, and  that
 the   site  posed  a  threat   to  surface  waters,   landfill
 employees, and  air  quality,

 Background

      The  RSS   site  is  Located  on  San Pablo Bay at the
 outlet   of   San   Pablo   Creek.  The   State-designated
 beneficial  uses  of  the  bay and  the  creek  area  are:
 recreation,  aquatic,   waterfowl,  and  migratory  bird
 habitat,  industrial   water  supply,   and  navigation.
 Richmond  Sanitary   Service began  accepting municipal  and
 industrial wastes in 1952.   In 1973, the RWQCB ordered RSS
 to  designate  separate  areas  for  Class  I  and  Class  II
 wastes.   The  designated  Class I section, consisting  of  a
 six-acre  (2.4  ha)   drum  burial  area and a  nine-acre  (3.5
 ha)  liquid waste evaporation  pond,  was  situated  on  top of
 an older layer of municipal solid  waste.

      Throughout  the early to raid-1970's,   state  agencies
 cited  RSS  for  numerous health, safety, and  air  pollution
 problems at the  site.  Drums  of solid  and  liquid chemical
 waste  often  ruptured  while being  dumped from trucks,  and
 were   not   segregated   according    to    compatibility.
Volatile  liquids  were  dumped   in   the evaporation pond,
 causing  nearby  residents  to  complain of  chemical  odors.
 In  1975,  the  RWQCB  ordered  RSS   to  make   a  number of
operational and  design  improvements in both  the Class  I
 and Class  II  areas.  Richmond Sanitary Service  responded
with  an engineering master plan for the site  proposing  a

                                     20-1
NCP reference
300.68(e)(2)(iv)
environmental
effects
-------
much  expanded  Class  I  area  enclosed  by  a  relatively
impermeable bay  mud subsurface barrier.   In  March 1976,
the RWQCB rejected  the  Class  I expansion plan but ordered
RSS  to  construct  a subsurface barrier,  a  two-foot high
dike  around  the  existing Class  I  area,  and  a  basin to
catch rainfall runoff  and liquid  waste  overflow  from the
Class  I  area.    Also  in 1976,  the  DoH  ordered  RSS to
improve waste handling and burial practices.

Synopsis of Site Response

     On September  14,  1976, RSS began construction of the
subsurface  barrier, the dike,  and  the  retention  basin
using  RSS'  own  earth-moving  equipment  and  operators.
The  work  was  inspected  by   the  engineering   firm  that
designed  the  improvements.  The  five-foot  (1.5 m) wide
barrier  ranged  from  5 to 30  feet (1.5 -9.1 m)  deep, and
was  2,765  feet (843 m) long.  The  new  barrier was  con-
nected to 2,100 feet (640 m) of a  pre-existing barrier to
completely enclose  a 25-acre (10.1 ha) area containing the
Class I  pond, drum burial area, and retention basin.  The
construction  took  28  days  over  a  seven-week  period,
including 16 days for the barrier and 12 days for the  dike
and  retention basin.   Six months  later,  ten monitoring
wells were installed in the barrier.
300.70(b)(l)
impermeable
barriers

300.70(b)(l)(ii)
(B)(l)
dikes and berms
SITE DESCRIPTION

     The Richmond Sanitary Service site is an active  land-
fill which  is permitted  to  accept  solid municipal wastes
(Class  II)  and hazardous  wastes (Class  l)  from  the  San
Francisco Bay Area.   Class I wastes are currently limited
to contaminated solids in the barrel storage area and acid
and caustic rinse water in the holding pond.

Surface Charaj^teristics

     The site  occupies approximately 350 acres  (142 ha)  of
former marshland  and tidelands  adjacent to San Pablo Bay,
in southwestern  Contra Costa County.   More specifically,
it is  situated at the foot  of  Parr  Boulevard in the City
of Richmond  and is  bounded  on  the west  and southwest  by
the  Bay and  on the  north  by  San  Pablo Creek.   The  San
Pablo  Sewage  Treatment  Plant  is located just west of the
site.   The   area  is  highly   industrialized.   A    large
refinery is located  less  than   1.5 miles- (2.4 Km) from the
site boundaries.

     Figures   1  and   2 show the  location  of  the   site.
Figure  2  also shows  the  relative  location  of the Class I
and Class II  areas.   The  Class  I area  comprises  only  about
300.68(e)(2)(i)
(A)
population  at
risk
                                      20-2
-------
Figure 1. Location of the Richmond Sanitary Service Site
                          Richmond, California

                                 20-3
-------
    I  RICHMOND SITE]
Figure 2.
Location of the Richmond Sanitary Services Class I and
Class II Disposal Areas in Richmond, California
                      20-4
-------
 25  acres  (10.1  ha)
 (142 ha) Landfill.
or  about  7 percent  of the  350  acre
      Because the site is  situated in former tideLands and
 marshlands  of San  Pablo Bay, potential for  flooding has
 been  a  concern.  However, as  Figure 2  illustrates, the
 Class  I  area is buffered  from tidal action by the Class
 II area and by a perimeter  dike.   However,  it  should also
 be noted that lower San Pablo Creek closely parallels both
 the Class I and Class  II  areas  along the northerly bound-
 ary of  the  site  before emptying into San Pablo  Bay.  The
 magnitude of flood  flow that  reaches the Class  I  area is
 limited mainly by the channel capacity  of  San  Pablo Creek
 and to a much lesser extent of Wildcat Creek.

      The San  Pablo  Bay  area  has cool, dry  summers and
 mild,  moist  winters.   The  mean  annual  temperature  is
 58.2 F  (14.6°C).   The   mean  monthly  temperature  ranges
 from a low of 50.2°F (10.TO in January to 65°F (18.3°C)
 in September.

      The average annual precipitation  in  Richmond  is  22
 inches (56  cm).   The winters are moist and  over 90 percent
 of the precipitation falls between  November  and May.  Late
 in spring and summer coastal  fog is  common  in  the  bay and
 usually clears by late  morning.   In winter, the  relative
 humidity averages about  90 percent  at night  and 70  percent
 in the afternoon.

 Hydrogeology

      The  RSS   site   lies   in  an alluvial valley which is
 covered   with   Reyes silty  organic   clay  soils  which are
 nearly  level,  very poorly drained,  highly   compressible,
 and   nearly   impermeable.   These  soils are commonly called
 Bay  Muds.   The  water   table  is  at   or  near  the  ground
 surface.

      Figure  3 shows  the  general  geology  in the  area of San
 Pablo  Bay.    As  shown,   the  alluvial  valley  in which  the
 Richmond  Site  is  located  is  separated   from the  bedrock
 formations to the northeast  by the  Hayward fault.   The San
 Pedro  -  San  Pablo   fault  separates  the valley  from  the
 bedrock  formation to  the southwest.

     The  Hayward  fault,  located approximately  1.3  miles
 (2.1 Km)  east of the  site  is seismically  active and  is  one
 of the great earthquake  faults in this part  of California.
 The  San  Pedro -  San Pablo  fault is  not considered  to be
 seismically  active.   The  San  Andreas fault,  although 16
miles  (26 Km) southeast of the site,  is considered  to pose
 a greater threat than the Hayward Fault.
                                         300.68(e)(2)(i)
                                         (D)
                                         hydrogeologic
                                         factors
                                         300.68(e)(2)(i)
                                         (E)
                                         climate
                                         300.68(e)(2)(i)
                                         (D)
                                         hydrogeologic
                                         factors
                                     20-5
-------
N>
O
 I
                                                                                                                          tot
                                                                                                                 Orlnda Formation

                                                                                                                 non-marine conglomerate,
                                                                                                                  sandstone and clay

                           RICHMOND  SITE
                                          and marsh deposits
Valley fill alluvium
sand,silt, clay and gravel
                  Kjf
             Franciscan Formation
             marine sandstone and shale
                Figure 3.  Surface Geology in the Area of the Richmond  Sanitary Service Site
-------
      A  combination  of driller's water  well logs,  founda-
 tion borings,  water  Level records, and  etc.  were used by
 Nevin  and  Ellis  (1971)  to construct  a  hydrogeologic
 cross-section  of the  area  as  shown  in Figure  4.   The
 alluvial  valley  is  underlain by  a considerable  thickness
 of unconsoLidated sediments  consisting  of silty clay with
 interbedded  layers  of sand,  shells, and  peat.   These bay
 muds, as  they are called,  occur to a  depth  of at least 50
 feet (15m)  along  the  eastern boundary of the  site  and to
 at  least  150  feet  (46ra)  along  the  western boundary  as
 shown  in  Figure  4.    Lenses  of  sand  found  within the bay
 mud occur erratically and discontinuously.  The bay mud is
 generally  underlain  by  a sand  unit  deposited  by  stream
 channels which once traversed the  area enroute to the Bay.
 These sand  and  gravel layers are  sparse,  highly variable
 in occurrence and generally  only a few  feet thick.   These
 pervious  layers are found  mostly at depths  below 100 feet
 (30ra) where they constitute  what  is referred  to in  Figure
 4  as the  "deep aquifer  zone".   The zone constitutes  the
 only productive aquifer in the area.  It is  encountered at
 depths  of 80 to 100  feet  (24  to  30m) several miles east of
 the study area but deepens to below 180  feet  (55m)  in the
 vicinty of the site.

      This sand layer in turn  overlies  an older bay deposit
 which consists of stiff,  silty clay.   Bedrock is estimated
 to underlie the  site  at depths of  about  300  feet (91ra).

      As  shown in Figure 4 most of  the aquifer material  is
 overlain by thick, tight  clay zones which  serve  as  aqui-
 cludes  to confine these aquifers under  artesian pressure.
 The  groundwater  in  the  area is  replenished  mainly  from
 percolation  of streamflow  in high  areas  considerably  east
 of the  project  area  where  aquifers  are   not  capped  by
 impermeable  clays  and can  receive surface water  infil-
 tration.   The  groundwater flows  from these  recharge  areas
 towards  the  Bay.   At  the  RSS site, groundwater  flow is  in
 a  westerly  direction  towards the  Bay but  the  hydraulic
 gradient   is  nearly  flat  and  the  rate of  groundwater
 movement  is  very slow.  Also, the  highly impermeable bay
 mud  and  deeper clay deposits inhibit  or greatly  minimize
 lateral groundwater migration.

     The  capacity of   the  "deep  aquifer  zone"  and  the
 shallower  sand  lenses  is  rather  limited  since  the  zones
 are generally only a few feet thick and are  discontinuous.
Although well  yields  of 300  to  350 gallons  (1136 - 1325
 liters)   per  minute have been  reported,  the  majority pump
much less.  Some wells which penetrate the most productive
aquifer zone have a maximum yield  of less than 50 gallons
(189 liters) per minute.
                                     20-7
-------
N)
O
I
CO
            Figure 4.  Geological  Cross-Section of  the  Area around the  Richmond Sanitary

                                               Services  Site
-------
      Water  levels  in  both   shallow  and  deep  wells  are
 generally  quite  shallow where not  influenced  by pumping.
 However,  pumping records  show drastic drawdowns  in many
 cases and specific capacities are commonly only  1 to 2 gpm
 of yield per foot (1.2 - 2.3  liter per minute of yield per
 meter) of drawdown.

      Groundwater usage within the entire groundwater basin
 is  very  limited.  There  are  no existing drinking water
 wells  in the  entire basin.   In the locality of the site,
 aquifer  zones   Located  at depths of 50 to 100  feet (15 -
 30ra)  are  known  to  be  brackish  and  unsuitable  for  most
 uses.
 300.68(e)(2)(i)
 (A)
 population at
 risk
 WASTE DISPOSAL HISTORY

      The disposal  practices  at  the Richmond  site  evolved
 over a  20  to 25 year period  from  haphazard,  unregulated,
 dumping  to  carefully  regulated and  monitored  disposal.
 This evolution  paralleled  the evolution  of  the State,  and
 to  a   lesser  extent ,   the   Federal   hazardous   waste
 regulations.

      Richmond Sanitary  Service  began  acquiring the  land
 currently used as a Class  I and Class  II disposal  site in
 the early 1950's.  In December of  1952,  RSS was granted  a
 land use permit  by Contra  Costa County for  operation of  a
 sanitary landfill.   This  permit,  and  a  subsequent  permit
 issued  in 1960,   placed minimal  operational  conditions  for
 the handling  of  solid  wastes,  and  handling of  hazardous
 wastes  was  not addressed at all.  As a result,  throughout
 the  50's  and  most  of   the  60's  RSS   indiscriminately
 accepted hazardous  wastes and  took  little   or  no pre-
 cautions to  protect  public health,  safety  of  the  workers
 or   the   environment.  Drums   of  wastes  were often  broken
 open,  exposing  workers  and the  public  to  flammable  and
 toxic wastes.   Incompatible wastes  were  not separated  and
 volatile, toxic  liquids were dumped  indiscriminately.   One
 of  the  few measures taken at  the  site during  the  1950' s
 was  to construct  a  perimeter dike around  much of  the  site.

      In  1964,  the Regional Water  Pollution  Control  Board
 (predecessor of  the present Regional Water Quality Control
 Board)  issued a resolution  requiring  that disposal  of
 solid municipal  wastes and industrial wastes be done in  a
manner that is not detrimental to the state's waters.  The
Board  established  a self-monitoring  program  for RSS and
ordered that   they construct a dike to prevent wastes from
leaching  into  the Bay.  However,  the resolution did not
establish  any  operational   requirement   for  handling
hazardous materials.
 300.68(e)(2)(i)
 (c)
 hazardous
 properties
300.70(B)(ii)(B)
(i)
dikes and berras
                                     20-9
-------
     The  1970* s  marked   the  beginning  of  an  increased
awareness by the  County  and State of the problems  at  the
Richmond  Site.   During   1970  about  1    x  10   gallons
(3.8  x 10  1)   of  hazardous  wastes  and   approximately
120,000  tons  (109,000 MX) of  non-hazardous  wastes were
discharged  at   the  site.  In 1971, the  RWQCB was granted
authority  to  establish  specifications   for  solid waste
disposal sites,  including design  and  construction  of
any  measures  needed  to protect state waters.  The RWQCB
ordered that  the suitability  of areas  used for disposal
of   Class  I  wastes   be   determined   based   on  soil
engineering,    hydrologic    and  hydrogeologic  studies.
Richmond  Sanitary Service's consultants, Cooper-Clark and
Associates,  conducted  these  studies  and  made  several
recommendations  for upgrading  the  site.    In  1973,  the
RWQCB  issued an order to RSS which  incorporated Cooper-
Clark's  recommended site  improvements  and  identified  a
Class  I  area for  disposal of  hazardous wastes and a Class
II  area  for solid municipal wastes.   Because RSS encoun-
tered  unanticipated  problems  in meeting  the requirements
of various governmental agencies, the Class I facility was
not upgraded at that time.

     The  RWQCB  was,  however,  investigating  the  site on a
routine  basis  at  this time.   Several violations  of the
Board's  order were  documented.   The  most  frequent viola-
tion was the deposition  of hazardous wastes in the Class
II  area.

     The  state  Department  of  Health (DoH)  also investi-
gated  the site  during  the early 1970's and expressed con-
cern over lack  of precautions  taken  to  ensure  protection
of  workers  and  the  public.  Drums were still  being dis-
posed  of  haphazardly,  incompatible wastes were   not  sepa-
rated  and volatile  liquids  were dumped indiscriminately.
However   until  the   passage  of the  California  Industrial
Waste  Act of 1972,  neither the RWQCB or  the Department of
Health had the  authority to control  operational  aspects
needed to protect public health and the  environment.  The
Industrial  Waste  Act required the Department of Health to
develop  a hazardous  waste control program by 1974.

     In  1975, RSS submitted an  engineering master plan  for
the site  which  proposed a  much  expanded Class  I area
enclosed by a bay mud  subsurface barier.  During 1975,  the
Department  of Health,  the RWQCB and  the  RSS  site operators
and their consultants,  Cooper-Clark and Associates,  met
on  several  occasions to  discuss needed improvements at  the
site.    Although there  was  general  agreement  among  the
involved  parties   regarding  the  need for design and
operational improvements,  RWQCB  rejected  the  expansion
300.68(e)(2)(i)
(B)
amount and form
of substances
present

300.68(f)
remedial
investigation
300.68 (g)
development of
alternatives
300.68(e)(2)(i)
(0
hazardous
properties
                                      20-10
-------
 plan.    They  ordered   RSS   to  construct   the   subsurface
 barrier,   perimeter dike  and  retention basin.  The Class I
 disposal   area was  upgraded  between  1975 and 1978 to meet
 the  requirements  set forth by the RWQCB and the  DoH.
 DESCRIPTION  OF  SITE  INVESTIGATION

      As  part of  the  RWQCB1s  requirements  that  Richmond
 Sanitary  Service  institute  a  self-monitoring  program to
 determine  the acceptability of the site  for handling Class
 I   wastes, Cooper-Clark and  Associates, under contract to
 RSS,   conducted   detailed  soil  engineering  and hydro-
 geologic   investigations of the site during 1971 and 1974.
 These investigations  included the following activities:

      •  Exploration of soil and ground water conditions in
        the  existing  and proposed Class  I  areas  to depths
        that could potentially be affected by wastes

      •  Evaluation of  physical characteristics  of soil by
        laboratory testing

      •  Determination of potential reaction of wastes with
        bay mud.

      Soil borings were drilled at 100  foot (30  m)  centers
 to  depths  ranging  from 3 to  60  feet  (1 - 18m) using truck
 mounted, 5 inch  (12.7  cm)  diameter  rotary-wash  equipment.
 Undisturbed soil samples were  taken  using split-tube
 barrel  samplers  for  visual  inspections  and  laboratory
 testing.

      Borings taken  around  the perimeter of  the  existing
 Class I pond encountered about 3  to  13 feet  (0.9  - 4.0 m)
 of  loose,  permeable  refuse.   In  one area  5.5  feet  (1.7m)
 of  chemical  waste  was encountered.   The  fills were
 directly underlain by bay  mud containing  varying  amounts
 of  sand lenses and peat.   In contrast, very  little  refuse
was  encountered  around  what  is  now  the  barrel  storage
 area, and the bay mud was relatively  free of  sand  deposits
 at  shallow depths.  Groundwater was  encountered within or
above the  fill  in the existing  filled area  and near  the
ground surface  in areas which remained  unfilled.

     Next,  a  series  of  soil   engineering  tests were
performed on  the bay mud and on the  sand lenses.   Testing
 included:

     o  Permeability  of natural  bay mud  deposits and com-
        pacted  bay mud materials.   Natural  bay  mud  was
        found to  have a  coefficient  of permeability  of

                                     20-11
300.68(c)
state or federal
evaluation of
clean-up
proposals
300.68(f)
remedial
investigations
-------
        10~^  to  10   cm/sec.    Bay  mud  compacted  to  80
        percent  of maximum  compaccion  at proper  moisture
        content  consistently  had  a   permeability  of
        10   cm/sec.

     •  Determination of strength  characteristics of  bay
        mud using a  portable Torvane Torsional  Vane  Shear
        test  at  natural moisture  content.    To  aid  in
        correlating  the  engineering  properties  of  soil,
        moisture  content   and  dry  density tests   were
        performed on  all  undisturbed  samples.

     •  Grain size distribution tests  on selected  sandy
        soils.

     Based on the results of field  exploration and labora-
tory  testing Cooper-Clark  concluded  that the bay mud was
sufficiently   impermeable to  prevent  leaching  into  the
underlying ground  water  but that  lateral  seepage  through
the existing  fill and sand  lenses was a possiblity.

     Although  the  permeability  of   the   bay  mud  was
extremely low, there was some  concern over  the  potential
for changes  in  permeability due to  reactions with  highly
acidic or basic Class I wastes.   The  results  of laboratory
tests on bay  mud  samples  saturated  with a pH solution of 2
and 10 showed no changes in consolidation or permeability
characteristics.   No such  laboratory tests were conducted
to  determine  changes  in   consolidation  or  permeability
characteristics  as  a   result   of  exposure  to  organics.
However, samples  of bay mud from the  existing Class I area
which had  been in contact  with various  waste  types were
tested, and showed no apparent  change in permeability.
PLANNING THE SITE RESPONSE

Initiation _of_ Response

     In March 1976, the RWQCB ordered RSS to implement the
site  improvements  in  order  to  bring  the  facility  into
compliance with new hazardous  waste  disposal regulations.
While  no  single  incident  triggered  the  order,  the RWQCB
concluded  that  the site  posed a  threat  to  state  waters
based on observations by state officials over the previous
five  years of  numerous  problems  with  the RSS  facility
design and operations.  The order came after six months of
negotiations between  the  RWQCB and RSS,  during  which RSS
submitted  proposals  to greatly  expand  the Class  I  area
pinto  adjacent  marshland  and  to  construct  a  bay  mud
barrier enclosing the new Class I area.
                                     20-12
-------
      The RWQCB  rejected  the expansion  plans because  RSS
 and^the U.S. Army Corps of Engineers were then engaged  in
 a dispute over the legitimacy of RSS1 claim  to title over
 the marshland.   The  RWQCB  instead ordered  RSS to  construct
 the proposed barrier  only  around  the existing 15-acre  (6
 ha) Class I area and  an adjacent 5  acres (2 ha),  which  was
 to concain a retention basin for rainfall runoff from  the
 Class I  area  and  overflow from the  Class I  pond  in  the
 event of a  dike  failure.  Figure 5  shows the  layout of  the
 Class I area.   The order to build  the barrier was part  of
 a larger effort  from  1975 to  1978 by  the RWQCB and the  DoH
 to improve  the  design and  operation of both the Class I
 and Class II areas at  the RSS site.

 Selection of Response  Technologies

      Based   on   detailed  hydrologic,  hydrogeologic,   and
 soil  engineering  studies   performed  by Cooper-Clark  and
 Associates   it  became  apparent  that,   although  the   low
 permeability  of  bay   mud  prevented  vertical  migration
 into  underlying ground  water,  there was  a  potential  for
 lateral  migration  into surface waters through  existing
 refuse  or sand  lenses.  These  studies  also   indicated  the
 potential for  releases  of hazardous chemicals in the event
 of flooding or seismic activity.   Based  on  these studies
 and  subsequent  discussions   with   Cooper-Clark   and
 Associates,  the  RWQCB  ordered  RSS  to  implement  the
 following improvements:

      •   Construction   of  an  underground,  impermeable
         barrier which was to be keyed into the impermeable
         bay  mud

      •   Construction  of a  perimeter dike  surrounding  the
         Class I area to prevent flooding

     •   Construction and maintenance  of  a  retention  basin
        with adequate  capacity  to   contain maximum  runoff
         plus maximum  volume  of  liquid which  would  escape
         the Class I pond in event of a dike failure

     •   Installation of monitoring  wells

     •  Raising the interior  dike around the  Class I  pond
        to  provide sufficient  elevation and  slope  to
        ensure  stability in the  event of seismic  activity.

      Inspections made by  the Air Pollution  Control
District  and the  DoH  throughout• the early and mid-1970's
and complaints  from area residents of odors indicated  that
severe potential  hazards still existed at the  site.  These
included disposal of  extremely hazardous  chemicals, mixing

                                     20-13
-------
to

O
                                                                   LIQUID WASTE
                                                                             CLASS I DISPOSAL AREA
                                                                              J ijttiJLJ  *• «j **-*-«•— ' ' ^-


                                                                              RICHMOND SANITARY  SERVICE
                                                                              ^l^jfll'ivnf «<*••*- --


                                                                              RICHMOND,  CALIFORNIA
                                                                              Subsurface  barrier

                                                                                and dike  .
                                                                                           ,,
                                                                              Monitoring wells .  .  .  •



                                                                              Settlement markers  .  .  ."L-l1
                      Figure  5.   Layout of the  Class  I  Disposal Area
-------
 of  incompatible  wastes,  haphazard disposal  of  drums such
 that drums ruptured and leaked and lack of adequate safety
 precautions in handling wastes.

      In November 1976, after the DoH1s 1975 recommendation
 for operational improvements had not been implemented, the
 Department threatened issuance of a cease and desist order
 unless   RSS  made  certain  operational  improvements.
 Richmond  Sanitary  Service   initiated  these  improvements
 shortly  thereafter,  including separation  of  incompatible
 wastes  in  the  barrel storage  area  and safer handling  of
 drums and liquid wastes.

 Extent of Response

      The RWQCB specified  in  its order to RSS that the sub-
 surface barrier be at least  5 feet (1.5 m)_wide  and have a
 permeability of  not  greater  than  1  x  10   cm/sec.   The
 depth  of  the  trench excavated   for  the  barrier  was  to
 extend at  least two feet  (0.6 ra)  into the underlying layer
 of bay  mud.   The order  further  required that  the  2-foot
 (0.6 m)  high  dike surrounding  the  Class  I  area be  com-
 pacted  sufficiently  to  meet  the 1  x  10~8 cm/sec  perme-
 ability standard,  that  the  retention basin be  of  a
 sufficient  volume to  contain any liquid  waste  release  in
 the  event  of a failure in the Class  I  pond dike, and  that
 ten  monitoring wells  be  installed  at  equal  intervals  in
 the  barrier.   The  RWQCB based  the  design  criteria  on
 facility  standards   set  forth  in   State hazardous  waste
 facility  regulations.  Since  the   site  rested  on  a  50  to
 150   foot   (15   to _46 m)  thick   layer  of bay  mud with  a
 permeability   of  10    cm/sec.,   forming an effective  aqui-
 clude  between  the  Class I  wastes and  the nearest  useable
 ground  water,   State  officials believed  that  the  barrier
 would  sufficiently mitigate  the  threat  to  State  waters.

     The order  listed other operational improvements,
 requiring that  two feet (0.6  ra) of freeboard be  maintained
 in the  liquid  waste  pond,  that each layer of buried drums
 be covered with at  least  1  foot (.3 ra) of compacted soil,
 that the height of the drum burial area not exceed 43  feet
 (13 m)  feet  above  sea  level, and that the retention basin
 not be used for waste disposal.
300.68U)
extent of remedy
300.68(e)(2)
(v)
state approach
to similar
situations
DESIGN AND EXECUTION OF SITE RESPONSE

     The  response  activities  designed to  prevent  surface
water  contamination  and  to  minimize  the  risk  to  public
health and worker safety were implemented between 1976 and
1978.   The  activities  were conducted  and funded by RSS
                                     20-15
-------
under the  supervision  of  the RWQCB and the Department  of
Health.

Construction of Impermeable Barrier, Perimeter Dike and
Retention Basin

     In  order  to  protect  adjacent  surface  waters  from
pollution caused  by  lateral  or  vertical  seepage,  an
impermeable,  underground  barrier  was constructed  around
the  perimeter  of  the  Class I  area,  and the  area  was
enclosed  with  a  dike  to  protect against  flooding  and
ensure  containment of runoff.    Both the  underground
barrier and the perimeter dike were constructed  using bay
mud  excavated  from  the   site.    The  inherently  low
permeability  and  ready availability  made  the bay  mud  an
excellent choice for the barrier material.

     RSS  began construction of  the  site  improvements  on
September  14,  1976  and  completed most  of  the  work  by
October 30,   1976  in  accordance with  plans and specifi-
cations  developed  by  the  RWQCB  and  Cooper-Clark  and
Associates.   The  specifications   required that the under-
ground  impervious  key  was  to  be  a  minimum of 5 feet
(1.5 m) wide  and extend a minimum of 2 feet (0.6 m) below
the  refuse material where it was keyed into the underlying
bay mud.   Where sand lenses  were encountered within 5 feet
(1.5  m)  of the bottom of the fill,  the trench  was to be
excavated  through  the  sand  and  2  to 3  feet  (0.6  -  1 ^m)
into  the underlying mud.    The  newly constructed barrier
was  also to  be keyed  into  those  portions  of the barrier
which  had been constructed during previous  years.   The
"old" barrier had been constructed along the northeast and
south boundaries of  the Class I Pond  and along the western
perimeter  of  what  was later to  be  the  retention basin.
The  new barrier was 2,765  feet  (843  m)  long, and the old
barrier  was  2,100  feet (640  m)  long.

      The  trench was  excavated  using a hopto,  which is  a
 large,  track-mounted  backhoe.    Although   the  trench  was
 required  to  be only  5 feet (1.5 m) wide,  it  sometimes
 reached  8  to  10  feet (2.4 -  3.0  m)  wide   in  areas  of
heterogeneous refuse fill.   During excavation,  the backhoe
 encountered  a considerable amount  of refuse  as well  as
demolition  debris,  chemical  waste and  drums.   These
materials were removed from the  trench and disposed  of  in
 the Class II area.   At one point during  trench excavation,
 flammable liquids were encountered and the  trench caught
 on fire.  No safety equipment was worn by field personnel
 despite the  fact  that  hazardous  materials  were  encoun-
 tered.   Because of the  considerable  thickness of  refuse
 and sand lenses  encountered, it was necessary to excavate
 the trench  to depths  of 20 to  30 feet  (6 - 9  m)  in some
(300.70(b)(l)
(iii)U)
impermeable
barriers
 300.71
 worker health
 and safety
                                      20-16
-------
 areas.   The  backhoe had  a reach  of  only about  20 feet
 (6.1 m).   Consequently,  it  was  sometimes necessary to use
 a track-type dozer to excavate about 10 feet (3.0 m) below
 grade  adjacent  to  the  trench  to  serve  as   a  temporary
 working area  for the backhoe so it could  excavate to the
 required depths.

      Inflow of water into the trenches was another problem
 encountered during  excavation.    Inflow was  particularly
 rapid  in areas  of more permeable refuse fill, and in the
 area of the Class I  pond  due to  seepage of liquid wastes.
 However,   the  need  for  dewatering  was  eliminated  by
 excavating and  backfilling  in about 30  linear foot  (9  m)
 segments,  avoiding  long  lengths  of  unsupported  open
 trench.

      A dragline was  used  to  excavate the bay  mud used for
 backfill from  an area southeast  of the retention basin.
 In  some areas   sand   lenses  were  encountered  and  this
 material,  unsuitable for  backfilling, was  discarded.   The
 bay mud  was  dumped   into trucks  from   the  dragline  and
 hauled  to  the  work  area  where  it  was dumped  into  the
 trench.  Dozers  were also occasionally  used  to push  the
 mud  into the  trench.

      It was necessary  to closely coordinate  the  rate  of
 trench  excavation and  backfilling.    If  the excavation
 proceeded  too  far ahead of backfilling  there was  likely  to
 be  considerable   inflow   of  water  into  the  trench and
 dewatering  would  be  needed.   if,  on  the  other  hand,
 hauling of the bay mud for backfilling proceeded  too far
 ahead  of excavation,  the  material would be unsuitable  for
 backfilling because   it was  required  that it be  dumped  at
 its  natural moisture  content  without  letting it dry.

     As requested by RWQCB,  Cooper-Clark took  undisturbed
 samples from  the completed barrier  at  less than  500  foot
 (150 m)  intervals for  permeability testing.    Both the
 "new"   and  existing   barriers had  permeabilities  on the
 order of 10   cm/sec  in compliance with  the RWQCB1s order.

     Following  completion of the key, RSS began  construe-    300.70(b)(l)(B)
 tion of  the  above ground perimeter dike.  The  perimeter    (B)(l)
 dike was   constructed  to  a height of about 2 feet  (0.6 m)    dikes and berms
 above ground  level which  was considered adequate to pre-
 vent Class  I area runoff  from entering  the  Class  II area.
 The  completed dike area was 4,900 feet (1494 m) long.

     Again, bay mud  was  hauled  in  trucks  from  the  area
 southeast of the  retention basin.  Large track-type bull-
dozers were used to roughly shape the slopes of the dikes.
 Smaller bulldozers, equipped  with extra  wide  tracks,  were

                                     20-17
-------
used  for  polishing and finishing the slopes.  The reten-
tion  basin  was  also  graded  and finished  using mainly
the  larger  bulldozers  for  shaping  and  grading  and a
smaller  bulldozer  for  final  polishing.   The  dike  was
compacted  to  at  least  80  percent  of maximum  density in
order to attain  the  required  permeability of  10   cm/sec.
In  order  to ensure the adequacy  of  the  dikes,  laboratory
permeability tests were performed on samples taken at less
than  500  foot  (150  m)  intervals.   Permeabilities  on the
order of  10~8 cm/sec were  achieved consistently.   Field
density  tests  were  performed   at  intervals of less than
500 feet (150 m)  according  to ASTM Test Procedure D1557-70
to  ensure  that  the bay mud was  compacted to  the required
80  percent.

Installation of Monitoring  Wells

      In  July  1977,  Cooper-Clark  installed ten monitoring
wells at  equal  distances  within the containment structure
enclosing  the Class  I areas.   The wells were drilled with
a   truck-mounted  7  inch  (17.8cm)  diameter,  rotary wash
drill rig approximately  along  the centerline  of the
containment  structure.    The  wells  extended  through  the
existing  bay  mud key and at  least 1 foot  (0.3m)  into  the
natural bay mud.   The depth of  the wells ranged  from 10  to
13.5  feet  (3.0  - 4.1m).   It was essential for Cooper-Clark
to install the  wells within  the barrier  so that  wastes
which had been  disposed  of outside  of  the barrier  limits
during  the 1960's and  early  1970's  would not be  detected
during monitoring.

      After drilling each  well,  a  4 inch  (10.2cm) diameter,
perforated PVC  pipe  surrounded by at least 1 inch (2.5cm)
of filter material  consisting of 1 inch  (2.5cm)  maximum
size  pea  gravel  was installed.   A  cap was  provided  for
each  pipe, and  the top 2  feet  (0.6m)  of  backfill  around
the  pipe   consisted  of  impermeable bay mud  to  prevent
surface  water infiltration  into the  well.  These wells are
monitored quarterly  by EMCON Associates  and the  data is
 submitted to  the RWQCB.

Class I  Pond

      During late  1976 and   early  1977,  the  9 acre (3.6
hectare) Class  I  liquid pond came under critical examina-
 tion by the RWQCB,  the DoH and  the Air  Pollution Control
 District.  The  pond  was  filling  up  and  the 2 foot (0.6 m)
 freeboard  limit  placed on it  by the RWQCB  was exceeded.
 On January 4,  1977,  the  RWQCB ordered  RSS to stop placing
 waste in  the pond.
                                      20-18
-------
     The  reason  the pond exceeded  it's freeboard limit was
 apparent.   Prior  to  installation  of  the underground
 barrier,  the pond acted as an  infiltration basin, allowing
 the  liquid  wastes  to  seep  into the old underlying refuse.
 Construction  of  the  barrier  in  October   1976  severely
 restricted  further  infiltration.   Also a persistent  layer
 of  2 to  5  inches  (5-13 cm) of oil  on the  pond prevented
 the  liquid  from  evaporating.

     In order to meet  the  requirements for   a minimum  of
 2  feet  (0.6m) of freeboard,  it was necessary to raise the
 crest  of  the perimeter  dike  to  an elevation  of  21 feet
 (6.4m).   The  RWQCB  granted  permission   to  raise the
 elevation provided  the following stipulations were met:

     o  The  permeability  of  the   dike  was  not  to   exceed
        10   cm/sec

     o  The crest width was to be  at least 5 feet (1.5 m)

     o  Inboard  and outboard slopes could  not  be steeper
        than 3:1 (horizontal  to vertical)  to assure  slope
        stability in the event of  seismic activity.

     The  crest  of  the dike surrounding  the  pond  was ele-
 vated  using procedures  similar  to those  used  for con-
 structing the perimeter dike.  The same  types of large and
 small bulldozers were again  used  to  shape,  compact, and
 polish the dike.

     Following completion of  the dike,  the  RWQCB required
 that permanent settlement bench marks and liquid gauges be
 installed at equidistant intervals around the perimeter of
 the  pond.  The  settlement  bench  marks  consisted  of nine
 capped steel pipes  driven  into  the top of the dike at 200
 foot  (61  m)  intervals.   The  liquid gauges  consisted  of
 four welded steel staff gauges which were installed  at 400
 foot (120 m) intervals.  The  top   of  the gauges were set
 at elevation 21  feet  (6.0 m)  to allow  a direct reading of
 the pond  freeboard relative to the top of the dike.

Loading Rate Determinations

     Elevating the  crest of  the dikes to 21  feet  (6.4  m)
was not sufficient justification for reopening the Class I
pond.  The  RWQCB required  that  RSS conduct  an evaporation
rate study  in  order to determine  the  liquid  loading rate
which  could safely be  accepted.    They  also  required
documentation that  the retention  basin located  south  of
the barrel storage area had sufficient  storage capacity to
contain runoff  and  any conceivable discharge from the pond
in the event of a failure  of the perimeter dike.

                                     20-19
-------
     Initially the  engineering  firm of Kister,  Savio  and
Rei,  Inc.  submitted  an  evaporation study  in which  they
estimated that 730,000 gallons (2.8 x 106 D of liquid  per
month  evaporated  from  the   pond.    However, _the  RWQCB
considered this  loading  rate to  be very optimistic.   It
assumed that  the  evaporation  rate from the pond  would  be
equivalent to  pure water.  This  assumption was  not  true
since,  as  the  salt  concentrations  increased within  the
pond, surface tension increased  and evaporation decreased.
Also  the  industrial discharge  to the pond typically
contained  substantial  amounts  of   floatable  oils  which
effectively prevented evaporation from the surface.

     The  RWQCB  therefore  recommended that  the actual
evaporation rates be  monitored.   Gal Recovery System Inc.
made  actual measurements  of the evaporation rates between
December 1977  and May 1978.   Based  on  these  studies they
concluded  that  an acceptable  loading  rate   was  500,000
gallons  (1.9  x 10  1) per  month, provided that  the pond
was  cleaned periodically  and  that the  rate  be adjusted to
reflect any unusual conditions such as very heavy rains or
excessive oil  and  debris.  This  loading rate  met with the
approval of  the  RWQCB provided  the  2  foot  (0.6m) minimum
freeboard was maintained.

      The  next task was to  determine the  adequacy of the
retention basin tocontain Class I liquids in the even of a
dike  failure  around  the Class  I pond.   To  answer  this
question,  it  was  necessary to  define  a conceivable dike
failure.   Due to  the  configuration of  the adjacent ground
surface, Cooper-Clark determined  that  there was no possi-
bility  of  failure  to  the north, west, and most of the east
of  the  perimeter dike.    However,  in  the  event of  the
maximum credible  earthquake  along  the  San  Andreas Fault,
there was  the possibility  of lateral  movement  along the
southern  perimeter  of  the  pond  but   not  complete  dike
failure.

      Cooper-Clark determined  the  stability of  these slopes
in  the  event of seismic  activity using  the  "SHAKE  2"
computer  model made  available  through  the  University of
California  at Berkeley and was  later  confirmed using the
results of the more complete  "LUSH"  program.

      Assuming the most severe  set  of  circumstances; that
is  a maximum  lateral movement  of  the  southern  perimeter
dike  and maximum  runoff  resulting from  a 100-year  storm of
24  hour duration,  Cooper-Clark  determined  that  the
retention  basin  would  be filled only 61  percent of its
capacity or  3.6  x 106 gallons (13.6 x 106 1) .  Therefore,
the  capacity  of  the retention  basin was considered
adequate.

                                     20-20
-------
 Implementation of Waste Management Practices for the Class
 I Evaporation Pond and Retention Basin

      Following completion  of  these remedial measures  and
 studies for the Class I Pond, the  pond was  reopened.   The
 RWQCB  stipulated   that  RSS  could  accept   up  to  500,000
 gallons (1.9  x 10   1)  per  month  (provided a  minimum 2  foot
 freeboard was  maintained)  of Class  I liquid wastes  with
 the  exception of  pesticides,  paint  sludges,   solvents,
 tetraethyl  lead sludge and oil, which cannot be  accepted.
 The pH of  the  pond  is now maintained near  neutrality  due
 to a balance  of caustic  and acid wastes.

      In order  to  insure  a minimum  freeboard  of two  feet
 and  to optimize  evaporation,  the pond  is periodically
 skimmed to  remove oils and animal fats  which rise  to  the
 surface as  a  result  of their disposal  in  the 1950's  and
 1960's.  Skimming  is  only  required infrequently  when about
 20% of the pond  is covered with  oil.   The  oil  is  pumped
 into a small  adjacent  pond  and is  later  sold for  fuel.

      Finally  the liquid level in  the  retention basin must
 be  maintained  such  that   sufficient  capacity  exists   to
 store liquids  from the Class  I pond in the event  of  a dike
 failure.   In  order to  ensure  this capacity, rainwater  is
 periodically  pumped from the  retention  basin directly  to
 the  San  Pablo  Sewage  Treatment  Plant  for treatment .
 Richmond  Sanitary  Service has  an agreement with  the  treat-
 ment plant  whereby the  landfill  accepts  secondary sewerage
 sludge  from  the  treatment  plant  in  exchange   for free
 treatment of  the retention basin  effluent.   The effluent
 from the  retention basin  can  be discharged  directly into
 the  bay if  it  meets minimum discharge  requirements.

 Implementation  of  Remedial  Measures  and Waste Management
 Practices for  the  Barrel Storage Area

      In 1976,  both the RWQCB  and  the DoH issued require-
ments   for  upgrading  the   barrel  storage area. The  RWQCB
 required  that  RSS submit  a   slope  stability analysis for
analysis  for   the slopes   around  the  barrel storage area
specifying  the maximum  slope   and  height  of fill which
could  be  developed without exceeding 80 percent  of  the
shear  strength  of  the  underlying material.    Slope
stability was  determined  using  the  previously  mentioned
 SHAKE  2" and  "LUSH"  methods  of  analysis and assuming the
maximum credible earthquake along adjacent portions of the
San  Andreas Fault.  Based  upon this analysis Cooper-Clark
concluded that  the  maximum allowable  slope  should  be  8:1
except  for  the  easterly slope  adjacent to the Class  I
pond,  which should not be  steeper  than  4:1.    The  RWQCB
also  required  that the  barrel  storage  area not have  an

                                     20-21
-------
elevation greater than 43 feet (13m)  above mean  sea level
to further assure slope stability.

     During the  later  months  of  1976 and early  1977,  RSS
instituted numerous operational  improvements for  the
barrel storage area  as  required  by the DoH.   Bay mud  and
other clays were used to  construct four separate  barrel
disposal  cells  for  each  of  the  following  categories  of
waste:

     •  Acids
     •  Alkalies and cyanides

     •  Strong oxidizers
     •  Pesticides, solvents and  organic chemicals.

The cells  were  separated  with a  minimum of 5  feet (1.6m)
of clay or bay mud.

     Special  equipment was  purchased so that  drums could
be  unloaded   and  disposed  of without  damage.    Equipment
operators  were   required  to  wear  respirators  and  safety
shields  were  installed on  the  front  of drum unloaders.

     In  February  1980, DOH ordered implementation  of
additional measures  to upgrade  the barrel  storage area.
These measures included:

     •  Bury  the  containers  with a  volume   of  soil
        sufficient to absorb  the total volume of  liquid in
        the drum.

     •  Completely cover  the  drums with earth at the  end
        of the day

     •  provide  a minimum  of 1  foot (0.3m)  of   compacted
        soil  prior to  starting the  next layer.

Rather  than meet these requirements, RSS stopped  accepting
drums  containing more than 10 percent  liquids.   .They are
currently accepting  bulk  or containerized   contaminated
soils  or solids.  A closure plan  has  been  developed  for
the barrel storage area.
 COST AND  FUNDING

 Source of _Fujid_iLng_

      Richmond   Sanitary   Service paid   for construction of
 the site  improvements  out of  its operating budget.


                                     20-22
-------
 Selection of Contractors

      Since  RSS  used  its  own  equipment, operators,  and    300.68(c)
 materials  to  implement  the  site  improvements, no con-    responsible
 tractor  selection  process  occurred.   Richmond  Sanitary    party
 Service  hired  Cooper-Clark  and  Associates, a  foundation
 engineering  firm,  to  design  the  site  improvements  and
 oversee  their  construction.    Richmond  Sanitary  Service
 based  its  selection  on  Cooper-Clark's  longstanding
 business  relationship with  RSS  and  their  familiarity with
 the site.

 Project Costs

      While RSS  made  a  number of  site  improvements  from
 1976 to 1978,  this  cost  analysis focuses  only on the  major
 actions:   the  barrier,  the  perimeter  dike,  and  the
 retention  basin.    Because  RSS primarily  used  its  own
 workers and equipment for  the  project,  invoices  were  not
 available with  which  to calculate the precise cost of  the
 work.   Operators and  earth-moving equipment  were  borrowed
 as  needed  from  the  daily  landfill  operations.   Conse-
 quently,  an estimate  of the cost of implementing  the  site
 improvements  was based  on  standard rates  for contracting
 similar labor and  equipment multiplied  by  the  number  of
 days and  hours  spent  on  the  project.  Since  all  of the  bay
 mud used  for the  site  improvements was  taken  from  other
 areas  of  the  landfill,  the  only material  costs were  for
 monitoring  wells.

     While  the work occurred in  1976, 1983  rates were used
 to estimate the  cost  of  the project,  in order to  make  the
 costs  more current.   It  is  important  to  note that  the
 estimated  costs  were  based  on  limited data, and may vary
 from the  actual  cost  by  as  much as 30%.   The  rates used
 were  taken  from  Mean's Building Construction Cost Data
 1983.   Most °f  the costs were  calculated  from  bare cost
 rates  for daily equipment  rental,  hourly operating cost,
 and  hourly  labor,  without  including overhead and profit.
 However,  since  RSS  hired  trucks  from  outside to haul mud,
 the  hauling estimate  includes overhead and profit, and was
calculated  on  a per-cubic-yard  basis.   A  summary of the
 cost is provided in Table 1.

     The total cost of constructing the 2,765-foot (843 ra)
 long  subsurface  barrier,  the 4,900-foot  (1,494 m)  long,
 two-foot  (0.6 m)  high compacted  mud dike,  and  the 5-acre
(2  ha) retention  basin  was  about  $111,000,   in  1983
dollars.   The bulk of  the  cost,  about  $77,000,  was  for
excavation  and  earth  moving.   The  remaining $34,000 was
for Cooper-Clark's engineering services.
                                     20-23
-------
          TABLE 1.  SUMMARY OF COST INFORMATION-RICHMOND SANITARY SERVICE, RICHMOND, CALIFORNIA
ro
o
i
Task
Constructing
subsurface
barrier
Constructing
dike, basin
Site investigation
and design
Installing
monitoring wells
Inspection
Oversight of
Construction
Total Cost
Quantity
7,313
cu.yds. „
(5,592m )


10 wells
30 days

Expenditure
(1983 dollars)
$56,118
$20,718
$15,000
$15,000
$4,200
$111,036
Unit Cost
$7.67/
cu. yd.
($10.03 m )


$1,5007
well
$140/day

Period of
Performance
9/14/76-
10/13/76
10/18/76-
11/9/76
1976
6/28/77-
7/7/77
9/14/76-
11/9/76
_
-------
Subsurface Barrier
     The  total  cost  of  buiLding  the  2,765-foot (843  m)
long  barrier,  excluding  engineering, was  $56,118,  or
$20.29 per linear foot ($66.56/m).   Since the depth  of the
trench  varied   from  5  to  30  feet  (1.5-9.1  m) ,  a  more
meaningful  unit measurement  of  the  cost   is  that  7,313
cubic yards  (5,592  m3)  of trench  fill  were  replaced  with
an equal  amount of bay mud,  at  a cost  of $7.67  per  cubic
yard  ($10.03/  ra ) of replaced  soil.   Excavation of  the
trench cost  $18,895  for  rental  and operation of  a  track-
mounted, diesel, hydraulic backhoe  and  a large  D-8  dozer.
Excavation of bay mud from a  borrow area elsewhere  in the
landfill  cost $11,043 for operation of  a dragline.   Haul-
ing  bay  mud  in dump trucks  to  the  trench, and  hauling
trench spoils to the Class II area  cost $26,180.   The cost
of  backfilling   the   trench  is   included in  the  hauling
figure since most of  the mud  was dumped directly into the
trench from trucks.

Dike and Retention Basin
     The  total  cost  of  building  the 4,900-foot  (1,494  ra)
long, two-foot  (0.6 m) high dike around the  Class I  area,
and  of  building the  5-acre  (2  ha)  retention basin,  was
$20,718.   Dragline  excavation  of bay  mud  cost  $2,734,
hauling cost $3,241,  and basin  excavation,  grading,  dike
construction  and  compaction  cost  $14,743,  using  small
dozers (D-6's and a JD-350)  and a loader.

Engineering
     The  total  cost  of  Cooper  and  Clark's  engineering
services  was  $34,000, including $15,000 for site  inves-
tigation and design of the site  improvements, $15,000  for
installing ten monitoring wells  in  the barrier,  and  $4,200
for inspection and oversight  during construciton.

Cost Components
     The construction costs listed  above are based on  the
following rates  for  rental  and  operation,  and  on  the
indicated amount of  time  each piece of equipment  was  used.

     (1)   Backhoe,  diesel hydraulic, crawler mounted,  1.5
          cubic   yard  (1.14  m3)  capacity;  17  days,  116
          hours; $10,883.   ($400/day rental, $15.80/hour
          operating  cost, $19.40/hour labor.)

     (2)   D-6 Caterpillar dozer, 140 h.p.;  20  days,  160
          hours:  $11,062,   ($295/day  rental, $13.30/hour
          operating  cost, $18.90/hour labor.)

     (3)   D-8 Caterpillar  dozer,  300   h.p.;  9  days,   48
          hours:  $8,012.   ($655/day rental, $25.20/hour
          operating  cost, $18.90/hour labor.)

                                     20-25
-------
     (4)  Dragline,   1.5  cubic  yard  (1.14  m )  capacity;
          9,124  cubic   yards  (6,916  in ) :     $13,777.
          ($1.51/cubic yard,  $1.97/  m )
                                        Q
     (5)  Hauling,  12-cubic yard (9.17 m ) dump trucks and
          1-mile (J..6 km)  round Crips;  9,124  cubic  yards
          (6,976 m3) bay mud, 7,313  cubic  yards (4,592 raJ)
          trench  spoils:    $29,421.    ($1.79/cubic  yard
          $2.34/m ), including overhead  and profit.)

     (6)  JD-350 dozer,  75  h.p.; 3 days, 234 hours:   $994.
          ($128/day  rental,   $6.50/hour  operating   cost,
          $18.90/hour labor.)

     (7)  Loader, tractor,  wheeled,  130 h.p.;  5 days,  40
          hours;  $2,697.   ($255/day rental,  $16.65/hr
          operating cost, $18.90/hour labor.)
PERFORMANCE EVALUATION

     Based  on  all  indications,   the  response  activities
undertaken  at Richmond  Sanitary  Service have  been effec-
tive  in  controlling  migration  of  contaminants  and  in
protecting public health and worker safety.   By installing
a  system of  dikes and an underground barrier composed of
bay mud, RSS  was able to take advantage of  the low perme-
ability  of the natural silty clays found beneath the site
to effectively  control  the  source  of contamination  at  a
relatively low cost.  The bay  mud barrier  and dikes were
such  logical  choices for the response technology that no
other technologies received serious consideration.

     Available monitoring data verifies the  performance of
the barrier.   As of  August  1982,  the results  of ground-
water monitoring have not detected any leakage of contami-
nants through the underground barrier.  Another indication
of the  effectiveness  of the barrier is  the  fact  that the
Class I  liquid waste  pond began to fill  up  rapidly after
the barrier wall was  completed.   Prior to construction of
the barrier, the  Class  I pond was acting as an infiltra-
tion basin  allowing liquid wastes  to  seep into the under-
lying  landfill.    The  barrier  has  restricted  further
infiltration.

     Also,  the  dikes  surrounding  the  Class I  area have
generally been effective in controlling  runoff and flood
waters.  However, in February of 1980, there was a failure
of  the  dike  surrounding  the retention  basin during  an
intense  rainstorm.   This  dike  was redesigned  and recon-
structed and no further problems have been reported.
                                     20-26
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     There  is  no  information on  the  volume  or  type  of
contaminants which  may  have  been dumped  outside  of the
underground  barrier  prior  to  its  construction  and  the
extent to  which  these contaminants may be  migrating into
San Pablo  Bay.   However,  the  potential for migration into
the Bay  has been greatly minimized  by construction  of a
second barrier around the entire perimeter of the 350 acre
(142  ha)  site.    This  barrier  was  required  to  have  a
maximum permeability of a 10   era/sec, as compared to 10
era/sec for  the Class I barrier.
                                     20-27
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                                 BIBLIOGRAPHY
Blasco, John C.   September 15,  1982.   Personal communication.   California
Department of Health Services,  Hazardous Waste Management Branch,  Berkeley,
California.

Bruhns, Will.  September 15,  1982.   Personal communication.   California
Department of Health Services,  Hazardous Waste Management Branch,  Berkeley,
California.

California Department of Health.  January 24, 1977.  "Summary of History of
the Richmond Class I Disposal Site."   Draft Report, Vector Control Section.
Berkeley, California.

California Department of Health.  1978.  "Hazardous Waste Facility Permit No.
07-0002-78, West Contra Costa County Sanitary Landfill, Richmond,  CA."
Berkeley, California.

California Regional Water Quality Control Board, San Francisco Bay Region.
March 16, 1976.   "Order No. 76-28-Waste Discharge Requirements for Richmond
Sanitary Service."    Oakland,  California.

California Department of Health.  1977.  "Richmond Sanitary Services Updates
Operations."  Berkeley, California.

California Regional Water Quality Control Board, San Francisco Bay Region.
July 19, 1977.  "Order No. 77-106-Order Requiring Richmond Sanitary Service to
Cease and Desist from Discharging Wastes in Violation of Requirments
Prescribed by California Regional Water Quality Control Board."  Oakland,
California.

California Regional Water Quality Control Board, San Francisco Bay Region.
September 18, 1979.  "Order No. 79-114.  Waste Discharge Requirements  for
Richmond Sanitary Services."  Oakland, California.

Cal Recovery Systems, Inc.  July 1978.  "Class I - Liquid Waste Pond
Evaporation Study."  Richmond, CA.

Cooper, R.S.  Cooper, Clark and Associates, Palo Alto, CA.  January 31,  1975.
"Progress Report:  Additional Soil Engineering Studies, Proposed Redesign  of
Class  IB and IP Areas."  Written Communication to Dana Murdock, Attorney at
Law, Walnut Creek, CA.
                                     20-28
-------
 Cooper,  R.S.   Cooper,  Clark  and  Associates,  Palo  Alto,  CA.   September  22,
 1975.   "Proposed  Master  Plan and Summary  of  Approved  Soil  Engineering,
 Geologic and  Hydrogeologic Design Criteria - Existing and  Proposed  Class  I
 Waste  Disposal Facilities."   Written  Coramunication  to Richard  Granzella,
 Richmond Sanitary Service.

 Cooper,  R.S.   Cooper,  Clark  and  Associates,  Palo  Alto,  CA.   November 1,  1976
 "Final Report Geotechnical Inspection and Testing Services.  Class  I
 Containment Barriers."  Written  Communication to  Richmond  Sanitary  Services.

 Dierker, F.H.   California Regional Water  Quality  Control Board,  Oakland,
 California.   January  11, 1977.   "Proposed Increase  in Elevation  of  Class  I
 Liquid Pond."  Written Communication  to R. Granzella,  Richmond Sanitary
 Service.
 Dierker,  F.H.   California  Regional Water Quality  Control  Board, Oakland,
 California.  January 26, 1977.  "Separation of Barreled Wastes at  IB Are
 Written Communication  to Richard Granzella, Richmond  Sanitary Service.
Dicker,  F.H.  California Regional Water Quality Control Board, Oakland, CA.
May  31,  1977.  Written Communicaton  to Richard Granzella, Richmond Sanitary
Service.

Dierker, F.H.  California Regional Water Quality Control Board, Oakland, CA.
September 27, 1977.  "Class I Liquid Waste Pond Evaporation Study."  Written
Communication to Richard Granzella,  Richmond Sanitary Services.

Franks,  Al.  January 5, 1977.  Re:   "Richmond Sanitary Service Liquid Waste
Pond."   Memo to Houssain Kajerai, California Regional Water Quality Control
Board, Oakland, California.

Franks,  Al.  September 16, 1982.  Personal communication.  California Regional
Water Quality Control Board.  Oakland, California.

Gaynor,  Robert.  September 27, 1976.  "Statement by Robert Gaynor, Field
Inspector, Bay Area Air Pollution Control District, San Francisco,
California.11  Richmond Sanitary Service Class I Disposal Operations, Public
Hearing  DN74-0-48.  U.S. Army Corps of Engineers, Oakland, California.

Goodson, F.L.  Resources Agency of California, Sacramento, CA.  Undated.
Written Communication to Colonel John Adsit, District Engineer, San Francisco
District.

Kolb, L.P.  July 17, 1978.   Re:  "Class I Liquid Waste Pond Evaporation
Study."  Written Communication to Richard Granzella, Richmond Sanitary
Service.

Means'  Building Construction Cost Data 1983.  Robert S.  Means Company, Inc.,
Kington, Massachusetts.
                                     20-29
-------
Nevin, R.L. and W.C. Ellis.   December 1971.  "Hydrologic and Hydrogeologic
Feasibility of the Richmond Sanitary Service Disposal Site."  Los Altos,
California.

Nuti, Caesar.  September, December, 1982.  Personal communications.  Richmond
Sanitary Service, Richmond,  California.

Nuti, Caesar., Richmond Sanitary Service.  February 24, 1977.  Re:
"Settlement and Liquid Gauges for Class I Pond."  Written Communication to
Houssain Kajemi, California Regional Quality Control Board, Oakland, CA.

Rei, M.P., Kister, Savio and Rei, Inc., EL Cerrito, CA.  March 18, 1977.
"Class I Liquid Pond."  Written Communication to Richard Granzella, Richmond
Sanitary Service.

Richmond Sanitary Services.   April 20, 1977.  "To All Producers and Haulers of
Class I Bulk Liquid Wastes."  Richmond, California.

Singer, Harold J.  September, 1982.  Personal communications.  California
Regional Water Quality Control Board, Oakland, California.

Tejima, T. and R.S. Cooper, Cooper, Clark and Associates, Palo Alto, CA.
December 28, 1971.  Report:   "Soil Engineering Studies - Existing and Proposed
Class I Disposal Areas."  Written Communication to Dan Murdock, Attorney at
Law, Walnut Creek, California.

Tejima, T.  Cooper, Clark and Associates, Palo Alto, CA.  February 7, 1977.
"Dynamic Analysis of Slope Stability under Seismic Conditions - Existing Class
II Waste Disposal Area..:  Written Communication to Richmond Sanitary Service.
Palo Alto, California.

Tejima, T.  Cooper, Clark and Associates, Palo Alto, CA.  February 28,  1977.
Report:  "Geotechnical Inspection and Testing Services Raising of Perimeter
Dike - Existing Class I Pond Area."  Written Communication to Richard
Granzella, Richmond Sanitary Service.

Tejima, T.  Cooper, Clark and Associates, Palo Alto, CA.  March 8, 1977.
"Estimate of Maximum Conceivable Discharge of Stored Wastes due to Dike
Failure - Existing  Class I Liquid Waste Pond."  Written Communication to
Richard Granzella,  Richmond Sanitary Service.

Tejima, T.  Cooper, Clark and Associates, Palo Alto, CA.  May 4,  1977.
"Seismic Slope  Stability of Class I and Class II Areas."  Written
Communication  to Richmond Sanitary Service.

Tejima, T.  Cooper, Clark and Associates, Palo Alto, CA.  August  24, 1977.
"Installation  of Groundwater Monitoring Wells - Existing  Class I  Areas."
Written Communication to Richmond Sanitary  Service.

Tejima, Tom.   December,  1982.  Personal communications.   Cooper  and  Clark
consulting engineers, Redwood City, California.
                                     20-30
-------
White, Charles A.  September,  1982.   Personal communications.   California
Department of Health Service,  Hazardous Waste Management Branch, Berkeley,
California.
                                    20-31
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                               TRAMMELL  CROW COMPANY

                                   DALLAS,  TEXAS


  INTRODUCTION                                                  MriJ    ,
                                                               NCP reference

      The Trammell Crow Company bought  a 133 acre  (53.2 ha)
  tract  of land  in western  Dallas  for development  as  an
  industrial park.  The site had been used by the Texaco Oil
  Company as a petroleum refinery and tank  farm from 1915 to
  1945 but had been vacant  since  then.   Oil sludge and coke
  cinders  were  stored  on-site  in  five   open  ponds  and
  totalled approximately 5,000,000  gallons  (1.9 x 10   1)  of
  sludge  and 10,000 cubic yards  (7,600  m )  of  cinders.
  Trammell Crow  obtained  an Urban  Development  Action  Grant
  from the U.S. Department  of  Housing and  Urban Development
  and a grant from the City of Dallas to finance part of the
  infrastructure  of  its  industrial  park,  which  included
 remedial action  concerning  the waste  ponds.    Waste  kiln
 dust and  fresh  kiln  dust were used  to   solidify the  oil
 sludge  and  cinders and  the  resulting mixture  was  land-
 filled on-site.   This innovative  and  economical technique
 was used  in  this  instance  for non-hazardous  substances,
 but has  possible applications  on  EPA defined  hazardous
 wastes  as  wel1.

 _Background_

     The^Texaco  Oil  Company operated a petroleum  refinery
 on  what  is  now the Trammell  Crow  site  from 1915  to  1945.
 During  that  period,  oil  sludge from tank  bottoms  and coke
 cinders  from  the  refinery's  petroleum  processing  were put
 into five  open ponds located  on  the premises.   After
 closing  the  refinery  in  1945,  Texaco sold  the property to
 Rogers  and  Wright, a  Tulsa  scrap  metal  firm  that bought
 the  property  to  salvage  the tankage, piping  and metal  in
 the  refinery.    After reclaiming  the  metal,  Rogers  and
Wright sold  the  land  in  1959  to the Zale  Corporation who
held the land until 1980,  when Trammell Crow purchased it.

     Trammell Crow  knew  of the  oil  ponds   when  it bought
the  land.  It  planned  to develop  the site in  two stages,
with the second stage involving the acreage that  contained
the ponds.  The Albert H.  Halff Associates  (Halff), a firm
of  consulting engineers  and scientists, was  hired  to

                                     21-1
-------
design roads, water mains, sewers and surface water drain-
age for  the  entire  133 acre  (53.2  ha)  site.   Halff also
was  responsible  for  analyzing  and  supervising  cLean-up
work.  Halff  took samples of the wastes  and hired South-
western  Laboratories,  a  geotechnical  testing   firm,  to
drill soil borings  and run standard  soil  tests.   Results
of the soil  tests  showed  that the  site  was underlain by a
layer of  low permeability clay, a  thick  shale formation,
and below that a deep aquifer.  Thus, the oil sludge ponds
posed  a   relatively  minor  threat   to ground  water.   No
measured  surface  water   pollution  occurred,  because  the
ponds were  banked and rainfall  in  that  area  was slight.
Moreover,  the waste  materials  had  weathered  for over 35
years,  resulting  in  heavy  sludges  with   thick crusts.
Volatile  substances  had  disappeared  long  ago.  Extraction
Procedure (EP)  toxicity tests were  negative.

Synopsis  of  Site Response

     Halff surveys showed  that  the  open ponds  contained an
estimated  5,000,000  gallons  (1.9  x  10   1)  of oil  sludge
and  10,000  cubic  yards  (7,600 m )  of  coke cinders,   far
more  than Trammell  Crow's prepurchase estimates.   Halff
selected  what it considered  to be  the  most effective  and
economical  technology:   solidification and  disposal in an
on-site  landfill.    They  then  planned  and  supervised  the
entire remedial  action.   Acting as  owner's  representative,
Halff  solicited  bids  for  the  work  and  selected  H.B.
Zachry,  Inc. (Zachry) as  low bidder.  Trammell  Crow  then
awarded  the  contract  to  Zachry.

     Work began on April  21,  1981  with the excavation of
the  landfill adjacent to a cluster  of three  ponds.   Oil
sludge  and  coke  cinders  from four ponds  were mixed  with
waste  cement kiln dust in  the  landfill,  pulverized, dried
and  compacted  to  specification.     Oil  sludge  from  the
largest  pond was mixed with  fresh  cement kiln dust  in the
pond, then   transported  several  thousand feet  to  the
landfill, where the  steps  for  mixing,  pulverizing,  drying
and  compacting  were  repeated.  After  solidification of all
 five  ponds,  the  landfill  was  capped,  graded and  seeded.
Work was  completed  on   September  1,  1981  and  required
approximately 75 working  days.   The  rest of  the site was
then graded  and a drainage system built in preparation for
construction of a large  warehouse  distribution facility.
 SITE DESCRIPTION

      The  Trammell  Crow  site  is  located  in  the  western
 sector  of  the  City  of  Dallas,  Dallas  County,  Texas,
 approximately  1  mile (1.6 km)  southwest of  the junction

                                      21-2
-------
 where the West Fork and Elm Fork become the Trinity River.
 The  site  is  situated on  a  133 acre  (53.2  ha)  embankment
 area bordered by  Interstate 30  to  the south and the Texas
 and Pacific Railroad  to  the north.   A  stream which flows
 north into the Old West Fork Channel  (the channel diverted
 from West Fork running parallel to the Trinity River) cuts
 through the site and along the waste ponds.

      The  site  and  area  surrounding  it  are  zoned  for
 industrial use.   To  the  north  of the  site  is  a  Texaco
 gasoline storage facility while a General Portland Cement,
 Inc. plant is located to  the  south.   East  of  the site are
 warehouse/distribution buildings and the Texas Industries,
 Inc. concrete pipe  plant  is  to the west.  A residential
 area  is  located  approximately   2,000   feet  (609.6  m)
 northeast of the sludge pit areas.

 Surface Characteristics

      Dallas County has a  mild  climate due to its  location    300.68(e)(2)
 at the   northern  edge of  a humid  subtropical  belt which    (i)(E)
 extends into  Texas from the Gulf of Mexico.  There  are no    climate
 pronounced topographic features to  influence  the  climate,
 so  temperatures,   precipitation,   and  snowfall  are  the
 results of the combined effects of warm moist air off the
 Pacific Ocean,  the  Gulf  of Mexico  and  cold dry  air  from
 Canada.

      Winter temperatures  average  48°F   (8.9°C),  and  the
 average daily minimum  temperature  is 38°F  (3.3°C).   The
 lowest  recorded  temperature in  the City of Dallas was  7°F
 (-13.9°C)   on  February   1,  1971.     Summer  temperatures
 average 84°F  (28.9°C),  and  the average daily  maximum
 temperature  is  94°F   (34.4'C).     The  highest   recorded
 temperature  for  Dallas County was  111°F  (43.8°C)  on  July
 25,  1954.                                                 y

      The  prevailing winds  are  from  the  south producing
 generally  clear  skies.   Frequently, from the  fall through
 the  spring,  strong winds  from the  north  rapidly  sweep  a
 cold  air  mass  into the area,  lowering temperatures  by as
 much  as 30°F  (-1.1 °C)  in 2 or 3  hours.    The strongest
 winds   are  during   April,  when  the average  wind speed is
 13 miles (20.8 km) per hour.

     Total  annual  precipitation   in   Dallas   County  is
 36 inches  (90  cm).  The period  of  greatest precipitation
 is  April  through  September  when 20  inches  (50  cm)   or
 57 percent  of  the  total falls.  On the  average, thunder-
 storms occur 40 days per year, mostly  in the spring.  The
heaviest recorded  rainfall  for one  storm was  6.01 inches
 (15  cm)  at  Dallas  on October  1, 1969.   The  average

                                     21-3
-------
seasonal  snowfall  is  2  inches  (5  cm),  and  the  heaviest
snowfall recorded accumulated 7 inches (17.5 cm).

     Relative huiridity averages  about 55 percent  in  mid-
afternoon.  It is higher at  night  and  at  dawn it  averages
about 79 percent.  Average daily sunshine is 75 percent in
summer and 55 percent  in  winter.

     The  surface  characteristics of  the  site  are  illus-
trated  in  the  topographic  map section  in Figure  1.   The
site  is  located  on a relatively  flat area adjacent  to a
small  stream  that  follows   the  waste  ponds  along  their
eastern and northern edges.  The  soil  has been classified
as  the  Trinity-Urban  land complex,  which is  composed  of
deep, nearly level, poorly drained,  dark  clayey soils and
areas  of  urban  land  or  flood  plains.   Soil  borings  by
Southwestern Laboratories were  taken  at  the  site  in the
locations shown in Figure 2.   These borings confirmed that
the  surface  soil  is  a Trinity Clay with a slope  of  less
than  1  percent.    Trinity  Clay  is  a  moderately  alkaline
soil of slow permeability (less than 0.06 inches [0.15 cm]
per  hour) and high water  capacity.  It  is  frequently
flooded,  has  slow  runoff  capabilities,  and  a  slight
erosion hazard.  The clay is  fine-grained and  over 97 per-
cent will pass through a  No.  200 sieve.

Hydrogeology

     Southwestern  Laboratories'  geotechnical test results
revealed  that  the  Trinity  Clay  extends 20  to  45 feet
(6.1-13.7 m)  below the  surface of the earth.  Below this
is  Eagle  Ford shale,  a  predominantly  dark,  blue-gray
marine  shale  reaching  a depth  of  approximately  400  feet
(122  m)  with an  average thickness  of 475 feet  (145 m) .
The Eagle Ford formation  contains minor beds of calcareous
shale,  shaley   limestone,   and   numerous  thin  beds  of
bentonite.   Below the shale formation  lies  the  Woodbine
Aquifer, one of the principal water-bearing beds in Dallas
County.   The  transition  between the  Eagle  Ford shale and
Woodbine Aquifer is gradual;  the sands of the Woodbine are
overlaid  first by sandy  clays and then  Eagle  Ford clays.
The Trinity  Clay and  Eagle Ford Shale formations form an
impermeable  barrier between  the surface and the Woodbine
Aquifer,  so there is a negligible  threat of ground  water
contamination at the Trammell Crow  site.
300.68(e)(2)(i)
(D)
hydrogeological
factors
300.68(e)(3)(ii)
extent of
present or
expected
migration
WASTE DISPOSAL HISTORY

     The  Trammell  Crow  site was  originally owned and
operated  by Texaco  Oil  Company  from 1915  to 1945  as  a
petroleum  refinery and  tank  farm.   When the  refinery
                                     21-4
-------
Figure 1.  Toposraphic Map Section of Trammell Crow Site Location
                     (Source: USGS, 1973)
                             21-5
-------
 Figure 2.  Location of Soil Borings at Trammell  Grow Site
(Source:     Albert H. Halff Associates, Inc.,  April 1981.)
                                  21-6
-------
ceased operations,  the five major  waste  areas  remained.
From 1945 to  1959  the property was  owned by a  firm  that
had purchased  the  property  for the  purpose  of  reclaiming
any valuable scrap metal from the site.  In 1959 after the
available   metal   was  reclaimed,    the  site was  sold  to
Zale Corporation.   Trammel1  Crow Company  purchased it  in
1980.   At  that  time,  Trammell  Crow Company hired  Halff
Associates  to  perform  the  initial  site  design  which
included designing a method  of  cleaning  up the  five waste
ponds.

     No  records  were available  to detail what processes
were  used  by Texaco  at the refinery or what wastes  were
generated   and  buried  in   the  ponds.   Therefore, Halff
Associates  supervised a  series of  field  surveys, sound-
ings, and   sampling and  analysis  procedures to determine
the  size,  contents,  and  characteristics  of  the  waste
ponds.   The five  waste ponds,  labeled A,  B,  C,  D, and E,
are  shown in Figure 3.
300.68(f)
remedial
investigation;
sampling and
monitoring
DESCRIPTION OF  CONTAMINATION

     Pond  A,  as  Figure 3  shows, was   the  largest of  the
five  ponds,  measuring  420  feet by  150 feet  (128 x 46 m)
with  an   average   depth  of  9  feet  (2.7 TB) .  The  bottom
and  sides  were  clay,  and  the  low   permeability  soil
prevented  much  seepage into the subsurface Trinity Clay.
The  pond  contained  approximately 3,500-000 gallons (1.3 x
10   1)  or  16,600  cubic yards  (12,616  m  )  of  waste.

     The material  contained in  Pond  A appeared to be tank
bottoms,  the  residues that settle to the bottom of crude
oil  tanks.   As the  tanks at  the Texaco refinery were
cleaned,  the  residues were most  likely  placed in Pond A.
The  sludge in Pond  A  consisted  of approximately 50 percent
carbonaceous  material,  35  percent  water, and 15 percent
ash.   A 2-inch (5  cm) crust had developed  over a semi-
liquid oil/water  emulsion  which  became  thicker  as  it
became  deeper  because the  density of the oil was greater
than  that  of  the water.  The carbonaceous portion of  the
sludge  was made up  of equal proportions  of asphaltenes  and
paraffins.   Complete  chemical analyses  of  the oil sludge
sediments  and  water content  from Pond  A are  presented in
Tables  1,  2,  and 3.    As   Table  1  shows, the sludge   was
tested  using  the Extraction  Procedure  (EP)  toxicity test
to  determine  whether or not  it was  a  hazardous  waste by
definition under  RCRA.   The  results  show that the sludge
was  below  the  maximum allowable concentrations as-defined
by RCRA.
300.68(e)(2)
amount and  form
of substances
present
                                      21-7
-------
Oo
           Figure 3.  Location of Sludge Pits  at Trammell Crow  Site
                  (Source:   Albert H. Halff  Associates, Inc. , 1981)
                                                                            rent: TRAMMEl CKOW COMPANY, OAU*$
-------
         TABLE 1.  CHEMICAL ANALYSIS OF OIL SLUDGE SEDIMENT FROM POND A
Test
Moisture, %/wt.
Gross Heat of Combustion,
BTU/lb
Flash Point, TOC, °F
Total Sulfur, %/wt.
Vanadium, ppm
Ash, %/wt.
Contaminant
Arsenic
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Barium


Sediment sample (composite from three locations)
As received Dry basis
34.3
3,802
301
0.63
51
19.9

5,787
301
.96
77
30.3
EP Toxicity Tests per 40 CFR 260.0 & 260.21
Test results Maximum allowable concentrations
mg/1 of extractant mg/1 of extractant
0.42
*0.01
0.1
*0.05
*0.002
*0.01
*0.01
0.9
5.0
1.0
5.0
5.0
0.2
1.0 "I
5.0
100.0
*less than





Source:   Morgan, D.S.  Albert H. Halff Associates,  Inc.,  1982.
                                     21-9
-------
             TABLE 2.  CHEMICAL ANALYSIS OF OIL SLUDGE FROM POND A

Test Pond A North End Pond A South End
Moisture content, %/wt.
Loss of heating, %/wt.
Ash content, %/wt.
Oil content, %/wt.
Gross heat of combustion,
BTU/lb
Viscosity, SFS
Asphaltene
30
35
10.5
56.0
8,316
*
26.67%
37
40
8.3
50.1
7,057
*
24.62%
*There was insufficient sample to perform the analysis




Source:  Morgan, D.S.  Albert H. Halff Associates,  1982.
                                     21-10
-------
                      TABLE 3.  WATER ANALYSIS  FROM  POND A
Identification: Water from south pond
pH 8.2
Conductivity 2200
mg/1
Silica
Iron
Aluminum
Calcium
Magnesium
Sodium
Potassium
Carbonate
Bicarbonate
I Sulfate
Chloride
Fluoride
Nitrate
Phosphate
Hydroxide
P-alkalinity (as CaCO?)
Total hardness (as CaCO,.)
Arsenic
Cadmium
Chromium
Lead
Zinc
Silver
Mercurv
Nickel
Boron
77.3
3.05
1.16
324
15
340
13.3
0
964
43
205
0.6
1.9 — 1
1.2
0
0
/y(j
870
0.15
* 0.01
* 0.1
* 0.05
0.07
	 * 0 . 0 1 	
* 0.01
* 0.002
0.09
* 0.1
*less than




Source:  Morgan, D.S.  Albert H. Halff Associates,  Inc.,  1982.
                                     21-11
-------
     Directly north of Pond A was Pond E.  It measured 550
feet by 200 feet (152 x 61 m) with an average depth of 2.5
feet  (0.76 m) .    Pond  B  contained   approximately  10,000
cubic yards (7,600 m ) of waste material.
     The waste  material in  Pond  B  was  a  hard  coke/slag
material believed  to  be  coke  cinders  from  the refinery
cracking process.  This "clinker pit" was characterized by
a soil boring and  trenching  of  the surface.  The findings
showed  that  the coke  material was  approximately  4 feet
(1.2m) deep  in  the northern  portion  of the pit  and varied
from a  few  inches  along the edge  to approximately 5 feet
(1.5m) in the center.

     Ponds C,  D, and  E were located next  to one  another
along  the  northern  edge  of  the  Trammell  Crow property.
Although they  were not all  the same size,  each pond was
approximately 300  feet (91m) in  length.    Pond  E  was the
largest with a width of 150  feet (46 m), while Ponds  C and
D were each  approximately  50 feet (15 m)  wide.   They had
bee-n  excavated  almost  6   feet   (1.8  m)  below   natural
gradient.  About 1,500,000 gallons (5.7 x 10   1) of sludge
were found in Ponds C, D, and E combined.

     The wastes  in the three northern ponds (C,  D,  E) were
believed  to  be  sedimentation  pond  or   oxidation  pond
residues.   These oily  sludges  were  approximately  4 feet
(1.2 tn)  deep and were covered  by  a  6 to 7  inch (15 -  18
cm) layer of clean silt.

     Although no significant contamination was  evident  at
the Trammell Crow site, the  sludge from these  ponds had  to
be  treated,  removed,  or  both  before  construction  at the
site  could  begin  in  order to ensure maximum and safe
development  according  to Texas  state  law.
PLANNING THE SITE RESPONSE

Initiation of Response

     When  the  Trammell  Crow Company  bought  this 133  acre
(53.2 ha)  tract in western Dallas,  it believed  that  only  a
shallow pond of waste oil  existed at the site  and that  it
would be  easy  to remove.  As  discussed above,  subsequent
tests  revealed that  the shallow  pond  was  really  an  oil
sludge  pit about 9  feet  (2.7  m)  dee*  that contained  an
estimated  3,500,000  gallons  (1.3 x 10  1).  Three smaller
ponds  on  the  property   had  layers  of  water  and  silt  on
their surface, but  underneath  were found to contain  about
4  feet  (1.2  m) of cdl  sludge,  for an  estimated  1,500,000
gallons  (5.7  x  10  1).    A  fifth  pond  containing  an

                                      21-12
-------
estimated  10,000 cubic  yards  (7,600 m3)  of coke  cinders
was  also discovered on the property.

     Upon  learning  of the extent of wastes present on  the
site and  the  initial  estimates  of  the  development  cost,
Trammell  Crow  concluded  that   it  would  be economically
unfeasible  to  develop the site  at  that time.  It notified
the  City of Dallas of the  situation  and requested that  the
city obtain  an Urban  Development Action Grant (UDAG) from
the  Department  of  Housing  and  Urban  Development  (HUD).
The  Dallas  City Council  refused in 1980,  but  in 1981  it
reconsidered Trammell Crow's request and decided to  apply
for  the  UDAG.    The  grant was made that  year.   Trammell
Crow received  $4,000,000 under  the UDAG plus a $1,000,000
grant  from the  city to finance part  of the  construction of
the  infrastructure  at  the  site,  which  included remedial
action  on  the  five  ponds.    The  company  financed  the
remaining construction costs itself.

Selection of Response Technologies

     Halff Associates took several criteria into consider-
consideration   before  selecting a remedial action.   These
included  cost,  feasibility, environmental  factors,  time,
and  legal implications.   Before  cement kiln dust   solidi-
fication was   chosen, 19   alternatives, including   on-site
and  off-site   disposal  methods,  were  investigated (see
Table  4) .    Each alternative  was   evaluated and  given  a
preliminary cost estimate.

     The  first  alternative  to   be  investigated  seriously
was  oil  recovery.    It  seemed   logical  that some  of  the
costs  incurred  for clean-up  would be able to be recovered.
To  determine whether  or not  the  sludge  had recoverable
oil,  sludge samples  were  sent  to  various  oil  and  wax
refineries.    Analyses  showed  that  the  oil, bound  in  a
tight  emulsion, would  be  difficult to  recover  using
standard techniques.   Unconventional recovery techniques,
such as filtration  through diatomaceous  earth,  produced  a
maximum  of  5    to 10  percent oil  by  weight at  a cost  of
$30  per  barrel, a  little  above  the current  market  price
for  a barrel.   Halff Associates  concluded that the expense
of  oil  recovery was  not  worth  the  limited amount  of  oil
that could be  recovered.

     Next, Halff Associates  compared off-site and on-site
disposal alternatives.   The on-site solidification  tech-
nique  was  found  to  be   the  most  feasible, because  the
sludge was classified as a Class II  industrial waste  under
Texas  State  law and  therefore  could  not  be placed  in  a
municipal landfill.   The closest industrial waste landfill
was  located  on  the  Texas  Gulf  Coast,  and the  cost  for
300.68(h)
screening

300.68(g)
development of
alternatives
                                     21-13
-------
          TABLE 4.  DISPOSAL ALTERNATIVES FOR THE TRAMMELL CROW SITE
Off-site disposal methods

   Industrial waste landfill
   Municipal landfill
   Fuel in asphalt plant
   Mixture in asphalt
   Require Texaco to dispose of waste
   Use as road oil
   Oil in grass-seed mix
   Sell oil to refinery
   Off-site land farm
   Transportation of waste to
     wax recovery plant
On-site disposal methods

   Open pit burn
   Incineration (mobile unit)
   Storage facility
   On-site land farm
   Landfill on-site*
   Solidification*
   Biological treatment plant
   Incineration at permanent site
   Recovery of oil and landfill
     on-site*
*Alternatives that were further investigated

Source:  Morgan, D.S.  Albert H. Halff Associates, Inc., 1982,
                                    21-14
-------
  transporting the waste would have been  $60  per  cubic  yard
  C$45.60/m )  or  $1,500,000.   The  on-site  solidification
  technique was  estimated  to  cost  $500,000  and  thus  was
  selected   as   the   most   cost-effective   procedure   for
  correcting the  problem.

  Extent  of Response

      Work began on  May  21,  1981  and  ended on  September 1,
  1981,   for a  total  of   about  75  working days.   Clean-up
  work  was stopped   when  all  of  the  oil sludge  and  coke
  cinders had  been solidified  and  landfilled  and the  site
  graded, capped,  and seeded.   All work  was  supervised  by
  Halff and performed according to specifications once  the
  landfill  closure plan  submitted  by  Halff  Associates  was
  approved  by  the  Texas Department  of Water Resources.
300.68(j)
extent of
remedy
 DESIGN AND EXECUTION OF SITE RESPONSE

      The design and implementation of  the sludge  solidifi-
 cation  technique  involved extensive   laboratory tests to
 determine  what  materials  in  what quantities would pro-
 duce  the most stable compound when mixed with the sludge.
 Several  factors  had  to be  taken  into  account  before  Che
 solidification materials and remedial  design were chosen.
 These  included  mixing,  solidification,  and  compaction
 characteristics; availability;  cost,  knowledge  of percent
 moisture  to  avoid  leaching;   compatibility   with  Trinity
 Clay; and distance maintained  from utility lines.

      With these criteria  in mind, Halff  Associates  began
 solidification  testing  using   various  local  materials.
 These materials included  on-site  clay,  sulfurs,  cements,
 fly  ash,  fresh cement  kiln  dust,  stale cement kiln  dust*
 quick lime,  waste  quick lime,   limestone screenings,  sand^
 and  various  combinations of these  materials.  As Table 5
 shows,  the least  expensive  solidification additives  were
 waste cement  kiln dust  at  $4.50 per  ton ($4.08/Mt.)  and
 cement kiln dust at $6.75 per ton  ($6.12/Mt.) (these  costs
 include  transportation).   The  waste cement  kiln dust  is
 known as  stale  dust  because  it  has   been  stockpiled  in
 cement  manufacturers'   quarries  and exposed   to  the  ele-
 ments, so  it has retained moisture.  As Table 5 shows,  the
 stale dust  is  in abundant supply  because it  was  believed
 that  the  moisture  content would hinder its  effectiveness
 as a solidifying  agent.    Therefore,   initial  testing  by
 Halff Associates  did  not  include  testing  the stale  kiln
dust.  Fresh kiln  dust  could only  be  obtained in limited
 supplies, because  it  had become  a commonly  used solidi-
 fying agent.   Demand  for  this  material had  increased  to
such  a great extent that rights  to the  fresh dust had been
300.68(h)(3)(i)
detailed
analysis of
alternatives
                                     21-15
-------
         TABLE 5.  COST AND AVAILABILITY OF SOLIDIFICATION ADDITIVES
Product
On-site clay
Sul fur
Cement
rly ash
Cement kiln dust
Waste cement kiln dust
(38% moisture)
Quick lime
iJaste quick lime
(41% moisture)
Limestone screenings
Tons per
cu . yd
1.28
-
1.27
1.0
0.54
0.75
0.34
0.55

Cost
per ton*
$ 0**
70.00
($63.50/Mt.)
69.00
($62.60/Mt.)
16.79
($15.23/Mt.)
6.75
($6.12/Mt.)
4.50
($4.08/Mt.)
65.00
($58.97/Mt.)
12.50
($11.34/Mt.)
7.92
($7.18/Mt.)
Availability
Abundant
Delivery problems
Abundant
Abundant
Limited supply
Abundant
Abundant
Abundant
Abundant

 *Delivered to site




**Exclusive of drying and grinding that would not have been cost-effective




Source:  Morgan, D.S.  Albert H. Halff Associates, Inc., 1982.
                                     21-16
-------
 claimed  prior  to its  production.   Even though supplies  of
 fresh  dust were  limited,  initial  tests included  it as  a
 viable solidifying  agent.

      Preliminary testing  conducted  by Halff  Associates
 included  a procedure  to measure  the compressive  strength
 of various mixtures of sludge and  solidifying agents.  The
 compressive strength test was as follows:

      1.   Twenty-five  grams of  sludge  were  mixed  with   a
           predetermined amount of drying agent.

      2.   Combinations of drying compound and oil sludge  by
           weight  were  tested  in  the  following   ratios:
           0.5:1.0, 1.0:1.0, 1.5:1.0,  2.0:1.0, and 2.5:1.0.

      3.   The drying compound and oil sludge mixtures were
           each  stirred  until  thoroughly mixed  and   lightly
           compacted to eliminate large voids.

      4.  The samples were  each  compacted 1 hour  later by
          pressing the blunt  end  of a soil  test  pocket
          penetrometer into the mixture 10 times.

      5.  The  soil  test  pocket   penetrometer   was  then
          pressed  into  the  mixture  and  the  unconfined
          compressive strength  was  measured  in  tons  per
          cubic  foot.

      6.   The sample  was  loosened and the test was repeated
          24 hours later  and  again  1 week later.

      The  results of  these preliminary  tests,  presented  in
 Table 6,  show that several  of  the materials  solidified the
 oil  sludge effectively while  others were less  effective.

      On-site  clay,  while most  readily available,  was  not
 effective  when  wet.  It was an  effective solidifying agent
 when  dried and  pulverized.   The strength tests on  the  dry
 clay  after one  hour  were moderately strong.  The wet soil,
 on  the  other hand,  did  not  solidify  to  a  satisfactory
 strength.   Therefore,  the moisture  content  of  the  soil
 appeared to be  an important factor.

     Neither crushed limestone  nor  sand proved to  be  good
 solidifying agents,  as  shown  in Table  6.   Both materials
 are_very  large  grained and  did not  solidify  because  the
 grains became coated with oil.

     Mixtures of  cement  with dry  sand and wet  sand were
both  tested as  solidifying  agents.   The  cement and dry
sand  showed  poor   compaction,   dryness,   and   lack  of

                                     21-17
-------
                            TABLE  6.   SOLIDIFICATION  TEST RESULTS PERFORMED BY
                                       ALBERT  H.  HALFF ASSOCIATES, INC.
Nl
i—*
I
i—'
00
Cost
>er
ton
($)
8.50
17.00
25.50
34.00
42.50
3.53
6.75
9.53
Compound
Fly ash*
Fly ash
Fly ash
Fly ash
Fly ash
Kiln dust
Kiln dust
Kiln dust
Ratio
CHPDjoil
0.5:1
1.0:1
1.5:1
2.0:1
2.5:1
0.5:1
1.0:1
1.5:1
Strength (tons/ft3)
1 hr. 24 hr. 1 «eek
_
1.75
2.6 2.45
2.85 2.50
2.00 2.50
2.15 2.40
1.50 3.00*
1.40 2.25 2.70
Description
Conditions af"ter approximately 1 week
Too wet; never tested; thrown out
very black; moist; compacts well; stays
tight
Black; moist; compacts; scrapes easily
dark brown; slightly moist; compacts;
scrapes easily
Brown; very slightly moist; compacts;
falls apart
Black; moist; compacts well; very
cohesive
brown; slightly moist; compacts;
slightly cohesive
Light brown; very slightly moist;
compact; not cohesive
(continued)
                        .
               **Sr,i! w-ia dried  and pulverized before raixin* with emuUion.
-------
                                                TABLE  6.    (continued)
N3
I—"
I

Cost
per
ton
<$>
13.50
19.00
0.00
0.00
0.00
0.00
0.00
3.96
7.92
Compound
Kiln dust
Kiln dust
Soil*,**
Soil**
Soil**
Soil**
Soil**
Crushed
limestone
Crushed
limestone
Ratio
CMPD;oiL
2.0:1
2.5:1
0.5:1
1.0:1
1.5:1
2.0:1
2.5:1
0.5:1
1.0:1
•i
Strength (tons/ft )
1 hr. 24 hr. 1 week
2.20
-
-
0.75
2.20
2.65
3.30
-
-
2.10
-
-
1.85
3.20
3.35
3.60
-
-
1.5
-
-
2.40
3.40
3.35
3.4
-
-
Description
Conditions after approximately 1 week
Light brown; relatively dry; does not
compact
Too powdery
Too wet; never tested; thrown out
Black; moist; compacts well; cohesive
Dark brown; not moist; compacts;
slight cohesion
Brown; not moist; compacts;
crumbles easily
Light brown; dry; compacts;
crumbles very easily
Too wet; never tested; thrown out
Too wet; never tested; thrown out

                 *Hot enough sample  for accurate strength  test.
                **Soil was dried and pulverized before mixing with emulsion.
                                                                                           (continued)
-------
                                              TABLE 6.   (continued^
|SJ
K-
I

o
Cost
per
ton
(?)
11.88
15.84
19.80
5.75
11.50
17.25
23.00
28.75
Compound
Crushed
limestone
Crushed
1 imeatone
Crushed
limestone
Kiln dust ,
fly ash
Kiln dust ,*
fly ash
Kiln dust ,
fly ash
Kiln dust,
fty ash
Kiln dust ,
fly ash
Ratio
CHPO;oil
1.5:1
2.0:1
2.5:1
0.5:1
1.0:1
1.5:1
2.0:1
2.5:1
Strength (tons/ft3)
1 hr.
-
-
-
-
-
2.1
2.45
3,20
24 hr. 1 week
-
-
1.30
-
1.25
2.65
4^0
3.75
-
3.25
3.35
1.75
3.2
2.5
2.15
2.25
Description
Conditions after approximately 1 week
Too wet; never tested; thrown out
Black; slight raoist; compact;
slightly; cohesion
Black; slight moist; compact
slightly set but does crumble
Black; very moist; compacts well;
very cohesive
Black; moist; compacts well;
cohesive
Brown; slight moist; will compact;
slight cohesion
Light brown;dry; tough to compact;
crumbles
Light brown; powdery; tough to compact;
crumbles
.
                *Hot enough sample for accurate strength test.
                                                                                        (continued)
-------
                                                  TABLE  6.   (continued)
to
I
ro
Cost
per
ton
($)
74.00
108.50
177.50
74.00
108.50
177.50
53.10
Compound
Dry sand,
cement
Dry sand,
cement
Dry sand,
cement
Wet sand,**
cement
Wet sand ,
cement
Wet sand,**
cement
Sand, sulfur
Ratio
CMPD;oil
5:0.5:1
5:1.0:1
5:2.0:1
5:0.5:1
5:1.0:1
5:2.0:1
5:0.5:1
Strength (tons/ft3)
1 hr. 24 hr. 1 week
1.20
1.85
2.25
1.5
1.75
2.6
1.2
1.25
1.75
2.95
4.50
4.50
4.50
1.5

1.25
1.70
1.70
4.5
4.5
4.5
1.7
Description
Conditions after approximately 1 week
5:0.5:1 Black; dry; does not compact
well; crumbles
5:1:1 Brown; dry; poor compaction;
does not hold
5:2:1 Light brown; dry; poor compaction;
not cohesive
5:0.5:1 Black; dry; set; crumbly
5:1:1 Dark brown; dry; set; difficult to
break
5:2:1 Gray; dry; set; crumbles easily
5:0.5:1 Black; moist; compacts; cohesive

                                                                                                      (continued)
                  *Sand vaa dried before it was added to the mixture.
                   Wet sand mixtures with cement set so the sample  was not broken  and re-compacted  for the 24-hour and week
                   tests.
-------
                                        TABLE  6.   (continued)
ro
I
NJ
Cost
per
ton
($)
311.50
583.50
108.50
0.00
0.00
0.00
0.00
0.00
3.45
6.90
Compound
Sand, sulfur
Sand, sulfur
Sand, water,
cement
Wet soil
Wet soil
Wet soil
Wet soil
Wet soil
Cement
Cement
Ratio
CMPD;oil
5:1.0:1
5:2.0:1
5:0.5:1:1
0.5:1
1.0:1
1.5:1
2.0:1
2.5:1
0.05:1
0.1:1
Strength (tons/ ft3)
1 hr. 24 hr. 1 week
1.75
2.25
-
-
-
-
-
-
-
-
1.95
2.65
4.5
-
-
0.5
0.5
1.55
-
-
2.2
2.5
4.5
3.1
3.25
3.55
3.0
4.0
-
0.6
Description
Conditions after approximately 1 week
5:1:1 Black; slight moist; compacts;
crumbles
5:2.1 Brown; slight moist; compacts;
slight cohesion
Black; oily; solid; very strong; rigid
Black; moist; compacts; cohesive
Black; slightly moist ; compacts;
cohesive
Black; slightly moist; compact; slightly
cohesive
Black; slightly moist; compact; crumble
Dark brown; dry; compact; crumble
Black; moist; not compacted well;
paste- like
Black; moist; compact; very cohesive

                                                                                (continued)
-------
                             TABLE 6.   (continued)

Cost
per
ton
($>
13.60
13.60
27.20
54.40
16.60
6.45
6.68
3.00
3.68
7.36
14.72
Compound
Cement
Sulfur
Sulfur
Sulfur
Sulfur,
kiln dust
Cement ,
kiln dust
Lime,
kiln dust
Kiln dust
Lime
Lime
Line
Ratio
CMPDjoil
0.2:1
0.05:1
0.10:1
0.20:1
0.05:0.5:1
0.05:0.5:1
0.05:0.5:1
0.5:1
0.05:1
0.10:1
0.20:1
Strength ( tons/ ft )
1 hr. 24 hr. 1 week
-
-
-
-
-
0.60
1.65
-
-
-
-
-
-
-
-
1.0
3.25
3.10
0.90
-
-
.70
2.3
-
-
-
2.4
-
-
2.55
0.70
1.60
-
Description
Conditions after approximately 1 week
Black; slightly moist; compact; cohesive
Black; very thick fluid
Black; very thick fluid
Black; paste-like
Black; slightly moiat; compact; slight
cohesion
Black; slightly moist; compact; cohesive
Black; slightly moist; compacts;
cohesive
Black; slightly moist ; compacts well;
cohesive
Black; moist; compact; cohesive
Black; moist; compact; very cohesive
Black; slight moist; compact; cohesive
                                                                            (continued)
Source:  Morgan, D.S.  Albert H. HaIff Associates, Inc.,  1982.
-------
 cohesion.   Mixed together,  cement  and wet  sand  formed  a
 strong,  concrete  material that  solidified  quickly.   One
 disadvantage of  this  mixture was that it could  not  to be
 broken up and re-compacted.

      Other  mixtures  which  were tested included  lime,
 sulfur, and cement.  These were combined in small ratios of
 each material  to  sludge ranging  from  0.05,  0.1,  and  0.2
 parts of  lime,  sulfur,  or  cement to 1.0  part  oil  sludge.
 Although  these  compounds formed  cohesive mixtures,  they
 did not  solidify  well.   They were  paste-like,  moist,  and
 remained soft for 2  days.

      Kiln  dust  and  fly ash  were  the  most  effective
 solidifying  agents,   as   they  solidified  at  low  mixing
 ratios  and could  be broken up and re-compacted.   A  50:50
 mixture of kiln  dust  and fly ash was  also  tested.   This
 compound  solidified the  sludge  well  at  lower ratios of
 kiln dust and  fly ash to oil.   At  higher ratios  of  kiln
 dust and fly ash to oil, such as 2.0:1.0  and 2.5:1.0,  the
 mixtures  became  powdery,   easily  crumbled, and  were
 difficult to  compact.

      Halff Associates  analyzed the   results of  these  tests
 and  determined   that cement   kiln dust  and dried clay were
 the  most  feasible  materials  to use for the solidification
 process.    Once  this  determination  was   made,  these
 compounds had  to  be   tested more  extensively.    Halff
 Associates  directed  Southwestern Laboratories  to  conduct
 further  testing of various mixtures of  clay,  soil, kiln
 dust, and  oil.  At the same time, Halff Associates  began a
 search  for  large supplies of  cement kiln dust.

     The  results  of  Southwestern  Laboratories'   solidi-
 fication  tests  are shown in  Table 7.   The compounds that
 were tested using clay as a solidifying agent demonstrated
 very high  linear  shrinkage.   For  an  8.0:1.0  ratio of clay
 to  sludge,  the linear  shrinkage  was 13  percent.   Insta-
 bility  of solidified  sludge   in a  large mass,  such as at
 the Tramraell Crow Site, would  not  be  acceptable.

     Cement  kiln   dust   was mixed  with  the   sludge at  a
 3.0:1.0  ratio.    As  Table 7  shows,  Southwestern  Labora-
 tories tested this cement kiln dust/sludge mixture  twice.
The  first  mixture yielded a   compressive    strength   of
2,210 psf and showed no linear shrinkage.  The second test
 shewed   a  compressive   strength  of  3,030  psf   (3.01 x
 10   Pa) .   Therefore,  it  can  be  assumed  that cement  kiln
dust mixed, with  sludge at a  3.0:1.0  ratio will produce a
strong,  stable  compound.   As   the  results in Table  8  are
examined more  closely,  it is  apparent  that the kiln dust
showed  little  to  no linear  shrinkage   and a  low to  zero

                                     21-24
300.68(i)(2)(C)
constructibility
-------
                TABLE  7.   PRELIMINARY SOLIDIFICATION  TESTS BY SOUTHWESTERN  LABORATORIES
I
Ni
Ul
Dry
Mixture Moisture density
description content (pcf )
Clay
Clay, sludge
(8:1)
Kiln dust , sludge
(3:1)
Clay, kiln dust, sludge
(5:4:2)
Clay, ktln dust, sludge
(6:2:3)
Clay, hyd rated lime,
sludge (13:1:3)
Kiln dust, sludge
(3:1)
Clay, kiln dust, sludge
(3:3:2)
Kiln dust, clinker
(1:3)
Clay, quick line,
Kiln dust, sludge
(10:1:33)
Clay, quick lime, sludge
(13:1:3)
Clay, sludge
(1 C.Y.:60 gal)
(field test)
Clay, kiln duat, sludge
(3:3:2)(Field test)
20
17

21

22

18

16

20

23

11


23

17


29

19

93
92

81

93

93

92

82

86

65


61

87


SI

81

Atterberg Limits
LL PL PI
55
46

41

43

40

27

-

48

51


45

45


53

45

23
21

40

41

39

28

-

47

48


40

46


38

35

32
25

1

2

1

-

-

1

3


5

-


15

10

Linear
shrinkage
I
14
13

0

0

0

0

-

1

2


3

0


10

4

Corapressive
strength
(paf)
4,650
3,810

2,210

4,980

1,345

2,670

3,030

3,220

3,930


4,730

5,820


4,070

5,030

                 Source:  Morgan, D.S.  Albert H. Halff Associates, Inc., 1982
                                                                                   (continued)
-------
           TABLE 8.  CHEMICAL COMPOSITION OF FRESH CEMENT KILN DUST
Compound
CaO
Si°2
A12°3
Fe2°3
MgO
Na2°
K2°
so3
Miscellaneous
Percent by weight
53.8
17.2
5.5
2.4
0.9
2.2
3.1
4.4
10.5
Source:  Morgan, D.S.  Albert H. Halff Associates, Inc., 1982.
                                     21-26
-------
 plasticity  index.  The kiln  dust  combined  readily  with  the
 sludge  so  that  a mixture of fair strength could be  tested
 within  1 hour.   The  kiln dust/sludge mixture  increased  in
 strength as the  material cured, and did not crumble  after
 being  submerged  in water  for  24 hours.   At  ratios  other
 than   3.0:1.0,   linear   shrinkage   was    observed    and
 compressive strength decreased.

     Quick  lime  (calcium oxide or  CaO)  and hydra ted  lime
 (calcium  hydroxide  or  Ca(OH).),  were  tested  by South-
 western  Laboratories  as  solidifying  agents  with various
 combinations  of  clay,  kiln  dust,  and sludge.   The  quick
 lime  reacted with the  water  in  the  sludge  to  instantly
 combine with  and dry the sludge.  The  roost desirable  ratio
 of quick lime to oil is  0.15 to 0.3  parts  of quick lime  to
 1.0  part  of oil.   Quick  lime,  however,  is  expensive
 ($65.00  per ton  or $58.97/Mt.) and  would  only be econom-
 ical  if  used in smaller amounts  to  decrease  the  moisture
 content and linear shrinkage of a soil/sludge  mixture.

     Hydrated  lime was mixed with  clay,  sludge,  and kiln
 dust so that  the ratio  of  clay to hydrated lime to sludge
 to  kiln dust  was  10:1:3:3.    The  compound formed  had  a
 compressive strength of  4,870 psf  (4.84 x   10   Pa)  and
 showed no  linear  shrinkage.   This reduction in the linear
 shrinkage   combined  with  a  reduction  in  the  plasticity
 index are factors that make  hydrated lime  a better solidi-
 fying  agent  than  cement kiln  dust.   The  hydrated  lime
 however, was at  least  as  expensive  or more  so  than  the
 quick  lime, and would  most likely  be added  to a cement
 kiln dust/sludge mixture in small amounts  to  improve  the
 shrink-swell characteristics of the  solidified mixture.

     Once   these  preliminary   tests were  conducted,  Halff    300.68(j)
 Associates  determined  that  the  most cost-effective and    cost-
 technically feasible  solidification  agent was  the cement    effectiveness
 kiln dust.   Because of a large demand  for  fresh kiln  dust,
 the  supply  was  limited.    Therefore, Halff Associates
 decided to have Southwestern Laboratories perform  the same
 solidification  tests  using  waste  cement kiln dust and
waste quick lime.  These materials were both stockpiled  in
 cement manufacturers'  quarries  and had  been  exposed   to
atmospheric  conditions.   Once  water  from  the atmosphere
 came into  contact  with  the  waste  kiln dust,  the powdery
waste cement  kiln dust  turned  into a crumbly limestone
 (CaO or quick lime) and the CaO reacted with water to form
Ca(OH)   or  hydrated  lime.    Southwestern  Laboratories had
 tested fresh hydrated  lime and quick  lime and found  them
 to be worthwhile as solidifying agents, but restrictive  in
cost.
                                     21-27
-------
     Waste quick lime was tested to determine the percent-
age of  avai lable CaO, because  the  CaO  reacts  with water
and produces  steam  and  Ca(OH)2.   The chemical reaction is
written as:

     CaO + HO—-        »-Ca(OH)  + heat.

This  chemical  reac tion  quickly dried  the  oil  sludge.
Therefore, the previous tests by Southwestern Laboratories
confirmed  this  using  fresh  cement  kiln  dust  and  quick
lime.   The fresh cement  kiln  dust  contained approximately
50  percent  CaO,  while  the  quick 1 ime  contained approxi-
mately 85 percent CaO.  Although these non-waste materials
had  produced  excellent  solidifying results,   they  were
expensive.   Therefore,  Halff  Associates decided  to test
the  waste  cement   kiln  dust   and   waste   quick  lime  to
determine how effective they would be.

     The waste quick  1 ime contained approximately 50 per-
cent CaO.   When mixed  with  the  sludge, the  waste quick
lime had  excellent  adsorption  characteristics,  was water
repellant, was  eas ily  compacted,  and  produced  a stable
fill.   The waste quick lime was available  for $12.50 per
ton ($11.34/Mt.)

     The  waste  cement  ki In  dust   was   also   sampled  and
tested by Southwestern Laboratories.  The sample which was
used contained 41 percent moisture  prior to mixing.  When
the  sludge  was  mixed  with  the  waste  cement  kiln dust
sample, the resulting compound  contained 55 percent mois-
ture.   The mixture  after  24 hours was 45 percent moisture
and maintained a compressive strength of 5,200 psf (5.16  x
10  Pa) .    The  waste  cement  kiln  dust  showed  excellent
stabilization  and   solidification   characteristics.    The
cost of the waste cement  kiln  dust  at the time  of testing
was $4.50  per ton  ($4.08/Mt.)  and  the local  supply was
abundant.

     Southwestern Laboratories'  tests  confirmed that the
best solidifying agents  for the oil/sludge  mixture at the
Tramrae 11  Crow site  were  either  cement kiln  dust,  quick
lime,  hydrated  lime,  waste cement kiln dust,  waste quick
lime,  or  a  combinat ion  of  some or  all of  these agents.
The  final  determination  of  the  solidifying  agents best
suited  for  this  site  was made  based  on cost  and avail-
ability of materials.

     The most  inexpensive materials  were the  waste cement
kiln  dust ($4.50  per  ton  or  $4.08/Mt.)  and  the  fresh
cement kiln dust ($6.75  per ton or  $6.12/Mt).   The fresh
cement kiln  dust produced  the  best results  using small
ratios of dust to oil at  1.0:1.0  or 1.5:1.0 parts dust to

                                     21-28
-------
 oil, while  the  waste  cement  kiln dust produced a suitable
 fill material when mixed with  the oil  at a  2.0:1.0 or
 3.0:1.0 dust  to oil ratio.  Although the fresh cement kiln
 dust was difficult to obtain in  large quantities, some was
 available locally.  Gifford-Hill, Inc. owns a large cement
 manufacturing plant, in Midlothian, Texas approximately 30
 miles (48 km) southwest of Dallas.  The Gifford-Hill plant
 had  some  fresh  cement  kiln  dust  available  and a  large
 stockpile of stale kiln  dust  that they were  willing to
 se,ll.  Gifford-Hill could only supply 138 cubic yards (105
 m )  or  33 tons  (30  Mt.)  of  fresh  kiln dust per day (an
 average of  three 25 ton (23 Mt.) cement  transport  trucks
 full).   Because of the  limited supply of  fresh kiln dust
 and large supply of stale kiln dust available, Halff Asso-
 ciates   decided  to  use  a  combination  of  fresh dust  and
 stale dust.

      Conservative estimates for the total quantity of dust
 needed  were  based on a  ratio of 3 parts  dust to  1  part
 oil, assuming that  the  majority  of the  bulking  agents
 would be stale dust and that  the best  solidification once
 in the  field would require a 3.0:1.0 ratio of dust  to oil.
 By using this ratio of  stale and fresh dust,  enough  dust
 would  be  available  from  Gifford-Hill  on  an  as-needed
 basis.

      The  total  amount  of  sludge  to  be  solidified  was
 estimated  at 5,000,000 gallons  (1.9 x  107 _1) of oil,  the
 equivalent  of 25,000 cubic yards  (19,000 m3) of  sludge  at
 a  density of  approximately 1  ton per cubic yard.  At  the
 3:1  dust to oil  ratio,  the  estimated amount of kiln  dust
 needed  for  solidification was  75,000  tons  (68,039  Mt.).
 The   projected cost   for the  kiln dust alone was  $300,000.
 In addition,   an  on-site   landfill for the   solidification
 process  and  resulting  solidified  sludge  was  designed  to  be
 5.5  acres (2.2  ha) on  the  surface and 12  feet  (3.7  m)
 deep.   Labor costs for  the  solidification  and  excavation
 were  estimated at  $200,000 or $500,000 for the entire job.

      Once  Halff Associates  had  determined  that  the oil
 sludge  solidification  by  cement  kiln  dust  was  a  viable
 solution  and  the  Trammell   Crow  Company   accepted  this
 alternative,  a  closure  plan was  filed  with  the  Texas
 Department of  Water  Resources.   The closure plan outlined
 the  solidification  process  and  the  proposed on-site
 landfill  for  disposal  of the solidified  sludge.   The 5.5
 acre  (2.2  ha) landfill was to be  located in the area con-
 taining sludge ponds  C, D, and  E (see Figure 3) to avoid
 odor  problems related  to the  moving and  mixing of  the
 sludge.    No odor  problems were  discovered.  There  were
 standing orders  left with Halff Associates by the City of
Dallas to shut down the project if high winds were present
 300.68(j)
 cost effective-
 ness
 300.68(i)(2)(B)
 detailed  cost
 estimation
300.68(i)(2)(E)
analysis and
mitigation of
adverse
environmental
impacts
                                     21-29
-------
that might  disperse  the kiln  dust.   High  winds did  not
occur,  so  the  project  did not  have  to be  halted at  any
time.

     After the closure  plan  was  accepted  by the  State  of
Texas,   Halff  Associates   acted  as  design  engineer  and
construction supervisor on behalf of  Trammell  Crow Company
for the  implementation  of  the  solidification  and disposal
process.   With  Trammell  Crow  Company's  approval,  Halff
Associates  combined  the solidification  and  disposal
process  with  the overall   site  grading  and drainage  that
was necessary  for  the entire  Traramell Crow  development
project.  Halff  Associates held  a  preconstruction meeting
for  prospective  contractors  to  explain  the  sludge
solidification process.  The  combined contract was awarded
to  the   low  bidder,  H.B.   Zachry  Company  of  San Antonio,
Texas.

     The  Zachry Company carried  out the  oil  sludge
solidification  process   on  the  smaller  ponds before
proceeding  to  Pond A.   Figure  4  illustrates the  sludge
solidification and disposal method in engineering drawings
prepared by Halff Associates.  These  drawings  were used to
describe  the  process   to  prospective  contractors.    The
first  step  was  to  excavate  the  southern  portion of  the
sludge disposal  pit  adjacent to Pond  C to a depth  of 12
feet (3.7 m) .   As  the  sludge was  excavated from the pond
in  small  portions,  the pit was  filled  in with  stale kiln
dust  and  the  mixture  compacted.    By testing a  small
portion  at  first,  the  field  engineers could determine how
the process  was  working  under  actual conditions  and  the
equipment operators  could  get an  idea  of  what  quantities
of  sludge and dust their equipment was capable of handling
most readily.  Hence, the exact ratios of kiln dust to oil
that  had  been  determined  in   the   laboratory  were  not
necessarily  valid  in the  field.   As long  as  the solidi-
fication  process  and compaction  yielded  appropriate
results  the  exact  ratios  were  not  necessary nor  were they
able to  be determined  as  both fresh and stale  dust were
used together.   Therefore, an overall  ratio  of  1.5  parts
kiln dust  to 1.0 parts oil was  determined  for  the entire
project.   The   solidification  process,  which  began  on
May 21,  1981,  is described in the  following steps:

     1.  The  sludge  disposal pit  was excavated  up to the
         edge of Pond C.

     2.  Stale   cement  ki In   dust  was  delivered  to  the
         bottom  of the excavated  pit in 25  ton (23 Mt.)
         truckloads.

     3.  The kiln dust  was leveled by a bulldozer  into a 6
         to  12 inch  (15 -  30 cm) layer.
                                     21-30
300.70(b)(2)-
(iiO(C)
solidification
-------
                                                TM( IW4TE dl SIUP<5E IN PONP*
                                                •»••£'*ND 'P- MUST 0G S0LIP1NED
                                                *NP STOCKPILE P TO ALLOW THE
                                                      PKTOSAL PIT TO BE
'	 MTMENT FO
         FOIf ITEM • 9
   •UNCLASSIFIED ore* fXCA
   SLUPOE DISPOSAL.' WILL BE BASED
   ON me CEos9-HAT<:nEp ABBA
                                                TYPICAL  SECTION
                                   DESIGNATED   SLUDGE  DISPOSAL  AREA
          AT THE ENP or EtCH wotrcwti PAT.
          THE coHifAcicK WIIL ee HELP
          ec«raM*iBLe rot MI DtcnAKQt
          or OIL OK eoNUMiMATeo i»»rei»
          INTO NAIUK41 Xtief COVIKt*
           I. 5L(IP6t WILL PC MIXEP IVIIft K'LM Pl>5T IN THE RATIO
            Of J  «MBT5 KILN DUST TO  1 «HT SLUMt  BT  WEIOHT

           r. me OPTIMUM  wowruee CONTENT OP THE MI* H«* BECM
            FOUND TO BE 46% BY MUTI-tHE^TEKN LABS, WITH A «TANP
            PPOCTOR PFM4HY UF 62 (b/fu Ft  ( OS* ION9/tf )

           ]. TElAL MIXES OF }:l KILN PU$T/«LUEtiE *MOW » MOI$TUKE
            CONTENT IMMEDIATELY AFTE* MMINa Of  **'/'.

           * KEOweeo  FIELP COMPACTION  WrLl. BE 96 K OF STANPARP
            PB(JCTOR PENtlTY . BBOUieEP UNCONriNCP COMPBE«lve
            ^TffENQTH  iv I LI BE  50OO lB/*d FT

           5 TMC  MIXEP 5LUPOE  I* TO BC *PEBAP AMP IMPACTED AT
            OEf'liMATED flEEA   IK 6-If CH LITTS . PROOF KOLLIN<3
            WILL  BE BtaurlteP AFTER EVEKY 2FEET OF  FILL.
                          PISPOSAL ABBA
Figure  4.    Proposed Sludge  Disposal Method
Source:       Albert  H.  Halff  Associates,  Inc.,  1981.
-------
     4.  The  oil  sludge was  removed  from the  ponds  by  a
         backhoe and placed on top of  the kiln  dust in  the
         disposal pit.

     5.  The  kiln dust  and  sludge  in  the disposal pit  was
         mixed by a bulldozer into 1 foot (0.30 m) layers.

     6.  A pulverizing  mixer  was then driven  over each  1
         foot (0.30 m)  layer  to  completely  homogenize  the
         mixture.

     7.  Each layer  of  dust/sludge mixture  air dried  for
         approximately one day.

     8.  Each layer  was  compacted  to  a  specified density
         and  field tested to ensure proper compaction.

     This  procedure was foliowed until all  of  the oil
sludge from the waste  ponds  C,  D,  and E had been emptied
and  solidified  in the  on-site  landfill.   The  old   ponds
were engulfed by the landfill.

     For  the  largest  sludge  pit,  Pond  A,   the solidifi-
cation process  was  modified,  since   the sludge  was  more
liquefied  and the  pond  itself  was several  thousand  feet
from the on-site landfill.  Because of its  more liquefied
nature,  the  sludge  was  solidified using both  fresh  and
stale kiln dust.  The procedure for solidifying the sludge
from Pond  A   incorporated  the  same layering  process  used
for  the  three  smaller  ponds, however, the  sludge was
treated  prior to  placement  in the on-site  landfill.    The
procedure used  for solidifying the sludge from Pond  A  was
as follows:

     1.  Fresh cetnent kiln dust was blown into sludge Pond
         A.

     2.  The   fresh  dust  was mixed  into  the  sludge  by a
         backhoe (this  semi-solidified the sludge).

     3.  The  semi-solidified sLudge was  loaded  into  a  -40
         cubic  yard   (3,040   m )  belly  dump  truck  and
         transported  to the on-site landfill.

     4.  The   semi-solidified  sludge  was dumped  into  the
         landfill and onto a bed  of stale kiln dust.

     5.  The  semi-solidified sludge was  mixed  in  the  same
         manner  as  outlined for the three smaller Ponds C,
         D, and  E.
                                     21-32
-------
      As  each  side  of  Pond A  was  excavated  the  pond was
 backfilled  with  clean  soil  until  all  of  the  sludge had
 been removed and  solidified  in the on-site landfill.  The
 coke/slag material  was removed  from  Pond B  and  mixed  in
 with the sludge in  the  on-site landfill.   Pond B was  then
 backfilled with soil.

      In order to ensure the quality of compaction, density
 tests  were  performed  daily  during  the  solidification
 process.  The results of some  of these tests  are  listed  in
 Table 9.   Proctor density tests were  run in a laboratory
 and  the  results  indicated that  the  3.0:1.0  kiln dust  to
 oil mixture would have a  Proctor  density  of 73.9 pounds
 per  cubic   foot  (1,182 kg/m  )  with  an   optimum  moisture
 content of  33.8  percent.   Based  on  the  Proctor density
 tests,  a compaction density of approximately  64 pounds per
 cubic foot  (1,024 kg/m  ) was  considered  to be the minimum
 acceptable  density.    As  Table  9   shows,   the  actual
 densities  of the  compacted  layers  were -.between 70  and 80
 pounds  per cubic  foot  (1,120-1,280 kg/m  );  well  above the
 acceptable  minimum  of  64  pounds  per cubic   foot  (1 024
 ,  /  -* \                      i       r                 \)
 kg/m ).

      The solidification process was completed by September
 1,  1981  c^:  within  75  working days.   Five  million gallons
 (1.9 x  10   1)  of  sludge were disposed  of  at an average of
 66,700  gallons (252,487 1)  per day  using  approximately
 41,000  tons (37,195 Mt.)  of cement kiln  dust.   This was
 much less  than the  75,000  tons (68,039 Mt.)  of kiln  dust
 originally  projected because the dust  solidified  with the
 sludge better in the field  than in  the laboratory.  There-
 fore, the  project  cost only $377,527.10 as  opposed  to the
 estimated  $500,000.   This is much  less than  the  off-site
 disposal alternative which would  have  cost  $1,500,000.

     Once the solidification process was completed a  layer
 of soil  from 3^to 5  feet (0.9 - 1.5 m)  was  placed  over the
 on-site  landfill to ensure  adequate  capping. The entire
 site  was then  completely graded   and  seeded   with grass.
 Unfortunately,  the grass  seed  was  planted  too late in the
 year and  did not grow.  However, the   site  was  naturally
 seeded  and  is   now  covered  with  wildflowers and weeds.
Presently, the  site  is adequate for building and is await-
 ing  future development within the Trammell Crow industrial
park.
300.70(b)(l)(ii)
(A)
surface seal

300.70(b)(l)(ii)
grading;
revegetation
                                     21-33
-------
        TABLE 9.  SOLIDIFIED OIL SLUDGE KILN DUST FIELD DENSITY  TESTS
Date
5/22/81
5/22/81
5/22/81
5/22/81
6/11/81
6/11/81
6/11/81
6/23/81
6/23/81
6/23/81
7/10/81
7/10/81
7/10/81
8/21/81
8/21/81
8/21/81
Field
moisture
(%)
36.5
37.5
35.2
35.4
35.2
40.4
41.4
30.7
28.7
34.4
36.0
35.8
34.2
33.3
37.2
36.2
Field
density
Clbs/cu.ft.)
79.0
78.2
81.6
81.2
75.2
71.2
74.7
77.9
74.3
74.9
72.3
73.3
73.4
74.9
74.1
74.4
Optimum
moisture
(%)
33.8
33.8
33.8
33.8
33.8
33.8
33.8
33.8
33.8
33.8
33.8
33.8
33.8
33.8
33.8
33.8
Proctor
density
(Ibs/cu.ft.)
73.9
73.9
73.9
73.9
73.9
73.9
73.9
73.9
73.9
73.9
73.9
73.9
73.9
73.9
73.9
73.9
Percent
density
106.9
105.8
110.4
109.9
102.2
96.2
101.1
105.4
100.5
101.4
97.8
99.2
99.3
101.4
100.3
100.7
Source:  Morgan, D.S.  Albert H. Halff Associates, Inc.,  1982.
                                     21-34
-------
 COST AND FUNDING

 Source of Funding

      The  solidification  and  landfilling costs were paid
 in  part  by  Traramell  Crow and  in  part  by the HUD and
 Dallas  grants.  However,  the  amounts that these sources
 contributed toward disposal costs cannot be given, because
 the grants subsidized the total infrastructure cost.

 Selection of Contractors

 Albert H. Halff Associates
      Trammell  Crow  hired  Albert  H.  Halff Associates  of
 Dallas, Texas   to design roads, sewers  and  surface water
 drainage for  the  entire 133 acre  (53.2 ha) site.   Halff
 also was responsible  for  analyzing  disposal alternatives,
 designing the remedial  action  plan,  submitting government
 applications,  monitoring  the  site,  and  supervising  the
 clean-up work.  Trammell  Crow  hired Halff based  on prior
 work and reputation.

 H.B. Zachry Company
      To save time and  reduce  costs, Halff  recommended  to
 Trammell  Crow  that   the  oil  sludge  solidification  and
 disposal work  be  included  in  the  grading  and  drainage
 contract for the  site.   Traramell  Crow agreed.  Acting  as
 owner's representative, Halff solicited bids for  the  work
 and  held  a  preconstruction  meeting  to inform  potential
 bidders about the  solidification procedures.   H.B.  Zachry
 Company,  of San Antonio, Texas  was selected as  low bidder.
 Although it  had  considerable  experience  with  road  and
 building construction, Zachry had never  done this  type  of
 waste  disposal.   One  reason  contributing to Zachry's  low
 bid ^ was the  fact  that  it had  most  of the required  heavy
 equipment available nearby.

 Project  Costs

 Engineering Feasibility Study-Solidification and Disposal
     Halff' s  fee  was  based on  a percentage  of  the  con-
 struction  costs.   The total  fee  cannot   be  determined
 because  construction  is still  in progress at the  site and
 the^percentage  used was not disclosed.  However, the  firm
 estimated that  the portion of its fee attributable to its
 engineering feasibility  study regarding  solidification and
 disposal  was  $50,000.    The  available  construction  cost
 information  relates   directly  to  solidification  and
 disposal of  the  sludge (see Table 10).   Included  are the
 costs  for  loading  the  kiln  dust,  transporting  it  to the
 site,  excavating,  capping  and  grading  the  landfill, and
manpower  and  equipment  used to  process  the   mixture of

                                     21-35
300.68(c)
responsible
party
-------
                          TABLE  10.   SUMMARY OF  COST INFORMATION-  TRAMMELL CROW COMPANY,  DALLAS,  TX.
Task
Loading
waste klLn
dust
Transport Ing
w.iate kiln
dust
Transporting
fresh kiln
dust
Excavation
of disposal
landfill,
capping and
L.ibor and
C'(|U Ipmi'lU CO
process
Subtotal
Engineering
feas. D!I ty
study so . Id-
Hlcatlun &
disposal
TOTAL
Estimated
Quantity



75,000 tons
(68,039 Ht.)



Actual
Quant Itv
29,435 tons
(26, 703 Ml.)
29,407 tons
(26,678 Ht.)
11,532 tons
(10,461 Ht.)
64,740 cu.yds
(49,500 cu.m.)
40,939 tons
(37,139 ML.)



Estimated
Expenditure




$500.000(o)


Actual
Expenditure
$14,717.50
$104,394.85
$69,192.00
$97,110.00
$92,112.75
$377,527.lO(d)
$50,000(e)
$427,527 .10(d)
Variance




$122, 472. 9C


Unit Coat
$0.50/ton
(S0.55/ Mt.)
53.55/ton
($3.91/Mc.)
$6. 00. ton
($6.61/Mt.)
$1.50/cu.yd.
($1.96/cu.m)
$2.25/ton
($2. US/Ml.)



Funding
Source (a)
Trammcll
Crow
Trammcll
Crow
Trammell
Crow
Trammell
Crow
Trammell
Crow

Trammell
Crow
Trammell
Crow
Period of
I'erform.ince






4/21/81-
9/1/81
r-j
i—'
I
                                 (a) portion of funds provided by  UDAC
                                    and City of Dallas grant

                                 (b) coat Is for kiln duat aa delivered
                                    to site, which  Includes coat  of
                                    purchasing kiln dust.
(c) does not Include engineering fee paid
   to Albert II.  1'nlff Associates,  Inc.

(d) does not include bonua of $34,061.00 paid
   to H.B. Zachry  Co.
                                                                                 (e) estimate by Albert H.  Halff Associates,  Inc.

                                                SOURCE: Morgan,  D.S. Albert H.  Halff Associates,  Inc.,ilo82
-------
 sludge  and  dust.  Halff  Associates  calculated both total
 and  unit  costs  for each  activity  as  part  of its planning
 and  supervisory work.

      The key to controlling costs  for this remedial action
 was  the amount of  kiln  dust  required.   With the exception
 of excavation of the landfill, the cost of  each remedial
 activity was directly affected by the tonnage of kiln dust
 involved.   Consequently,  the costs  of these  activities
 could be  controlled  by  limiting  the  amount of  kiln dust
 used.  Halff took advantage of this situation by inserting
 an interesting provision  in the contract with Zachry:  the
 contractor was paid a bonus of $1 per ton ($0.907/Mt.) for
 each ton  of  dust not used in the  solidification process.
 This reversed  the economic   incentives  for  Zachry,  from
 using as  much kiln dust  as possible  to  maximize loading,
 transportation and processing charges  to using  as  little
 as possible to cut its  costs  and earn  the  bonus.  Regard-
 less of the amount used, the  solidification process  had to
 conform to Halff's workplan  and the  results had to  meet
 Halff's  specifications  for mixture  and compaction.

      Because  the  solidification technique worked  better in
 the  field than  the  laboratory,  only  40,939 tons  (37,139
 Mt.)  of  kiln dust were  used,  only  55% of  the  original
 estimate of  75,000  tons  (68,039  Mt).   This  is about  a
 1.5:1.0  ratio of  dust  to  sludge,  rather than  the 3.0:1.0
 ratio originally  estimated.   Reduced  tonnage  resulted  in  a
 total cost of $377,527.10,  compared  to an estimated  cost
 of $500,000.   Zachry received a bonus  of  $34,061,  while
 Trammell  Crow had  the  job done  for  $88,411.90  less  than
 estimated.  Even  when the bonus is  figured as  part  of  the
 cost  of  solidification,  this  only   totals  $411,588.10,
 which is  less  than  one-third  of  the  cost  of off-site
 disposal, which was estimated  to be $1,500,000.

 Capping, Grading  and  Seeding;  General Drainage  Work
      The  contract  with  Zachry  included within  the same
 category  the  tasks of  excavating  the  disposal  landfill,
 capping  it  and   grading  it,  as  well   as   general site
 preparation such  as construction  of the  building pads  and
 drainage channel.   Zachry  bid the entire category of work
 at  $1.50  per  cubic yard ($1.15/mJ).   The cost  of seeding
 was not  included  in Zachry's  bid  and  no data on  this item
 are available.
PERFORMANCE EVALUATION

     The remedial  action that was  taken at  the Traramell
Crow  site   entailed  detailed  and  innovative design  and
implementation.    These  observations  are  made  after

                                     21-37
-------
visiting  the  site,  viewing  a  videotape  of  the  actual
solidification process, and discussing the remedial action
with  representatives  of  Halff  Associates,  TrammeLl  Crow
Company, and the Texas Department of Water Resources.  Not
only  did  Halff Assoc iates devise a method  to correct the
problem of the sludge ponds on the property, but also they
implemented  a  plan which  recovered  the  land  for further
use in a cost-effective, timely, and novel manner.

      Because this  remedial  action  was a voluntary planned
response with no strict time constraints, Halff Associates
was able to  thoroughly investigate all of the alternatives
which  were  available  for  remediation.    Halff Associates
recommended  the corrective action for this particular site
only  after carefully evaluating  all  of  the options avail-
able,  keeping  in  mind  the  interests of  their  client and
government   regulations.  Once   preliminary  tests  showed
solidification  to  be  a  viable  alternative,  Halff Asso-
ciates  performed   extensive  tests  to  determine  the  best
solidification  materials  based on   technical  stability,
cost,  and supply.    Halff Associates  then  took  this one
step   further  when  determinations  found  that  the  best
sol id ification  material,  fresh  cement  kiln dust,  was   in
short  supply.   They   tested  to  see  whether  or not   a
material  such  as  waste kiln dust,  originally believed  to
be  ineffective,  would  indeed  be effective.   The  results
show  that this was indeed worthwhile.

      The  Trammell  Crow Company and Halff  Associates showed
responsibility  and cooperation  in  this  remedial  action.
Care  was taken  to ensure  that the  appropriate  Federal,
state,  and  local  officials were  contacted  and  that  the
work  performed at  the  site  was  acceptable at  each  level.
Once  it  was  determined  that  the  waste oil was  not  EP  toxic
and  did  not  fail  within  the limits   of  RCRA,  Halff
Associates maintained  close  communications with the  Texas
Department   of  Water  Resources and  the City  of Dallas
Health Department  to  ensure  that the Class  II  wastes were
handled   correctly  and  that  the   solidification  process
posed no  threat to human  health  or the  environment.   Prior
to  the  sol id i f ic a t i on  and  remova 1 o f  the was te oil from
the  sludge  ponds,  numerous  carcasses  of  dead  waterfowl
were   found  along  the  banks  of  the  sludge.    With  the
removal  of  these ponds,  this  threat  to  local and  migrating
waterfowl  is no  longer  present.

      From a  technical  perspective, the site  is  stable  and
ready  to  be  developed.    The  solidification  technique
worked better  in  the  field than in the laboratory.   It  is
impossible  to  tell by  looking  at the  site that  the solidi-
fied  on-site  disposal  area contains  oil sludge  material
                                      21-38
-------
 and  that the capped  area,  formerly Pond A,  contained  oil
 sludge.

      One area  of  potential  concern  is  the  long-term
 stability of  the  solidified  sludge.   It  is  not possible to
 determine  whether  or  not the  kiln  dust  and sludge  will
 indeed  remain intact.  Perhaps some type of  monitoring or
 sampling could  be  conducted  periodically  to  determine
 whether  or  not  there  is  any  actual  leaching  from  the
 on-site  landfill.

      Another  area  of potential concern  is the  former  Pond
 A,  now  a capped  site.   The site is  graded  over  and  the
 soil  cover  rises above ground  level  approximately 6 inches
 (15 cm).  On  top of the cap  was quite  a  bit of water which
 had  remained  after  a heavy  -rain.    The  water  did  not
 evaporate quickly,  nor did it drain readily.   Upon closer
 examination,  it was concluded  that there was  no  need to go
 to  the   expense of  further drainage of  this   area  because
 there is no apparent  threat  to  percolation  of contaminants
 reaching the  Woodbine  aquifer,  as  the clay layers  are
 impermeable.   Secondly,  the  site will  have  to be  graded
 and  drained  prior  to  construction,  at  which  time   any
 puddles  of water will  be  removed.

      If  these puddles do persist  for  long periods  of  time
 between  rainfall,  and  construction  is not  imminent,  then
 improvement of the  site drainage  would be prudent.   Other-
 wise,  the  solidification and  capping  at  the  site   are
 effective.

     The Trammell  Crow site  is  an example of a  remedial
 action   in  which  careful planning  and  investigation  of
 numerous alternatives  led to a successful  clean-up.  This
 action not only corrected a problem waste site, but  turned
 it into  one with potential for an economic return.

     The scientists  and engineers at Halff Associates  are
 convinced that  the  technique  used  at  the Trammell Crow
 site  is  applicable  to  many oil  sludge sites  where   the
waste is hazardous  by  definition under RCRA.   Addition-
ally,  the concept  that a substance  not  yet proven  (stale
kiln dust in  this  case)  may  be  worth trying  on  a  proven
process  is  one that   should be  considered more  often by
 industry.  Therefore,  it  is  important  for  decision  makers
to realize  that the   techniques  now  known for remedying
hazardous waste sites  are by no means  the  only techniques
that  will prove successful.
                                     21-39
-------
                                 BIBLIOGRAPHY


Albert H. HaLff Associates, Inc.   August 9, 1982.   Case Study Site Visit Made
   to Albert H. Halff Associates, Inc.,  and Trammell Crow Site.  Personal
   visit with Dr. Albert H. Halff, Mr.  Patrick Jolly, and Mr. Jim Pritchard of
   Albert H. Halff Associates, Inc., Dallas, TX.

Albert H. Halff Associates, Inc.   April  1981.  Contract Documents, Specifica-
   tions and General Conditions of Agreement for Site Grading, Street, Channel
   Excavation, and Oil Sludge Solidification in Turnpike Distribution Center,
   Phase II, Dallas Texas Trammell Crow Company No. 60.  Albert H. Halff
   Associates, Inc., Dallas, TX.

Albert H. Halff Associates, Inc.   1981.   Assorted Engineering and Site
   Diagrams of Turnpike Distribution Center for Trammell Crow Company,
   Dallas, TX.

Dallas Geological Society.  December 1965.  The Geology of Dallas County.
   Symposium on Surface and Subsurface Geology, Gravity, Physiography,
   Underground Water Supply, Economic Geology and Engineering Geology of
   Dallas County, Dallas, TX.

Eubanks, Don.  September 27, 1982.  Personal Communication.  Texas Department
   of Water Resources, Austin, TX.

Morgan,  David  S.  September 1982-January 1983.  Personal Communication.
   Albert H. Halff Associates, Inc., Dallas, TX.

Morgan,  David  S., Jose I. Novoa,  and Albert H.  Halff.  August  1982.   Solidifi-
   cation of Oil  Sludge Surface  Impoundments with Cement Kiln Dust (draft
   pending  publication).  Albert  H. Halff  Associates,  Inc.,  Dallas, TX.

Morgan,  David  S.  April 1982.  Surface  Impoundment  Cleanup.  Waste Age.
   13:99-102.

Myers,  J. Marc.   August 9,  1982.  Case  Study  Site Visit  to Trammell Crow
   Company, Dallas,  TX.

Soil Conservation Service.  February 1980.   Soil Survey  of Dallas County,  TX.
   U.S.  Department  of  Agriculture in Cooperation with  Texas  Agricultural
   Exper iraent  Stat ion.
                                      21-40
-------
                              UNIVERSITY OF IDAHO

                                 MOSCOW, IDAHO
 INTRODUCTION                                                NCP
                                                             References
      A  chemical   waste   disposal   site   located   on
 University  of Idaho (Ul) property  in Moscow,  Idaho (see
 Figure 1)   was  used from  1972 to  1979 for disposal  of
 various  chemical  wastes  from  the  university  campus.
 Concern  over  the  site  was  prompted  by  the  City  of
 Moscow's proposal  to sink  a new municipal well about 800
 feet  (244  m) away from the  site.   When the City applied
 to  the state Department of  Health  and Welfare (DHW)  for
 a permit to sink the well,  DHW denied the permit because
 of  the lack of information  about the possible threat  of
 ground   water    contamination   from    the    hazardous
 chemicals.    DHW  further stated that the proximity of the
 hazardous waste  dump  to the university1s existing  wells
 located  approximately   300   feet  (91  m) from the  site
 jeopardized  the  approval  status  of  the   university's
 water  system.   The disposal site (shown in Figures  1-3)
 consisted  of 11  trenches  located  on a small  hillside.
At  the  time of  site closure in 1979,  the site contained
 approximately  10  to  15  tons  (9-14  Mt) of pesticides,
 acids,  mixed  solvents,  and  miscellaneous   laboratory
wastes.

Background

     In  1975,   the  Environmental  Protection  Agency
approved  a  chemical   waste   dump   constructed  by  the
University  of Idaho for disposal  of miscellaneous wastes
from  campus  laboratories   and   physical   plant  opera-
tions.  About 10-15 tons (9-14 Mt)  of wastes were dumped
into 11 backhoe-dug trenches in  an 80 by 40 foot (24  by
12 m)  fenced in  area  (Figure 3).   The  disposal site was
located on campus  agricultural land adjacent to a nearby
shopping center (Figure 2).
                                     22-1
-------
Figure 1.  "Former Disposal Site Location, University of  Idaho,
           Moscow
                               FORMER DISPOSAL
                                SITE LOCATION
                                                 »i •..•t_==.-=j' m- v \
                                                 J. lt^^-; •^V>^
                                                 mSiitf^r^ -
                             22-2
-------
     Figure 2.  Former Disposal Site and Supply Well Locations
                                 ORMER DISPOSAL SITE
                                                    of I
                                                 SUPPLY WELL
                                   U of \E
                                   WELL
PROPOSED CITY
         WELL
                                  —=^
         PALOUSE EMPIRE MALL
SEWAGE
PLANT
                            22-3
-------
Figure  3.  Monitoring Wells and Trench Location
               #7
             Fence
                   #11
                    *
                           #10
                           #12
                                               \
                                               N
 Trench

   area
#9
                                Gat'e
                         #2
                                     #1
                        22-4
-------
     The City of Moscow  had  planned  to  locate  a new city
water well  some 800  feet (244  m)  away  from the site,  but
was  denied  approval  by DHW based  on  the lack of informa-
tion about  possible  ground water contamination  from  the
dump  site.    Furthermore,  because  two  university  wells
were also located  approximately 300  feet  (91 m)  from the
site,  DHW  determined  that  the  approval  status of  the
university's water system was  in jeopardy.  In order to
clarify approval  status  of the university's well and to
secure approval for  the  municipal well,  DHW requested a
study to address  the geology and  ground water  conditions
at the dump site and surrounding vicinity.

^ynopsis of Site Response

     A testing  program was  entered  into jointly by  the
university  and the city  in response  to  DHW's request  for
a   hydrogeological  study.     Environmental   Emergency
Services  Inc.  (EES) was hired to  drill  test  wells  and
report the  soil conditions,  including  the probability of
migration beyond  the site.  EES reported a  very limited
and  minor   migration  (discussed   in  "Description   of
Contamination"   section),   but   recommended   that   the
chemicals be  removed before  drilling   a  new well.    The
University  of  Idaho decided  to  proceed  with  excavation
of the buried  chemicals  and contracted with EES for  the
excavation  and  removal   of  chemicals  and  contaminated
soil.   EES  excavated  a  total of 817  cubic  yards  (625
m ).  The contaminated material was  taken to an approved
disposal  facility  at  a  site near  Arlington,  Oregon,
owned  by  the  State  of  Oregon  and  operated  by   Chem
Security  Systems,  Inc.   The  land  was back-filled  with
clean  fill  by    the  University   of   Idaho,   and   was
cultivated with an alfalfa crop.

Surface Characteristics

     Moscow, Idaho (population 16,513) is  situated  west
of   the   Bitteroot  Mountains  in  northwestern   Idaho
bordering with  Washington,  75 miles (120 km)  southeast
of  Spokane, Washington.    Moscow is at  an  elevation of
2,550  to  2,650   feet  (777   to  808 m).    The  average
temperature  ranges from  a high  of  83.4  degrees F  (28.5
C)  in  July  to a  low of 22.1  F  (-5.5C)  in  January.   On
the  average  there  are  11 days  per year with temperatures
reaching  90 F (32.2°C)  or higher  and  only 3  days  when
the  temperature   falls  to  0  F  (-17.8  C)  or below.
Relative  humidity  is   highest   in  the  winter months
ranging from 65  to  80%.   The  humidity is  lowest in the
summer  months  ranging  from  25  to 75%  with  afternoon
values 25  to 40%.   Damaging winds are  infrequent but do
occasionally  occur with  thunderstorms  during  the winter
months.   Winds usually  range  12  miles (19  km)  per hour
300.65(a)(4)
discovery

300.68(f)
remedial
investigation
300.68(f)
assessing the
use of source
control remedial
action
300.68(e)(2)
(i)(E)
climate
                                      22-5
-------
or less.   The greatest frequency of fog,  low visibility
and  low  clouds  is  during  November  through  February.
Average  snowfall each  season  is  53.2  inches (135  cm)
most of  which occurs in the winter and  spring.   Average
annual  precipitation is  22.21  inches (56.4  cm).    The
disposal  site  itself is situated at a slight  slope  on a
50 foot  (15  m)  hilltop at an elevation  of approximately
2600 feet.

Hydrogeology

     The  following  description  is  drawn  from a  report
made by a consulting geologist to the City of Moscow.

     The  area in the vicinity of  the disposal  site  is    300.68(e) C2)
underlain  by  a  large   thickness  of  mostly  basalt    (i)(P)
overlying  a  granitic  basement  rock.    The  basalt  and   hydrogeological
intercollated  sediments form  the  primary aquifers  for    factors
the cities  of Moscow  and  Pullman.   Wind  blown  silt  or
loess   overlies  the   basalt,   resulting  in   a   low
permeability  of the soil,  since loess  has  a  uniformly
low hydraulic conductivity.   The driller's log from the
university well  describes  the geologic material some 300
feet (91 m)  from the disposal  site.  This  data indicates
that basalt  was  first  intercepted 11  feet (3.4 m) below
land surface.    Given  that  the  basalt  level  is fairly
even in  the  immediate vicinity of the  disposal site,  the
depth to basalt  at the  disposal  site would thus be about
60  feet  (18.3  m).    The  elevation at  the   top  of  the
university well  is  about 2560 feet  (780 m);  at  the  top
of the  hill,  2610 feet  (796 m).   The  University  well  is
drilled  to  a depth of 747  feet,  deriving  water  from
depths greater  than  600  feet (183 m) with  a static depth
to water greater than 200 feet  (61  m).   Thus the depth
to water below the disposal  site is 600 feet (183 m) .

WASTE DISPOSAL HISTORY

     The  University  of Idaho  chemical  waste  dump  was
used for the disposal  of  chemicals from  1972 to 1979.
Approximately  10  to  15   tons  (9-14  Mt.)  of chemical
wastes   were  disposed  of   into  13   foot (4 m)   deep
trenches, which were dug with  a backhoe.   The disposal
site consist  of 11  trenches contained within  a 80 by  40
foot  fence  (24  by  12  m).   UI  records indicated  that
large    volumes   of   organic    solvents,    herbicides,
insecticides,  pesticides,   and  inorganic  chemicals  had
been indiscriminately  deposited within  the  cells.   The
trenches  were  unlined,  and  many  of  the  containers  in
which  chemicals  were  stored had  ruptured  and  leaked
contaminants  in the  trenches.  In  addition it is highly
probable   that   the   mixing  of  chemicals   within   the
trenches  altered the compounds to  substances  other  than

                                     22-6
-------
 those  recorded  on the  UI  disposal  sheets.   A  complete
 inventory of  the waste  was  kept by  the Safety Control
 Officer and turned over to the state of Idaho.

      In  1979   the  site  was  closed,  and  an alternate
 disposal method was arranged for at an off-site  approved
 facility.   The  City  of Moscow  had  been denied  approval
 by DHW  for a  proposed well to  be  located some 800 feet
 (244 m) from  the  site.   The  DHW further determined that
 the  proximity   of   the  site  to   UI' s   water  system
 jeopardized  the  university's   approval   status  of  and
 requested   a   complete   hydrogeological   study  of  the
 problem by the university.

 DESCRIPTION OF CONTAMINATION

      EES carried out  a testing program from May 27 - 30,
 1981  to determine the  extent  of migration  of chemicals
 that  were  buried  at  the site.   As  shown in  Figure  3,
 thirteen test  wells were drilled at various locations in
 the  area  of  the  site,  and soil  samples were  analyzed
 using  a uniform testing  system.    The  results  of  all
 tests  performed were  below detectable  limits for  each
 contaminant with the  exception of  copper and  arsenic.
 The   unusual   elevation  for  these  two   elements   was
 attributed  to  the  lubricant  used on  the drill  itself.
 The  lubricant  was shown  to have been  made of a copper
 material with an arsenic component.

     Table  1  shows  the  results  of  EES's  soil   test
 analysis for each  of  the four groups used  to  screen  for
 persistent compounds.    Thirteen multi-level  monitoring
wells were drilled with screen ranges of 6 feet  (1.8 m)
 to 38  feet (11.6  m) .   The four groups of contaminants
 tested for were divided as follows.

    Group 1.   Organic  phosphorous pesticides—This group
              includes Class A poisons;  compounds which
              are extremely  toxic but  relatively short
              lived.     Detectable   level,   less   than   1
             ug/g-

    Group 2.  Heavy metals—This group includes lead,
             copper,   mercury,  and   arsenic.    These
             materials  do  not   degrade  and  can  be
             expected   to   migrate   through   water.
             Detectable level,  less  than 1 ug/Kg.

    Group 3.  Chlorinated pesticides—In addition to
             pesticides,     this     group     includes
             phenoxyherbicides   and  PCBs.    Detectable
             limits,  1 ug/kg.
300.68(f)
sampling and
monitoring
                                     22-7
-------
TABLE 1.  RESULTS OF SOIL SAMPLES TAKEN PRIOR TO EXCAVATION
Sample #
1
2
3
4
5
6
7
8
9
10
11
12
13
Group 1
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
Group 2 (mg/kg)
Hg Cu Pb As
bdl 9.7 bdl .9
bdl 7.4 bdl .9
bdl 6.6 bdl .6
bdl 6.8 bdl .9
bdl 7.7 bdl .9
bdl 6.4 bdl .8
bdl 5.6 bdl .6
bdl 4.7 bdl .7
bdl 6.0 bdl .9
bdl 6.7 bdl .9
bdl 8.6 bdl 1.0
bdl 5.4 bdl .8
bdl 6.3 bdl .5
Group 3
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
Group 4
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
bdl
   Key:    bdl-    below detectable limits
          Hg-     Mercury
          Cu-     Copper
          Pb-     Lead
          As-     Arsenic

   Source:  Environmental Emergency Services,  "Report on
   Site  Investigation  at  the  Old  UI  Chemical  Waste
   Deposit Site,"  June 3, 1981.
                              22-8
-------
      Group  4.   Solvents—This  group  contains  carbon
                tetrachloride  and benzene,  in addition to
                other  suspected  solvents.    Phenols  were
                also added  to  this  group at the request of
                the  State  of   Idaho.   Detectable  limits,
                less than 1 ug/Kg.

      With   the   exception   of   copper   and   arsenic
 contamination, which was  determined to be an artifact of
 the  lubricant  used  on the  drill,  all  contaminants  were
 shown  to  be   below  detectable  limits.    In  addition,
 although  data on  contaminant  levels  was  presented  in
 terms  of  detectable  limits  and   not  drinking  water
 standards,  the  EES   report  indicated   that   chemical
 concentrations were also  below safe  drinking  standards,
 with the  exception  of copper and  arsenic  for the  same
 reason as  previously mentioned.   In  order to  remove  any
 possible  future  threat of  migration  of chemicals,  EES
 recommended that  the  hazardous  waste  be excavated  and
 removed from the  site.

 PLANNING THE SITE RESPONSE

 Initiation of  Response

      Concern over the  site was prompted when the  City of
 Moscow  was  denied  approval  by DHW  to  sink a  new city
 water well some  800  feet  (244 m)  from the  site.   In a
 letter  of April  17,  1981, DHW  requested the University
 of  Idaho  to  arrange a  study  to  "address  the geology,
 soil  characteristics,  topography, and ground water flow
 at   the   dump   site  and   surrounding  vicinity."    This
 information would then be  used to  determine the safety
 of  both  the  university   wells and  the  proposed  city
 well.   The University  responded by  soliciting proposals
 from  EES  and  two  other  firms  for soil testing and clean-
 up.   Time  considerations  were given  a  high  priority in
 order  to  minimize   further  delay   in  sinking  the  new
 municipal well.

 Selection of Response Technologies

     The  response alternatives  considered  by UI  were:
 (1)  complete  removal   of  contaminated  soil,  and  (2)
 encapsulation  of  the site.    Encapsulation  of the  site
 would involve installing an  impervious cap over the  site
with  layers  of  sand,  PVC liners and  crushed  rock.   This
 option  would  have been  only  a  temporary measure  which
would only  postpone  ultimate  removal  of the soil.   The
University  of  Idaho  determined   that   complete  waste
removal was in the  best  overall  interests  of all  the
parties concerned.  Although  DHW was  prepared  to  accept
some alternative  plan  for waste containment, UI made  a
300.68(e)(2)
source control
remedial
action
300.68(g)
development
of alternatives
                                     22-9
-------
decision   for   complete   removal   based   on   several
factors:   the  possible  threat  of  future  migration  of
chemicals  to  the water supply,   the detrimental  future
impact  that   the buried  materials  might  have  on the
development of  the  property by  the  university, and the
cost  of continued  monitoring that  would  be  necessary
without complete removal.

     Given UI' s  goal   of  complete  waste  removal, the
appropriate   remedial    technology    was    excavation,
transportation,    and   disposal   of   chemicals   and
contaminated   soils.    On  June  8,   1981,  UI  signed  an
"Hazardous Substance  Excavation  and Removal  Agreement"
with  Environmental   Emergency Services,     The  parties
contracted to:

    •  remove the soil  at  the  site to a depth of  13 feet
       from  the  original  grade  (estimated  600  to 900
       cubic  yards (459 to 688 nT);

    •  to  transport all excavated soil  to Chem Security
       Systems in Arlington, Oregon for disposal; and

    •  to  take  soil samples  from the bottom and sides  of
       the excavation as  are necessary to determine that
       the hazardous waste materials do not remain.

Extent of Response

     From  July  18 to 25,  1981,  approximately  817  cubic
yards of chemicals waste,  contaminated soils, and debris
were excavated  from the UI site.  The site  was excavated
to  an  undetermined  depth, exceeding 13 ft  (4 m),  and  25
cubic  yard (19   m )  dump   trucks  were  used  to transport
the  contaminated material  to  an  approved  dump  site  in
Arlington, Oregon operated by Chem  Security  Systems  and
owned  by  the  state  of Oregon.    The  resultant  pit  was
divided  into  grids  from  which soil  samples  were taken.
When  the  digging was  stopped, the soil concentration of
each  hazardous   substance  was  less  than  10  ug/g,  which
was  the interim  drinking  water  standard  for  2,4  - D  at
the  time.  The  EES  report to UI made on August 21, 1981
provided the  following  conclusion:  "Although evidence of
contamination  still  exists,  the  levels  are relatively
minor  and  represent no danger to nearby water sources.
The  concentrations  of  contaminants  found   represent  an
insignificant volume  of material which will  most likely
remain  bound  in the soil  until it  ultimately  degrades."

     Table 2 shows  the  results  of soil  samples taken
following  the  excavation as  reported  by  EES to  UI  on
August  21,  1981.   The City  of Moscow  built  the water
well,  and  the disposal  site  is now covered  with an
300.68(h)
initial
screening of
•alternatives
 300.68(j)
 extent of
 remedy
                                     22-10
-------
      TABLE  2.   RESULTS OF  SOIL TAKEN FOLLOWING EXCAVATION
                               (ug/g)
Ident.


#1
#2
#3
#4

#5
#6
#7
#8
#9
#10
#11
Cu


5.0
5.5
5.1
6.0

5.4
5.1
5.1
9,6
5.7
6.7
9.8
As


1.0
1.1
1.0
1.6

1.7
1.5
1.2
1.3
1.4
1.5
1.9
Hg


ND*
ND
ND
ND

ND
ND
0.24
0.62
0.26
1.2
1.5
Pb


ND*
ND
ND
ND

ND
ND
ND
ND
ND
0.5
0.4
Chlorinated
Ionic

ND*
ND
ND
2.0(2,4-D)

ND
ND
ND
0.4(2,4-0)
ND*
ND
0.1(2,4-0)
Pesticides
Chlorinated
Non- ionic
ND*
ND
ND
5.8 (DDT)

0.2 (dieldrin)
0.8 (aldrin)
5.1 (dieldrin)
ND
0.8 (DDT)
ND
ND
2.0 (dieldrin)
1.1 (DDT)

0-P (b)

ND*
ND
ND
(trace)
(a)
ND
ND
ND
ND
ND
ND
ND
Cu = Copper
As * Arsenic
Hg = Mercury
Pb - Lead
(a)     Disyston found to be present
        but could not be quatititated.

* Minimum detectable limit =0.1 mg/kg
   except lead =0.2 mg/kg
ND=  None Detected
             (b) organophosphate pesticides
                                 22-11
-------
  alfalfa  crop  which 3 harvests a year  which  are  used for
  cattle  feed.    Although the  Idaho  Department of  Health
  and Welfare had informed  the university there is no need
  for^ futher monitoring  of  any of  the  test wells,  the
  monitoring wells  are still maintained  and are available
  for   field  lab  experience  by  hydrology   classes  on
  campus.    Students  can  gain  experience in testing  in
  ground water  contamination,  and at  the same  time provide
  frequent inexpensive monitoring.

 DESIGN AND EXECUTION OF SITE RESPONSE

      The  basic components  of  the  remedial  action  are
  listed  and  described  in  the  following  sections.    The
 response  action at  this  site was  straight  forward  and
 without complication.

 Sampling, Testing, and Analysis

      The first  part  or Phase  I of  the remedial action
 involved drilling  a  series  of 13 test holes and taking
 soil   samples   at   various   depths.     The  samples   were
 analyzed by a  certified  laboratory using EPA approved
 procedures.  Soil samples  were taken from depths ranging
 from  6 feet to  38  feet  (1.8 - 11.6 m)  and  at locations
 agreed upon by EES and UI.  The drilling took place  from
 May  27  to  May  30,   1981.    Samples  were   analyzed to
 determine   the  occurrence   of  any  gross  migration  of
 chemicals  or  possibility  of such migration  which might
 affect the drilling  of the proposed  water  well  on UI
 property.   The  samples were analyzed  specifically for
 the  hazardous  materials  listed by  the University of
 Idaho  in the  request  for  proposal.   The  tests were not
 designed  to  test for  the presence  of naturally occurring
 elemental   materials   inherent  in   the  soils.     The
 suspected  chemicals  were  divided  into  four groups  to
 screen for long lived  toxic  compounds  associated  with
 hydrophopic and  hydrophilic  leachate materials.   Results
 of  these   tests  are  given   in  the   "Description  of
 Contamination"  section.   All  four groups were shown to
 be below  detectable limits with the  exception of copper
 and arsenic  in  the heavy metals  group.   The elevated
 levels  for copper and  arsenic were  determined to  be
 erroneous  due  to  contamination from the  lubricant  used
 on  the  drill   itself.    Gross  migration  of  chemicals
 beyond the boundaries of the  site was not  found.

Excavation, ^Transportation, Disposal

     In  accordance  with  the  Excavation and   Removal
Agreement,  EES  excavated  817  cubic yards (625  m  )  of
 chemicals  and  contaminated  soils  from July  18  to  25,
 1981.   Soil  removal was accomplished with a  Caterpillar
 300.70(b)(l)
 (ii)(D)
 revegetation
300.68(f)
remedial
investigation
300.70(c)(2)
(i) removal
of contaminated
soils
                                     22-12
-------
 30  ft  (9 m)  arm  backhoe with  a 2  cubic  yard (1.5 m^)
 bucket.   The contaminated  soil  was placed  in 25  cubic
 yard (19  m ) dump  trucks  that  had  been  lined and made
 water  tight.   The  trucks  were   then covered and sealed
 after  loading.    The  contaminated  materials  were  then
 transported  to  Chem  Security  Systems   in  Arlington,
 Oregon  for disposal.  This  is an approved  facility  owned
 by the  State  of Oregon.   The contract provided that all
 work be   done  in  accordance  with  federal  and   state
 regulations.

 Post-Excavation Soil Analysis

      Following  the   excavation,  11  soil  samples  were
 taken from predetermined  locations  within the resulting
 pit.    The  results  of  these tests  are presented  in the
 "Extent of Response"  section,  showing relatively minor
 levels  of remaining contamination.    This  follow-up  soil
 analysis  was  done  in accordance with the  contract signed
 between EES and  UI.

      The  pit  was backfilled by the  university with clean
 fill  taken from a  construction site on campus.  The site
 is  now  covered with  an  alfalfa crop.

 COST  AND  FUNDING

 Source  of  Funding

      The  total cost  of Phase I of  the  remedial action—
 the  initial  sampling  testing,  and  analysis—was  shared
 equally  by  the University   of  Idaho  and the  City  of
 Moscow,   providing  $9119  each  for  a total  of  $18,237.
 Phase II  cost $156,660 and  was  paid for  entirely by  UI
 out of  the  facilities capital improvement  fund.

 Selection of  Contractors

     On May  14, 1981,  UI  formally  requested proposals
 from  three companies  for site clean-up  and   testing  of
 soil  in  the   vicinity  of  the  site.   The request  for
 proposal  specified that  costs  for  excavation,  loading,
 transport,  and disposal  shall be quoted on a cubic  yard
 (ra )  basis,   and costs  for  the   initial  report on  soil
 conditions be  quoted  on a lump sum  basis.   Environmental
Emergency   Services   of  Portland,    Oregon  was   chosen
because  it had  both the   lowest  estimate   and  technical
qualifications.    EES  estimated the  excavation  would
 involve  removing 600 to 900 cubic yards (459  to 688 m )
and  quoted a  price  of $192 per cubic yard  ($147/nr).
The  Phase  I   estimate  was  originally  $13,435  but was
increased  to  $18,237  to  accommodate UI requests  to
increase test  hole depth, take additional  soil  samples,
300.70(c)
off-site
transport
for secure
disposition
300.62(a)
state role
in response
                                     22-13
-------
and  perform   additional  contaminant   testing.     The
contract  for  Phase I was  signed on May  28,  1981.   The
contract for Phase II was signed on July 8, 1981.

Project Costs

     The   total   cost   of   the   Moscow  clean-up  was
$174,897.  Precise  cost  breakdown of each of the clean-
up elements is not possible because of the lump sum and
cubic yard (m )  basis  on which costs were estimated and
billed  to the  university.    The $192  per  cubic  yard
($147/m )  included the  entire volume  of activities  in
Phase  II,  totalling $156,660.   Table  3 summarizes the
cost information  for Phase  I  and II.   One invoice was
submitted for each phase  simply  providing totals for the
work completed.

PERFORMANCE EVALUATION
     The   streamlining   of  this  particular   clean-up
benefited  from the cooperation  between  federal, state,
and university officials.   The full  range of  response  to
the  site was accomplished  in  3   /2  months,  from  April
17, 1981  when DHW denied a permit to the City  of Moscow
for a new well to August 3,  1981 when DHW pronounced the
area  safe  for   future  activity.    The  work  done   by
Environmental Emergency  Services  was  accomplished within
the  contractual   time  frames  and was  highly  regarded.
Delays  in the response  action were  avoided  due to the
willingness  of the University of Idaho  to  pay for the
clean-up.   The City of  Moscow proceeded with  construc-
tion of  the new water well.
                                      22-14
-------
                  TABLE 3.  SUMMARY  OF COST INFORMATION FOR MOSCOW,  IDAHO
Task
Test In)1,,
Drilling, ami
sampl 1 t\K of
contaminated
soil (l'h.is« I)
Excavation,
Transportation,
and disposal



Total
quantity
—
817 cu.
yards
(625 m3)




Mst i ma led
Expenditure
$18,237
3192/c.u.yd
($251/m3)




Actual
Expend I turi'
$18,237
$156,660



$174,897
Variance
0
0




Unit Cost
—
$192/cii. yd.




Kundlnt; Source
City of Musrow:
Univ. of Idaho:
Univ. of l.l.ilio




Perl oil of
Performance
May 27-
.Inne 3.1981
t'xcav.i t Ion ,
t ran^porta-
l Ion disposal
July 1H-23,
1'JHl
Tina) soil
submit 1 od
AUR. 21.19H1

ho
ro
I
                —  ; Not Applicable
-------
                           BIBLIOGRAPHY
 Environmental  Emergency  Services  Company, Portland, Oregon.
    "Proposal  for  Removal and Disposal  of Hazardous Materials Located
    on  the  Campus  of  the  University of  Idaho," sumbitted  to to Don A.
    Amos, University  of Idaho.

 Foch,  Daryl F. June  2, 1981.  State of Idaho Department  of Health
    and Welfare,  Boise,  Idaho.   Letter to Arnie Bromberg, University
    of  Idaho.

 Grupp,  Carol. May 14, 1981 University  of Idaho Office of Financial
    Affairs.   Letter to  Ted  L.  Terrel, Morrisen  -  Knudsen Company,
    Boise,  Idaho.

 Grupp,  Carol.  November  12, 1982.  University of Idaho Office
    of  Financial Affairs.   Letter to  James  Werner, Environmental Law
    Institute.

 Grupp,  Carol. August 20,  1981. University of Idaho Office of
    Financial Affairs.    Memorandum  to  Record, "EES  Chem-Site Waste
    Haul Manifest Audit."

 "Hazardous Substance Excavation and Removal Agreement,"
    July  8, 1981.    Signed  by  Enviromental  Emergency Services  and
    University of Idaho.

Hopkins, John G.L. June 8, 1981.  Environmental Emergency
    Services  Co.,   Portland,   Oregon.     Letter  to   Carol   Grupp,
    University of Idaho Office of Financial  Affairs.

Koch, Daryl.   August 3,  1981.   State of Idaho Department of Health
   Welfare, Boise,   Idaho.   Letter  to Carol  Grupp,  University  of
    Idaho Office of Financial Affairs.

Ralston, Dale.  May 20,  1981.   Consultant in Hydrology,  Moscow,
    Idaho.  Memorandum #8 to Gary Presol,  City of Moscow  and Carol
   Grupp, University Idaho.

Roberts, Keith C.  August 6, 1981, August 21,  1981.  Environmental
   Emergency  Services.   Letter  to Carol Grupp, University of Idaho
   Office of  Financial Affairs.  Co.,  Portland,  Oregon
                                22-16
-------
Roberts, Keith C.  May 18, 1981.   Environmental Emergency Services
   Co., Portand Oregon.   Letter to Don A.  Amos, University of Idaho.

Roberts, Keith C.  May 20, 1981,  June 3, 1981.   Environmental
   Emergency Services,  Portland, Oregon.   Letter  to Carol  Grupp,
   University of Idaho Office of Financial Affairs.

Stawski, John,  April 17, 1981.   State of Idaho Department of
   Health and  Welfare,  Lewiston, Idaho.  Memorandum  to  Carol  Grupp
   and  Arnie  Broberg,   University   of Idaho  Office  of  Financial
   Affairs.

"Testing Agreement #1 for Hazardous  Substance  Determination,"
   May  28,   1981,  signed by  Environmental Emergency Services  and
   University of Idaho.
                                 22-17
-------
-------
                          VERTAC CHEMICAL CORPORATION

                             JACKSONVILLE, ARKANSAS
INTRODUCTION

     The Vertac Chemical  Corporation owns and operates an
herbicide manufacturing  plant  in  Jacksonville, Arkansas.
On-site  disposal   of chemical  wastes  and^  discharges  of
process wastewater  over  a thirty  year  period resulted in
contamination of soils, ground water  and  surface waters by
several  substances,  most notably dioxin,  in  excess  _of
Federal  and  state   levels.   Administrative  and  judicial
orders  have required the  company to  undertake five  dis-
tinct  remedial  actions to date,  and have required  Vertac
to  submit  studies  of  on-site and off-site  contamination
which  may  necessitate further  remedial action.   Although
remedial action at  this  site  may  not be complete,  and some
cost  and  engineering details are not  available  regarding
this  private clean-up,  a large  portion of  the  work  has
been  done and sufficient  information is available  for this
case  study.

Background^

      The  Reasor-Hill Company purchased the  site  in ques-
 tion  from  the U.S. Government in 1948.  The Government had
 used  it for  a munitions  factory  in the 1930's.   Reasor-
 Hill  owned it  from 1948-1961 and built  a  plant  to  formu-
 late  the  insecticides DDT, aldrin, dieldrin  and toxaphene.
 During the 1950's,  it  also  began producing the herbicides
 2,4-ot 2,4-5-T;  and  2,4,5-TP ("Silvex").    The  Hercules
 Chemical Corporation purchased the  plant site in 1961 and
 continued  manufacturing  the  same  products.   In 19b7-iyb8,
 Hercules  produced  "Agent Orange,"  a  2,4,5- T/2,4-D mix-
 ture,  for  the Government.   From 1971  to  1976,  Hercules
 leased the  plant to   the  Transvaal  Corporation,  a
 subsidiary of Vertac, Inc. Transvaal  resumed production  of
 2,4-D  and   intermittently   produced  2,4,5-T.    Transvaal
 purchased  the  property  from Hercules  in 1976.   In  19/8,
 Vertac, Inc. underwent  a Chapter  XI bankruptcy reorganiza-
 tion   and  ownership  of  the  site   was  transferred  from
 Transvaal  to the  new company,  Vertac Chemical Corporation,
 which  is  the  present  owner.    Contamination  of  soil,
 surface  water  and  ground   water  has resulted  from  the

                                       23-1
                                                              NCP Reference
-------
  storage  and  disposal  of  process  chemical wastes  at this
  site  between 1948 and  1979.

  Synopsis of Site  Response

       Remedial actions  have  been completed  at  five  major
  areas  on  the Vertac site  to  date.   The  Reasor-Hill  land-
  fill  area  was  capped  with  clay,  covered  with soil,  and
  seeded.  Clay barrier walls were  installed on three sides,
  leaving  the downgradient  side  open.    The  Hercules-
  Transvaal landfill was also capped with clay,  covered with
  soil  and seeded,  but had  no barrier  walls at  the  time  of
  this  study.   The  former above-ground   storage  area was
  capped, covered with soil and  seeded;  the old drums  were
  repacked  and placed along  with  new  drums   in  a  roofed
  storage warehouse.   Two-thirds  of the blow-out  area,  where
  spills from reactor vessels  had occurred  was paved  with
  asphalt while the  remaining  portion  was capped with  clay,
 covered with  soil  and seeded.   Extensive  remedial work was
 performed on  the equalization basin, which pre-treated the
 plant's^process wastewater.   Vertac  dewatered the basin,
 solidified   its  sludge  with  lime,  installed  clay   barrier
 walls  around  it, a French  drain downgradient  from  it, and
 placed a clay cap, topsoil, and seed over  it.   The  company
 then  constructed  an above-ground  treatment system to
 replace  it.   Before and  throughout  the  site response,
 extensive  monitoring of  soil,  ground  water  and   surface
 water  has  taken  place,   including  15 test pits,  42  test
 borings,  39  piezometers,  and  19  ground  water monitoring
 wells.    In  addition,  numerous  samples  were  taken   from
 surface soil, surface water  and sediments on  and  off the
 site.   Further,  Vertac was directed  by a Consent Decree to
 have  an  independent  consultant conduct  studies  of  both
 on-site and   off-site  contamination  and  report   on  the
 effectiveness  of the  completed  remedial  actions.
SITE DESCRIPTION

     The Vertac site  is  located  in  northwest  Jacksonville,
Arkansas,  approximately  20  miles   (32  km)  northeast  of
Little  Rock.   The facility  is  about 93  acres (37 ha)  in
size.  As Figures 1 and  2 show,  the  site  is bounded  to the
east by Marshall Road  and the Missouri-Pacific Railroad to
the  west.    The  northern  boundary  is  an  old  artillery
booster  line.   Adjacent  to  the  site to  the  south   is  a
housing development.   Rocky  Branch  Creek flows  along the
western edge of the site and  the East Branch  is  located to
the east of the site.  A cooling pond, formed  by  construc-
tion of  an earthen  dam across  Rocky Branch,  is located
along the  western  edge of  the  site.  Rocky  Branch  flows
into Bayou  Meto  approximately 2 miles  (3.2  km)  south  of

                                     23-2
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                  V  Lake Dupree
                   \.   I .•
Figure 1.   Topographic Section of  Vertac  Site Location
Source:    USGS,  1975.
                                 23-3
-------
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               pt   rt
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               3   O
               oo
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-------
 the Vertac  site.   The entire  site  is fenced  in  with  the
 main gate facing Marshall Road.

 Surface Characteristics

      The  Vertac  site  is  located  in  Pulaski  County,
 Arkansas.  The topography of Pulaski County (see Figure 1)    300.68(e)(2)
 does not have a  major influence  upon the climate.    Cli-    (i)(E)
 matic   conditions  are  caused by  exposure to  all  of  the    climate
 North  American air mass types.  Air  which  moves  downslope
 from the higher elevations may be  slightly warmer  at lower
 elevations.   Because of the  lifting  effect  transmitted to
 moist  air by local  ridges  and mountains,  there is  slightly
 more rainfall at higher elevations.

     Winters  are  basically  mild  and  relatively  free  of
 severe  cold.   The  daily winter  temperature  averages  at
 41 °F (5°C).   January  is  the coldest month  and a  low of
 10 °F (-12°C)  occurs  frequently.   The lowest  temperature
 ever  recorded in  Pulaski  County  was  -13°F (-25°C)   in
 February 1899.  Annual snowfall averages 5.7  inches  (14.3
 cm)  per year, however almost half of  this  snowfall  occurs
 during the month  of January.  The greatest  monthly  snowfall
 ever recorded was 12 inches (25 cm)  in January 1966.

     Summers in Pulaski County are hot with  large periods
 of  high humidity.   The daily summer  temperature  averages
 at  82°F (28°C).   The hottest  months  are  July  and  August
 when  a  high   temperature  of  over  100°F  (38 °C)   occurs
 frequently.    The  highest  temperature  ever  recorded   in
 Pulaski  County was  110°F  (43°C)  in August  1936.

     Precipitation  is  fairly well distributed  throughout
 the  year,  however May is  normally the wettest  month.   The
 average  annual  precipitation is  approximately 48  inches
 (120 cm).    During  March,  April,  and May approximately 15
 inches  (38 cm) or  almost  31 percent  of  the  annual  total
 precipitation falls.    The driest months   are  August,
 September,  and October when approximately 3 inches (8  cm)
 of rain  falls.

     The soil has  been classified  as  the Leadvale-Urban
 land complex with  a  1 to 3  percent  slope.   The Leadvale
 series  are  composed  of  moderately  well-drained,   nearly
 level  and  gently  sloping soils  in  valleys.   They  are
 formed mainly in loamy sediment washed  from  uplands con-
 sisting  of weathered  sandstone  and shale and  in some  areas
 from material weathered  from silts tone.    The  native
vegetation  is mixed hardwoods  and  pines.   Leadvale  soils
 show moderately slow  permeability  and maintain  a medium
 level  of  available  water  capacity.    The Leadvale-Urban
 land complex are areas of Leadvale  soils  that have been

                                     23-5
-------
modified by  urban  development.   The Level of  runoff  from
the  Leadvale-Urban  land  complex  is  medium,  while  the
erosion hazard  is moderate  if the  soils  are  not protected
by  vegetation.    Additionally,  these  soils  maintain  a
seasonal perched water  table,  slow percolation  rate,  and
moderate bearing capacity.

Hydrogeology

     Pulaski  County is an  area that  is  composed of  two    300.68(e)(2)
physiographic  regions:  the  Interior Highlands  and  the    (i)(D)
Coastal  Plain.    The  Interior   Highlands  are  hilly and    hydrogeological
underlain by  unconsolidated  sediments which dip slightly    factors
in  a  southeasterly direction.    The  consolidated  rock of
the Interior  Highlands  underlies the  unconsolidated sedi-
ments of the Coastal Plain.  Above the lowest level of the
water  table,  the consolidated  rock of  the  Interior High-
lands  has  been   subject  to weathering.   This  has  formed
soil  and  "rotten  rock",  which  have  a total maximum
thickness of approximately 20 feet (6.1m).  This weathered
area  is  more  permeable  and   porous   than  the  original
unweathered  rock.   Water is present  in  the  intergranular
voids  of  the "rotten  rock"  and  soil  while  water  is also
present  in  secondary  openings,  such  as  joints  and
fractures  in  the unweathered rock.

     The  relationship of  the   Interior  Highlands  to  the
Coastal Plain is shown in Figure  3.   The relationship of
the rocks  of the  Coastal  Plain to those  of the Interior
Highlands   is   shown  in  Figure  4.     The   Coastal  Plain
sediments,  which make  up Units  3 to  9, vary  from high
plasticity  clays  to  sands  and  gravels.   Additionally,
permeabilities  vary quite a bit between  units.   Units 3,
7,  and  9  are major water sources  in some areas  throughout
Pulaski County.   Unit 3 is made  up  of beds of  claystone,
calcareous  sandstone,  sandy  limestone, marl  and  conglomer-
ate.   Its  thickness varies from 7 to 60  feet  (2.1-18.3m).
Unit 7  is  composed  of  fine  to medium sand with  some  inter-
bedded  clay lenses.  Its total  thickness is  approximately
320 feet  (98m).   Unit 9  is composed  of terrace deposits
and alluvium.   The terrace deposits  are  formed  of  sand
while  the  alluvium,  which  is  deposited  by  both the
Arkansas  and Mississippi  Rivers,  is made of  a  fine-grained
top stratum  which becomes  coarser with depth.   Unit  9
reaches a thickness of  120  feet (36.6m)near  the  Arkansas
River  and  is much  thinner  at other locations.   Units 4,  5,
6,  and  8  are  primarily  fine-grained  materials  which,
unlike 3,  7, and 9, do not  yield much  water.

      The  Vertac site is situated very near  or  possibly  on
 the fall  line of the Interior Highlands and  Coastal Plain.
Although   geologic  maps  show  that  the  Vertac  site  is

                                      23-6
-------
              C0astal  Plaln
23-7
-------
Figure
Source:
Relationship of ^surface Characteristics^o^the
to the Subsurface Characteristics

Walton, 1982.
                                   23-i
-------
slightly  to  the  west  of  the  fall  line,  which  would
indicate  that it  is  in the Interior  Highlands,  there  is
evidence  which  indicates  that it  is  also in  the Coastal
Plain, or perhaps  in  a zone  of transition between the two.
The  subsoils are  part  of  the Atoka  Formation  which  is
found  in  the Interior  Highlands,  however  clays  of  the
Midway Group, which  are present in  the  Coastal Plain,  are
known  to  exist  in the  northern part  of  the site.   Addi-
tionally,  a  surficial  geologic  inspection  made  by
Developers  International  Services  Corporation  (DISC),  a
consultant  to  Vertac,   indicates  that  the  surface  soils
near  the  eastern  portion  of  the  site  are  sedimentary,
which  further supports  the  theory  that  a portion of  the
site  is  in the  Coastal  Plain.  Regardless,  at relatively
shallow  depths,   the  Vertac   site  is  underlain  by  the
consolidated  rock  of  the Atoka Formation which  surfaces in
the  Interior  Highlands  and underlies  the  sediments  of  the
Coastal Plain.

     The  Vertac  plant is  located  on the south  flank of a
westward  plunging  syncline.   The  axis of  the  syncline  is
approximately 5 miles (8 km)  north  of  the  plant and  has a
strike between  N  75°W and N 60°W.  The  bedrock is  alter-
nating gray  to black shales  and  sandstones  of  the  Atoka
Formation  which dips  to the NE at  a rate of  almost 30°.
Because  the site   is   so  close  to  the fall  line,  there  are
many  discrepancies regarding   the  strike  and  dip of  the
rock strata at  the Vertac  site.  Overlying the  unweathered
bedrock  in  ascending  order  is weathered bedrock approxi-
mately 5  feet (1.5m)  thick,  clays,  and alluvium.

     Drainage patterns  at  the Vertac  site  are  predomi-
nately westerly and  easterly  as  shown  in  Figure 5.   The
western  55  acres  (22 ha)  drain directly to  Rocky Branch.
Rocky  Branch enters   the  Vertac   site  at  the  northwest
boundary and  flows into  a man-made pooling  pond.  Approxi-
mately 700,000  gallons  (2.7  x 10   1)  per  day  of  plant
process wastewater enter the  cooling pond.   Flow from the
cooling pond  is by way  of  a concrete outlet structure  at
the  southwest  extremity of   the  pond.    Additionally,  a
central  ditch  (see   Figure  2) which  acts  as  a  surface
drainage  channel   from  the  plant  production area,  flows
into  the  cooling  pond.   The combined  flow  of  surface
runoff and  process  water enters  Rocky  Branch and  flows
south to Bayou Meto.

     The  eastern   38  acres  (15.2 ha)  of  the Vertac  site
drain to the  east  into numerous small ditches.   These  are
natural erosion channels with  only a few man-made ditches
along roads  and driveways.   Several catch basins  located
in  the  eastern  portion of  the  site  drain  into a  storm
sewer which empties into an open ditch near the  main  plant

                                      23-9
-------
'  • •  •  •   DRAINAGE DIVIDE
	*^^_  DRAINAGE & DIRECTION

Figure 5.   Surface Drainage at the Vertac Site
Source: .-   Walton, 1982.

                              23-10
-------
entrance.  AIL surface  runoff  east  of the drainage divide
eventually  flows  into  the  East  Branch of  Rocky Branch.
Most of  this  runoff  is  carried by the  "East  Ditch" (see
Figure 5) to the East Branch.   The East Branch eventually
links with Rocky Branch south of the Vertac  site.

     Additionally, it is  important  to  note that  during
heavy  spring rains it  is not uncommon  for Rocky  Branch  to
flood the area south  of the Vertac  site.  This is signifi-
cant  because, as  shown on  Figure 1,  there is a man-made
body of  water,  Lake  Dupree, located  about  1.3 miles (2.1
km)  south of the  Vertac  site.    Lake  Dupree is approxi-
mately  15 acres  (6  ha)  in  size  and  has   been  used for
recreational  purposes.    It  is  likely  that  flooding has
contributed to contaminant  transport  from the Vertac site
to Lake  Dupree because  contaminants discharged into  Rocky
Branch  from  the   site   subsequently  may  be  removed and
deposited in Lake Dupree during flooding.
300.68(e)(l)
(vii)
weather; sub-
stance migration
WASTE DISPOSAL HISTORY

     The  Vertac  site  was   originally  developed  by  the
United States Government  in  the 1930's and was used  as  an
ordnance plant during World  War II.   In 1948 it was  pur-
chased by  the  Reasor-Hill   Company  and converted  into  a
chemical manufacturing  facility.

     The  Reasor-Hill Company   operated  the   facility from
1948 to  1961.   At  first,   Reasor-Hill  manufactured  the
insecticides DDT, aldrin, dieldrin and  toxaphene.   During
the  1950's  Reasor-Hill  began production of the herbicides
2,4-dichlorophenoxyacetic  acid;   2,4,5-trichlorophenoxy-
acetic  acid;  and   2,4,5-trichlorophenoxyproprionic   acid
(Silvex).   Drums  of organic  waste were  stacked in  an open
field  immediately  southwest of  the  production  area  and
untreated wastewater was  discharged from  the west end  of
the  plant and was channeled  into Rocky  Branch Creek.

     Rocky  Branch drains  into  Bayou Meto a few miles from
the  site.    Bayou  Meto  is  classified as  a  warm  water
fishery  according  to  the September  1975  Arkansas  Water
Quality  Standards.    It  is   categorized  as being  suitable
for  desirable species of  fish,  wildlife, and  other  aquatic
and  semi-aquatic  life,  and as  a  raw water  source  for
public water supplies.

     Pollution problems associated with Bayou Meto  and its
tributaries,  including Rocky  Branch Creek,  date back  at
least  as  far as  1955  when  a  fish  kill  occurred  in  the
Bayou near Jacksonville.  At that  time  the Water  Pollution
Control Commission   and the  Game  and  Fish Commission per-

                                     23-11
300.68(e)(2)(i)
amount and form
of substances
-------
formed an  investigation.   They determined  that  the cause
of the kill was oxygen depletion resulting from the efflu-
ent of the Jacksonville  sewage  treatment  plant.   However,
other pollution sources were  found  further  upstream along
the  creek,  including  the  Reasor-Hill chemical  plant  and
the Arkansas Highway Department shops.  A strong chemical
odor was  noted at the Reasor-Hill  plant's  discharge into
Rocky Branch.  Other complaints of a "medicinal" taste and
odor in fish caught  in the  Bayou  were registered with and
investigated  by  the  Game  and  Fish  Commission.   They
determined  that  the cause of the problem was the Reasor-
Hill effluent.   Complaints continued through  June of 1958
at  which  time  the  Water  Pollution  Control Commission
began a survey of the area.  Chemical  and  bioassay tests
on  the  Reasor-Hill   effluent  found  it  to be  extremely
toxic. The survey  continued  intermittently  through  the
summer of  1959 when  a taste test  found  no  problem with
fish  from  Bayou   Meto.     However,   a  biological  report
(quoted in  a  summary  report  found  in U.S.  EPA  Region VI
files) stated  that  "the  bottom of  the  Bayou is  devoid of
life" and noted that "the stream will become barren unless
the situation  is corrected."

     At this   time,  it became  evident  that  the  City  of
Jacksonvilie's  sewage  treatment  plant  was overloaded
because of the increased growth of  the city and  the Little
Rock Air Force  Base.   It  was not  until April of 1960 that
a  meeting  was  held with representatives  of the  Air Force
and  the   Water Pollution  Control  Commission  to   discuss
improvements  for  the  sewage treatment  plant.   In 1961,
following a study of  the sewage treatment requirements for
the  area  and  a renegotiation of  the  city's contract with
the  Air   Force,   the  city  improved the  sewage  treatment
plant.  At this time, Reasor-Hill  began  discharging some
of  its wastewater  into the  city's sewage  treatment  plant.

     The  plant site  was  purchased by Hercules  Chemical
Corporation  in 1961.   Hercules  continued  to manufacture
the  same  products as  Reasor-Hill.   The  waste drums that
were  stacked near the plant were  buried  in the  same area.
This  became  known  as  the  "Reasor-Hill  landfill"  (see
Figure 2).   Hercules  continued  to  discharge  some  process
wastewater  into  Rocky  Branch  Creek  and  some  into  the
Jacksonville  sewage  treatment plant.   A  few months after
Hercules gained ownership,  the  company informed the Water
Pollution  Control Commission that  it intended to  pretreat
its  wastewater to  reduce  the load  on  the  Jacksonville
sewage treatment  plant.
300.68(e)(3)(i)
contribution to
water pollution
problem
                                      23-12
-------
      Complaints  about taste  and  odor  in fish  caught  in
 Bayou Meto continued  and on  February 19, 1963,  a massive
 fish kill  occurred in  the Bayou  approximately  45 miles
 (72 km) downstream from Jacksonville, near Stuttgart.  The
 Water  Pollution Control Commission  determined that  this
 was caused by  a  slug  of  toxic chemicals from the Hercules
 plant.  By May 20, 1963, Hercules was ordered to shut down
 operations at  the  plant  and submit plans within  165 days
 for  a  pretreatment   facility.   Hercules  complied  and  a
 neutralization  and equalization  pretreatment  system  was
 completed in August  1964.   As of September  30,  1964,  the
 plant's  entire wastewater  effluent  was  being  discharged
 into the Jacksonville sewage treatment plant.

      Bayou Meto and Rocky Branch Creek were sampled in the
 summer  of 1965  and  again  in  January  1966.   Continued
 improvements in stream ecology,  fish, and bottom organisms
 were  found.    However,  complaints  of  disagreeable  fish
 taste and odor continued.   Another  fish  kill occurred  in
 Bayou Meto  in  December of  1965 between  Jacksonville  and
 Lonoke  which  was  caused  by  oxygen  depletion  in  the
 Jacksonville sewage treatment  plant  effluent.   The  Water
 Pollution Control  Commission determined  that  the  sewage
 treatment plant  was  overloaded  and  recommended that  the
 city install a new sewage  treatment  plant.   With  joint
 participation from Hercules, the City of Jacksonville,  and
 a  grant  from the  Federal  Government,  the new sewage treat-
 ment plant  was completed  in 1969.    It  was  specifically
 designed to handle Jacksonville  municipal wastes  and  the
 chemical waste  generated by the Hercules facility.  Once
 the new sewage  treatment plant  went  into  operation,
 complaints of the  taste  and  odor in  fish decreased.

     At^ approximately this  same time,  Hercules began  to
 treat  its  wastewater  via  a  solvent  process.   This new
 process  separated out  several  by-products  of  the  waste and
 produced   toluene  still  bottoms.    When  hot,  the  still
 bottoms  were  liquid;  however,  they solidified when pumped
 into  drums and  allowed to  cool.    These drums  of  solid
 waste  were  then  buried  in an  area  north  of  the  plant
 operations area,  known as the Hercules-Transvaal landfill
 (see Figure 2).

     From  1967  to  1968,  Hercules was  ordered to manufac-
 ture the  herbicide  Agent  Orange, a 2,4,5-T/2,4-D mixture,
 for  the  United  States  Government.  Agent  Orange was used
 as  a  defoliant  in  the jungles of Vietnam.   A finding of
 the  possible  teratogenic  effects of  Agent Orange  by the
National Cancer Institute caused a ban on Agent Orange use
 in the Vietnam  War.  Soon  after  the  ban, other additional
uses  of  2,4,5-T   were  discontinued.    Hercules  then
discontinued operations at the Jacksonville site.
300.68(e)(3)(i)
contribution to
water pollution
problem
                                     23-13
-------
      From 1971 to 1976, Hercules leased the plant site to
Transvaal,  Inc.,  a  predecessor  company  of  Vertac.
Transvaal  resumed production  of  2,4-D and  intermittent
production of  2,4,5-T.   Toluene  still  bottom wastes  from
Transvaal's  manufacturing  processes  were  also  buried  in
drums  at  the Hercules-Transvaal  landfill  area.    In  1974
Transvaal ceased  still bottom burial and began storing the
drums  above ground for ultimate recycling or off-site dis
posal.

      In  1976,  Transvaal purchased  the  Jacksonville plant
from  Hercules.   That same year,  an EPA inspection of the
Jacksonville site did  not  indicate the presence  of dioxin
on  the plant  site.   By 1978, Transvaal  and  three Vertac
companies  were  involved  in bankruptcy  proceedings.

      At  that  time,   the  rising  concern  over  the health
risks posed by Agent  Orange  and  its  dioxin by-product,
caused Senator Mark  Hatfield  to  institute   a nationwide
survey of potential  dioxin sites.  Vertac  participated  in         ft,fflw4)
this  survey  and in April  1978  Vertac  officials reported  to     300.63UX4)
the U S  EPA and  the Arkansas  Department  of Pollution  Con-     discovery
trol  and Ecology  that  the  toluene still bottoms  located  on
Che Jacksonville  site  contained  37 ppm of dioxin  C2»3>^'8_
 tetrachlorodibenzodioxin  also  known  as  TCDD).    Subse
quently   U  S.  EPA  officials  visited  the site  and  took
 samples'to verify Vertac's findings.   The U.S. EPA samples
 did  not show any  evidence of  dioxin  in the still bottoms.
 Vertac  scientists then requested verification of  the^EPA
 results to clarify  the discrepancy between their findings
 and   those  of  EPA.   Meanwhile,   in  November  of  1978,
 Transvaal and  the other Vertac  companies  were brought_out
 of  bankruptcy  by  new  owners   to  form  Vertac  Chemical
 Corporation.

       In May 1979, using  an  improved analytical   technique,
 EPA   confirmed  Vertac's  orginal  report  that   there  was
 indeed  37  ppra  of  dioxin  present  in  the  toluene   still
 bottoms  at  the Vertac  site.   Subsequently, EPA found  trace
 quantities  of dioxin, usually  in the parts  per  trillion
 (ppt) level,  at  other  locations  at the Vertac site.

       A final   area  of waste  contamination  at  the Vertac
  site is  referred to  as  the  "blow-out area".   This  is  an
  area onto which some of the materials from  the  trichioro
  phenol  reactor   (used  by  Hercules  and  Transvaal)  were
  expelled during valve  rupture  blow-outs  experienced  by
  Hercules and  Transvaal prior to 1976 (see Figure 2).   In
  1976   Vertac  installed  a   catch  basin  into  which  the
  expelled  contents   of  the   reactor   would  be   discharged
  during future blow-outs.


                                       23-14
-------
      In summary, the waste disposal history of the Vertac
 site  includes  the  following  five  major  waste   disposal
 areas of contamination:

      •  Reasor-Hill  landfill  area  (drums  of organic waste)

      •  Untreated  wastewater  discharge  to  Rocky Branch
         Creek and  ultimately  Bayou Meto

      •  Hercules-Transvaal  landfill  area  (drums of toluene
         still bottoms)

      •  Above-ground  storage  area  (drums  of toluene still
         bottoms)

      •  Blow-out area.
 DESCRIPTION OF CONTAMINATION

     Historically,  it  is  difficult to  determine  exactly
 when  much of   the   contamination  at  the  Vertac  site
 occurred.   it is  evident  that  pollutants  from herbicide
 manufacture  were  detected by  1955  when  the  previously
 mentioned  fish  kill  occurred   in  Bayou   Meto   near
 Jacksonville;  however, it may  be  possible  that  chemical
 contaminants might  have been  seeping  into  the  ground,  as
 well as  into  Rocky Branch  Creek,  from as far back as 1948
 when Reasor-Hill first  manufactured  insecticides  and
 stacked  drums  of  waste in an  open  field.   These  drums
 consisted  of  various   insecticide wastes  and  are  believed
 to  have  contained such   compounds  as  DDT,  aldrin,  and
 dieldrin.   Still  further,  depending  upon  the  waste
 disposal methods used  at the time, some contaminants might
 have been  building up  in  the  soil, ground  water,  and/or
 Rocky  Branch  Creek from the  1930's when the Vertac site
 was  originally operated as an ordnance plant by  the U.S.
 Government.   Dioxin  could  not have been  present  prior  to
 the manufacture of 2,4,5-T in  the 1950's.  However, it  was
 not  known  that  dioxin contamination  was  present  at  the
Vertac site until  Vertac had  discovered dioxin at 37  ppm
 concentration at  the site in 1978,  while responding to  the
 previously mentioned nationwide survey of potential dioxin
contaminated sites.    Furthermore,  it was  not  until May
1979  that   EPA   positively  confirmed  Vertac's   findings.
Therefore,  the extent  of the dioxin contamination  was  not
even  determined   until after  May  1979,  at  which  time
studies  were   sponsored and  conducted  by  the Arkansas
Department  of Pollution Control and Ecology  (ADPCE), EPA,
and by contractors hired by Vertac.
                                     23-15
-------
Sampling and Monitoring History                         .
     Once EPA had confirmed Vertac's findings that   dioxin    300.
did exist at the Vertac site in concentrations of  37  ppm,    remedial   _
a series of ground water monitoring wells were  installed,    investigation
samples were taken, and analyses were performed by  several
contractors  as well  as  EPA  and ADPCE personnel  and
laboratories.

     During  May and  June  of  1979, McClelland  Engineers
installed  15  test  pits and made one log  boring  to deter-
mine subsurface  conditions  at  the  site.   In  October 1979,
Southwestern Laboratories installed 8 more test borings at
EPA's  request.   From  May  through  October 1980  the ADPCE
performed  analyses  of the monitoring  well  samples, while
EPA  performed  analyses from May 1980  through March 1981.
These  test borings and  test  pits  installed  by McClelland
Engineers  and  Southwestern Laboratories  are shown in
Figure  6.   Additional samples were taken from the  cooling
pond and Rocky  Branch  Creek themselves.

     In April  1982,  Developers,   International   Services
Corporation (DISC) made  41  auger  borings   at  the Vertac
site.    DISC  was  hired  by Vertac  to  help  determine the
extent  of  contamination,   review  remedial   actions  taken
thus  far,   and  make  recommendations  for further  remedial
work.   The location of each  of these  41 borings  is  shown
on Figure   7.   The  data  obtained   from  these borings was
combined  with  the data  obtained from the  previously
 installed  test  pits and test borings  to  determine subsur-
 face geologic  conditions.   DISC  mapped  these results  in
 cross-sectional views of different segments  of the site  as
Figure 8 shows.  This example of a cross-section shows^the
 subsurface geologic conditions determined by auger borings
#119,  #111, and #136.

      Thirty-nine of the 41  auger  borings made by  DISC  in
 April  were subsequently used  to install  39  piezometers  to
 determine the  characteristics  of  ground  water  flow.
 Hence, the location of each  of the 39 piezometers is also
 shown in Figure 7; however, as noted,  piezometers  were not
 installed   in borings #110  and #119.

      By July 1982, DISC had  begun a complete geotechnical
 investigation  to  describe  the engineering  properties  of
 the soil  and  rock  strata encountered.   This  was accom-
 plished through conducting  11  test borings  at  the  site.
 Once  these 11  borings were  completed,  they  were  used   as
 ground water monitoring wells.  An additional 8 wells were
 installed,  hence  a  total of  19   ground water monitoring
 wells were  installed  and sampled during July  1982.  The  11
 test  borings which  became  ground water monitoring  wells


                                       23-16
-------
       •   TEST  BORINGS
       o   TEST  PITS

Figure 6.   Location of Test Borings and  Test Pits Made in 1979
Source:     Walton, 19S2.


                               23-17
-------
Figure 7.   Location of Auger Borings and Piezometers
Source:    Walton, 1982
                                      23-18
-------
LO
I
                 I      I      I     I
I      I      I     I
                                                                           I     I
                      fffff
            Figure 8.   Cross Sectional View  of  Subsurface Strata From Auger  Borings
                       # 119, # 111, and  // 136.

            Source:    Walton, 1982.
                                                          Jar
                                                                                                            -fc.-
                                                                                                        Atfi
                                                                                                                          .
-------
and the  additional  8 ground  water  monitoring wells  were
located at the Vertac site as  shown  in Figure 9.

     During July  and  August  of 1982,  DISC  also  performed
sampling and analysis of  surface soil,  surface water,  and
sediments  at  the  Vertac  site.   The  surface soil at  the
Vertac site was analyzed  for  measurable  concentrations  of
2,3,7,8- TCDD at the areas shown in  Figure 10.

     Surface  waters  at  the  Vertac   site  were sampled  by
DISC  at  the   Locations  depicted  in  Figure 11.    These
samples  were  measured  for  concentrations  of chlorinated
phenols, benzenes, anisoles,  toluene, and phenoxy acids.

     Finally,  in  August  1982,  DISC  sampled  and  analyzed
sediments  for  concentrations of  chlorinated phenols,
chlorinated  benzenes,   toluene,  and  TCDD.   These  samples
were drawn  from the areas shown in Figure 12.

     In  total, the ADPCE,  EPA,  and Vertac  investigations
determined  that the contamination of both the  Vertac site
and  areas  off-site,  as well  as Che  potential threat of
contamination  to  other  areas  off-site,   included    the
following  (see Figures  1  and  2):

     •   Dioxin  detected  at  the  ppt   level  in  certain
         sediment  samples  and  species of   aquatic life in
         Rocky Branch  Creek and  Bayou Meto.  Contaminants
         were   found  as far as 45 miles  (72  km) downstream
         in Stuttgart   discovered  by  a  massive fish kill
         that   occurred  in  February   1963.   These   are
         probably  from  process  waste  discharges  made  by
         Reasor-Hill  Company  during  herbicide  production
         (1950's to  1961)  and  by Hercules Chemical Company
         from  1961 until  May  20, 1963,  when Hercules  was
         shut  down  and  ordered to  build  a pretreatment
         system

      •  Surface erosion,  percolation,  and  seeps on top  of,
         through,  and attributed  to  the Reasor-Hill  land-
         fill  and  former  above-ground  drum  storage  areas.
         The  estimated  total  volume  of  contaminated
         materials  (which include  chlorinated  phenols,
         benzene,  and toluene) lying  within the Reasor-Hill
         landfill  is 30,000 cubic yards  (22,800 m3) .   This
         may have  also contributed to contaminant  flow into
         Rocky Branch Creek

      •  The  equalization  basin that  was  installed as  a
         process  wastewater   pretreatment   system  in  1964
         contains   contaminated  st i11  bottoms.    Approxi-
         mately 20,000  cubic  yards  (15,200  m )  of  material
300.68(e)(2)(ii)
extent of migra-
tion of sub-
stances
300.68(e)(2)
Civ)
environmental
effects and
welfare concerns
                                      23-20
-------
   •   WELL LOCATIONS


Figure 9.   Location of  19 Ground Water Monitoring Wells
Source:    Walton, 1982.
                               23-21
-------
        Sample Area Number

        Sample Area rioundary

Figure  10.  Location of Surface  Soil Samples
Source:     Walton, 1982.

                           23-22
-------
     Cooling
     Pond  -v   /
     Center
         Cooling Pond
         North End
     Coolin
     Pond
     South
                                               East Ditch
                   Central Ditch
                Rocky Branch @ Eq  Basi
A  Sample Location
Figure 11
Source:
Location of  Surface Water Samples
Walton, 1982.

               23-23
-------
                    Cooling
                    Pond  NE
Cooling
Pond NW
   Cooling
   Pond
               Cooling  Pond SE
                 ^-Central Ditch
     Rocky
     Branch
A Sample Location

   Sample Area Boundary

 Figure 12.  Location of Sediment  Samples
 Source:    Walton, 1982.


                           23-24
-------
    is  presently  contained  within  the  equalization
    basin.   The basin was closed out  in  1981  as part
    of  Vertac's  remedial  response.    This  amount  of
    material  includes  the  clay  cover which was placed
    on  the basin  at closure

 •   Leachate  from the equalization basin  was detected
    along the western  portion of the property adjacent
    to  the basin.  This could have also contributed to
    the contaminant   flow  into  adjacent  Rocky  Branch
    Creek

 •   2,4-D,  2,45-T, and  2(2,4,5-T)P  were  detected  in
    ground  water monitoring  welIs  down gradient
    from the  Hercules-Transvaal  landfill  area.   There
    is  also  a likelihood of co-solubilization of TCDD
    with  the  detected 2,4,5-T  in the   ground  water
    adjacent  to  the  Hercules-Transvaal landfill.  The
    estimated  total  volume of materials  lying  within
    the Hercules-Transvaal landfill  area  is  100,000
    cubic yards (76,000m )

 •   Contaminants  from Hercules-Transvaal landfill
    migrated  to  the  process cooling  pond  where dioxin
    was found

 •   Contaminants  from the central drainage  ditch  and
    surface runoff at the Vertac site contributed  to
    concentrations of dioxins in the  cooling pond

 •   Cooling pond is in the Rocky Branch stream course;
    therefore, contaminants  that  leaked  into the
    cooling pond  and/or  settled  there  probably  flowed
    into Rocky Branch as well

 •  Blow-out  area,  which  contained  materials from
   valve ruptures of trichlorophenol reactor (used  by
   Hercules and Transvaal),  could be  cause of  dioxin
   percolation underground  and/or  surface  runoff  to
   the east.   Drainage from  this area is towards the
   east where coittaminated sediments  were  discovered
   in East  Branch

•  Contaminants  from  spills  that may have occurred
   during  normal  plant  operations,  exclusive of the
   blow-out  area  catch basin,  may  have  entered East
   Branch  following  heavy rains

•  At various points  to  the  east  of  the  site  (other
   than East Branch),  evidence of  dioxin,  which
   migrated  from  the  blow-out  area or  perhaps from
                                23-25
-------
       spills  that occurred  during normal  plant  opera-
       tions, was  found  due  to the downgradient movement
       of contaminated surface runoff as well as movement
       of subsurface  contaminants.   In  particular,  1 ppb
       of  dioxin  contamination  was  detected  along the
       creek  bed adjacent to  private  residences located
       east of  the Vertac  site

       Dioxin contamination  was  found  in  fish  and  sedi-
       ments  of Lake Dupree, a  15 acre  (6  ha) recrea-
       tional lake  approximately  1.25 miles (2  km)  south
       of the Vertac  site.   The contamination is believed
       to  have  resulted from flooding of  Rocky  Branch
       during  heavy  spring  rains  which  carried  dioxin
       from Rocky  Branch and into Lake  Dupree

       Further  contamination  could  have occurred during
       remedial action  implementation,  particularly  at
       the equalization  basin where movement of equipment
       noticeably  disturbed  the soil near  a former inter-
       ceptor ditch.
     Another issue at  the  Vertac site  is  that of  cross-
contamination.     In  the  Spring  of  1979,  Vertac  halted
2,4,5-T production  because EPA  had  banned  most  uses  of
2,4,5-T at  that time.   In  September of that year,  Vertac
switched  to 2,4-D  production.    Since October  of  1979,
Vertac  had  been   accumulating   solid  wastes  from  2,4-D
production.  However,  these wastes may have  been  cross-
contaminated with  dioxin by using  the same equipment  to
produce 2,4-D as was used  to produce 2,4,5-T.   The  extent
of contamination at the Vertac site that may have resulted
from  this  cross-contamination is  not  really  known.
Vertac, however, has been aware of the  cross-contamination
problem and has  been  setting  aside  the  2,4-D waste  in
drums  since  1979.    Since  July  1982, Vertac  has  been
recycling  2,4-D  waste  liquids   and  has  eliminated  the
potential  for  cross-contamination through the  use  of new
equipment.

     It is .important to note  that at  the  present time,
surface soils  at  the  site show  no measurable (detection
limit  of  50-100   ppt)   concentrations  of  TCDD  (dioxin)
except in  the  area   near the Reasor-Hill landfill.
Additionally,  no  existing domestic or industrial water
wells  were  located in the  areas  that  are  immediately
downgradient from the site.
                                     23-26
-------
PLANNING THE SITE RESPONSE
Initiation of Response

     The first major  remedial actions at  the Vertac site
occurred in accordance with a June 15, 1979 Administrative
Order  issued  by  the  Arkansas Department  of  Pollution
Control and  Ecology  (ADPCE).   Vertac  had  participated
in a nat ionwide  survey of  potential  dioxin sites in 1978,
and  in April  1978  had reported to U.S.  EPA and the ADPCE
that its toluene still bottoms contained 37 pptn of dioxin.
Further  testing  and analysis  was  performed  and  EPA
confirmed Vertac's findings in May 1979.  This led to more
ground  water monitoring  and  subsurface  test ing   at  the
site, performed by EPA, ADPCE, Vertac and  its contractors.
Negotiations  among Vertac  and  the   two  agencies   led  to
entry of the Administrative Order.

     The ADPCE Order referred generally to chemical wastes
and  by-products  stored  above  ground  or   buried   in  the
ground  at  the   site, but  specifically  mentioned  only
d ioxin.   The basic  thrust  of this  Order was  to  compel
Vertac to  undertake certain  interim containment measures
re lat ing to the above ground storage of wastes  and to the
wastes  buried  in the  ground.   It  spec ifically  required
Vertac to immediately install a clay cap over the  Reasor-
Hi11 and fill area.  With respect to  longer  term contain-
ment measures,  the  Order  directed Vertac  to  submit engi-
neering reports regard ing  barrier  dikes  and  interceptor
ditches at the two on-site  land fills and a detailed report
on  alternatives to  the  equalization basin.   Subsurface
samp1 ing and development  of a ground water monitoring plan
also were required.

     While  the  Administrat ive  Order  directed   Vertac  to
recontainerize  any  leaking  drums stored above  ground and
place them  in a newly built  roofed  storage area,  it did
not  prohibit  off-site  disposal  of  drums.   However,  in
early 1980,  EPA issued  a TSCA section  6  ruling directing
Vertac to hold  drums  on-site  containing 2,4-D and 2,4,5-T
still bottoms and not dispose  of  them in landfills.  This
ruling was  prompted  by  Vertac's  finding  of  0.7  ppb  of
dioxin in  its 2,4-D still  bottoms that  were  generated  in
late 1979  (the 2,4,5-T still bottoms were already known to
contain dioxin).   Apparently the 2,4-D  wastes  had  become
contaminated  inadvertently  through  the manufacCuring
process.   The EPA ruling provided that after May 12, 1980,
Vertac  could  dispose of the still bottoms in an approved
PCB landfill  if their analysis showed only trace  amounts
of dioxin.    A Vertac  official reported, however, that by
that time no  PCB landfi11  would accept  the  drums  because
of the presence  of  dioxin.   This situation  led  Vertac  to
300.68(c)
administrative
process; private
clean-up
300.68(e)(l)(iv)
above ground
hazardous
substances
300.70(c)
off-site trans-
port for secure
d ispos it ion
                                     23-27
-------
develop a  process  for recycling the  2 ,4-D  still  bottoms,
thus eliminating  the  dioxin as  a  waste.   Vertac  is  also
investigating, with EPA,  the possibility of incineration.

     The second  major series of  remedial actions  at  the
Vertac  site  was  also initiated  by  a legal order.   While
Vertac had completed or was implementing some of the tasks
spec ified   in  the  Administrative  Order,  it  had  not
completed  all  of  the work.   On March 4,  1980,   EPA  and
ADPCE  sued  Vertac  and  Hercules Chemical Corporation in
Federal District Court under  the "imminent threat" provi-
sions of   RCRA and Arkansas statutes.   The  agencies then
obtained a  Preliminary  Injunction  on  May 12, 1980 that
directed Vertac  to  undertake  numerous  specific  actions.
The  Injunction  required  Vertac  to  repair the  cap  on  the
Reasor-Hill  landfill  (which  was capped under the Adminis-
trative  Order  but had  eroded)  and  install   containment
walls  around  it.   Vertac also had to cap  and cover several
other  areas at the site:  the Hercules-Transvaal landfill,
the  old  above-ground drum  storage  area,  and  the blow-out
area.   The  Injunction  stated   that  Vertac  was  to submit
detailed   engineering  plans  for  an  alternative   to  the
equalization  basin,  as  had been required by  the Adminis-
trative Order but  had not been  done.  Finally,  the  Injunc-
tion   imposed  on-site  sampling requirements   similar   to
those  in  the Administrative Order,  but went  further than
the  Order  by directing Vertac  to begin off-site sampling,
i.e.,  sampling  from the  waters  and   sediments  of Rocky
Branch Creek.   Thus,  the  May 12,  1980  Injunction  was
consistent with  1979  Administrative  Order,  continuing some
work,  requiring  remedial  work  to  be  performed  that
previously  had  been  studied, and  directing   new  and
complementary work.

      The next substantial  remedial  action was  initiated  on
September  26, 1980,   when   the   court   ordered  Vertac   to
proceed  with its   plans  for   replacing  the   equalization
basin  with an alternative  system and remediating  the basin
area.   Vertac  submitted  its  plans  to EPA and the ADPCE
pursuant   to  the  Injunction1s   requirements.    The ADPCE
approved  them but EPA did  not.  Following a hearing,  the
court  ordered Vertac to proceed with  its plans, which  the
company did.

      During   1981,  Vertac,  Hercules,  EPA  and  the ADPCE
negotiated extensively, seeking to  resolve  their  disputes.
This led  to  the  entry of  a  Consent Decree  on January 9,
 1982  in  the suit   that the agencies  had  filed  in  1980.
Like  the  Preliminary  Injunction  before   it,   the Consent
Decree was  consistent with the  previously  required  work
 and added  certain complementary tasks.   Since most, if not
 all, of the  required remedial  actions  had  been completed,
300.68(c)
judicial pro-
cess; private
clean-up
 300.68(c)
 judicial  pro-
 cess;  private
 clean-up
 300.68(c)
 judicial pro-
 cess; private
 clean-up
                                      23-28
-------
 the  Consent  Decree  was concerned  with assessing  the
 effectiveness  of  those  actions;  the  parties  named  an
 independent consultant,  Developers,  International Services
 Corporation  (DISC) ,  to  do this  study.    The Decree  also
 stated broad  goals for  protecting  public health and  the
 environment, and provided  that  Vertac would  submit  plans
 for additional on-site remedial work  needed  to meet  those
 goals.   In  addition,  Vertac  was  to  submit plans for  the
 study of certain areas of off-site contamination, such as
 Rocky Branch Creek,  Bayou  Meto  and Lake Dupree.    The
 Decree imposed various other tasks upon Vertac,  including
 submission   of a   plan   for  managing  accumulated  stored
 wastes,  exercise of best efforts  to  reduce the  volume of
 wastes stored on-site, and  submission of  interim  discharge
 limitations for Vertac's discharges  into  the  Jacksonville
 STP.   It appears  that the  Consent Decree  generally  seeks
 to ascertain  the  effectiveness  of past remedial actions,
 study on-site  and  off-site  conditions  to determine  the
 need  for future actions, and manage  and reduce the  wastes
 stored on-site or discharged  into  the STP.

 Selection of Response  Technologies

      The  remedial actions that were  chosen at the  Vertac
 site  were actions that did  not come about  through a  simple
 examination of the problem, analysis of alternatives,  and
 selection of  the  best   remedial  technologies available.
 Instead,  the remedial  actions which have been completed as
 well  as  those which are  still on-going, were  the  result of
 the aforementioned administrative and  court  orders  which
 took   into   account recommendations of  EPA  personnel,
 Arkansas  Department of Pollution Control   and Ecology  per-
 sonnel, Vertac  officials, as well  as  those recommendations
 made  by  independent consultants  that  were  used throughout
 the legal proceedings.

      The  remedial actions first  implemented at the Vertac
 site  were the  direct result of the June 15, 1979, Adminis-
 trative  Order issued to  Vertac by the  ADPCE.   Vertac  had
 consented to the  order once EPA had  verified the presence
 of  dioxin  at  the  site  in May  1979.    As  negotiations
 between  Vertac,  the  ADPCE,  and  EPA  took  place  prior  to
 entry  of  the  Administrative Order of June  15, 1979, Vertac
 had hired Shreeve Engineering of Little Rock, Arkansas,  to
 conduct an  objective  study  of  the  site and make  recommen-
dations for  remedial actions.   The recommendations made  in
 the Shreeve  Engineering Report, as well as  recommendations
made  by   EPA and ADPCE   personnel, were   the  criteria on
which  the Administrative  Order requirements were  based.
                                     23-29
-------
     The Administrative Order required Vertac to  Cake  the
following actions  (where  not  specified;  compliance  was
required prior to October 1,  1979):

Above-ground Storage Area
     •  Inspect  and  inventory  all wastes  stored  above
        ground in containers, and recontainerize any which
        were leaking
     •  Prepare  secure  on-site  storage  area(s)  to be  of
        adequate size to store all above-ground container-
        ized wastes Located at Vertac

     •  Conduct  weekly  visual  inspections  of each drum in
        storage

     •  Conduct  daily visual  inspection  of tanks in which
        wastes are stored

     •  Containers must be located  on  sealed concrete or
        other  sound, sealed,  impermeable material

     •  Storage area(s)  must  be  completely curbed to
        contain  any  spills or leaks from  containers; must
        be  capable of containing at  least  twice  the volume
        of   the  largest   container  in  storage;  and   all
        material including rainwater, contained  within  the
        curbed  area must  be  analyzed  for  contamination.
        Any such contaminated  material must  be handled  and
         stored  as  a waste material  and  disposed  of as
        approved by  the ADPCE

      •  Drum  storage areas must be covered  by  August  15,
         1979  by  fixed  roof  structures of  reinforced
         fiberglass or  materials  of greater strength  to
         withstand forces such as wind  and  snow

      •  Storage  areas  must be  well ventilated  to prevent
         accumulation  of  toxic  fumes  and must   be secure
         from unauthorized entry

      •  Drums  in  above-ground storage  area  must be recon-
         tainerized by  July 9, 1979

      •  All other deteriorated drums  must be recontainer-
         ized  and relocated by October 1,  1979

      •  Maps  must be  drawn  up immediately, delineating:
         outside boundaries  of   above-ground  drum storage
         areas; portions  of  above-ground   storage  areas
300.68(e)(l)(iv)
above surface
hazardous sub-
stances—direct
threat
 300.70(b)(l)U)
 air emissions
 control
                                       23-30
-------
      which  overlie  underground  burial  areas;  all
      contaminated surface  areas  and  recontainerization
      operations

   •  Locate and construct dikes to intercept and direct
      all  surface drainage  away from  the  above-ground
      container storage site

   •  No  excavation will  be permitted  in areas mapped
      for  above-ground storage or that  are delineated  as
      contaminated  areas

   •  Install  impermeable  cover  to  prevent precipitation
      and   surface   runoff  from coming  in  contact  with
      areas  mapped  for   above-ground   storage  or   are
      delineated  as contaminated areas

    »  Store  and  isolate   discarded containers and other
      debris from surface  runoff and  precipitation

    •  Once wastes  are relocated  to secure area, contam-
       inated wastewater  within sumps and catchment basin
       downgradient  of  existing  storage area must  be
       removed  and  placed  in  secure containers pending
       final disposal

    •  Existing  sumps  and   catchment   basins  must^ be
       leveled, filled, and covered to  prevent  contamina-
       tion  of  surface runoff and ground  water

    •  Treat dioxin  contaminated  ground  surfaces  to  pre-
       vent  contamination  from becoming airborne
     •  Sampling  and  analysis  activities must  be continued
        by  Vertac  within  30  days  of  receipt  of EPA-
        approved  analytical procedures,  which   are  needed
        to report qualitative  and  quantitative character-
        istics of  all surface  flows of  leachate,  storm
        water, cooling  water,  and  process wastewater  to
        the ADPCE

Reasor-Hill/Hercules-Transvaal Areas
     •  Vertac must  submit an engineering report no later
        than July 9,  1979  for construction of barriers and
        interceptor ditches necessary to prevent movement
        of  subsequent  waters  through the  waste materials
        buried at  the  Reasor-Hill  site  and to collect and
        contain  subsurface waters flowing  from  the Reasor-
        Hill  area  for treatment as  necessary.   This will
300.70(b)(l)(U)
(B)
surface water
diversion
3QQ.7Q(b)(l)(ii)
(A)
surface  seals
 300.68(e)(2)
 source, control
 remedial  actions
 300.70(b)(l)(ii)
 (A)
 surface seal

 3Q0.70(b)(2)(i)
 gaseous
 emissions
 treatment

 300.66(c)(2)
 (iii)
 assessing  poten-
 tial  for
 migration
                                     23-31
-------
    include  soil borings,  soil  classification and
    stratigraphic logs for  each boring,  permeability
    or  transmissivity  of  significant  strata,  and
    subsurface  flows

    Vertac  shall  submit an engineering report no later
    than August 9, 1979  for construction of barriers
    and  interceptor ditches  necessary to  prevent move-
    ment of  subsurface  waters  through  the  waste
    materials buried  at  the  Hercules-Transvaal  site
    and  to  collect  and contain subsurface  waters
    flowing  from  Hercules-Transvaal area  for treatment
    as  necessary.  The same boring  data as described
    above are pertinent to the Hercules-Transvaal area
    as we 11
 •  Vertac  shall submit  a plan  for  development  and
   implementation of  ground  water  monitoring program
   prior to August 9, 1979

 •  Locate  and  map  all underground  waste burial  areas
   including  areas known  to  be  or  expected to  be
   contaminated by surface or underground flow

 •  No  exploratory  drilling,   coring,  or  excavation
   shall be conducted in burial areas or contaminated
   areas,  without   the  express  written consent  and
   approval of the State of Arkansas

 •  Wastes from any exposed containers shall be placed
   in  new  containers  and  transported  to  an  above-
   ground  storage  area.    Any  voids  produced by  the
   removal oE exposed containers shall  be  backfilled
   Limned iately

 •  Once  boundaries  of  disposal   areas  have  been
   defined  and mapped, Vertac  shall clearly  mark  the
   limits of each site

 •  Dikes  (approved  in  writing by  the  State    of
   Arkansas prior to construction)   shall be   located
   and constructed   to  intercept and direct  all sur-
   face drainage away from underground  waste burial
   sites
300.70(b)(l)(ii)
(B)(l)
dikes and berras
•  Impermeable  cover shall  be installed   to prevent
   infiltration  and   surface runoff  from coming   in
   contact  with the  surface of the underground  waste
   burial sites
300.70(b)U)(ii)
(A)
surface seal
                                23-32
-------
      •  Immediately proceed with  application  of clay cap
         at  Reasor-Hill  area  as  recommended  by Shreeve
         Engineering Report of June 7, 1979

 Equalization Basin
      •  Within 45 days of the Administrative Order, Vertac
         shall  submit  a  detailed  report  to  the  ADPCE
         describing  alternatives  to  the  continued  use  of
         the equalization basin.

      As  a  result  of  this  Administrative  Order,  Vertac
 hired McClelland  Engineers  of Little Rock  to  perform the
 geotechnical testing required.   At EPA's  request,  Vertac
 hired Southwestern Laboratories to perform the analyses of
 the soil borings taken by McClelland Engineers.

      One  engineering  report   recommended that the ground
 atop  the  Hercules-Transvaal   burial  area  be  recapped.
 Vertac,  although  not required to do so  by the Administra-
 tive Order, recapped the Hercules-Transvaal landfill area.

      Under  "substantial  threat"  provisions  of  RCRA  and
 Arkansas state  law,  the EPA  and ADPCE sued Vertac  in March
 of 1980.   On  May 12,  1980,  the  EPA and ADPCE obtained  a
 temporary injunction ordering  Vertac to  do the following:

 Reasor-Hill Landfill Area
      •   Restore   and repair  the  clay cap placed  over the
         Reasor-Hill   landfill  area,   pursuant  to   June 15,
         1979, Administrative Order,  because  it  had   eroded

      •   Once restored,  cover clay cap  at  Reasor-Hill  land-
         fill area  with  topsoii  and seed
     •  Within  six months,  construct clay cut-off or con-
        tainment walls around the north and east  portions
        of Reasor-Hill  landfill area  to prevent movement
        of  ground water through  the dump area into Rocky
        Creek                                            J

Equalization Basin
     •  Submit detailed  engineering plans and  specifica-
        tions within 60 days to the ADPCE and EPA  for the
        development  and  installation   of  a  wastewater
        treatment system as  an alternative to the equali-
        zation basin

Hercules-Transvaal Landfill Area
     •  Proceed  to  cover  the  Hercules-Transvaal burial
        area  and  former above-ground barrel  storage area
        with an impermeable clay cover within  90 days to
 300.70(b)(l)(ii)
 (A)
 surface seal
 300.70(b)(l)(ii)
 (A)
 surface seal
 300.70(b)(l)(ii)
 (A)
 surface  seal

 300.70(b)(l)(ii)
 (D)
 revegetation

 300.70(b)(l)
impermeable
barriers Branch
300.70(b)(2)(ii)
wastewater
treatment
300.70(b)(l)(ii)
(A)
surface seal
                                     23-33
-------
        prevent  the  penetration of  underground areas  by
        surface  waters

     •  Cover  clay  cap at HercuLes-Transvaal burial area
        and  former  above-ground barrel storage area with
        topsoi1  and seed

Blow-out Area
     •  Proceed  to cover "blow-out" area to a distance not
        less than 200 feet (61m)  east, north, and  west of
        the  trichlorophenol  reactor  vessels  within 120
        days; cover should be of impermeable clay material
        to prevent infiltration by surface waters

     •  Cover  blow-out  area,  cap with topsoil and seed
        unless (in opinion of Vertac personnel) area will
        not  support  vegetation;  otherwise  cover  with
        asphalt  or other similarly permanent material

     •  Collect,  label,  and  keep  separate  samples  from
        each  of  the  monitoring  wells  presently  on  the
        property  and  from the water and sediment of Rocky
        Branch Creek  at  the  south  fence line on a monthly
        basis.   These samples  should  be  delivered to the
        ADPCE and EPA for analysis.
300.70(b)(l)(ii)
(D)
revegetation
300.70(b)(l)(ii)
(A)
surface seal
300.70(b)(l)(ii)
(D)
revegetation
     Vertac  submitted its  plan to  take the equalization
basin,  which was  part of  the  process  water  treatment
system  built  by  Hercules  in  1965,   out  of   service.
Vertac's  plan  was to  install a new  above-ground waste-
water treatment  system.   The  equalization basin was to  be
dewatered  and  the  remaining  sludge was  to  be  mixed with
lime  to  form  an  extremely hard  phenoxy compound.   The
entire area was to be capped and sealed and  the basin area
was to be  protected by   an impervious barrier wall.  This
plan was approved by the  ADPCE but  was not approved by the
EPA.   After  a  hearing  on September 26, 1980, the  court
ordered Vertac to proceed with  its  plan.
      During  1981,  negotiations took place  between  Vertac,
 Hercules,  the  ADPCE,  and EPA to settle the EPA/ADPCE  suit
 of  March  1980.   A  Consent  Decree was entered  on January 9,
 1982.   It  required to  Vertac  to do  the  following:

 Effectiveness/Compliance
      • Retain  DISC as  an independent  consultant  to  con-
        duct a study on the  effectiveness  of the  remedial
        action  at  the Vertac  facility  and   for  contami-
        nation  that has migrated  from the facility  to be
        completed  within 150  days
300.70(b)(2)(ii)
direct  waste
treatment
methods
 300.70(b)(l)(ii)
 (A)
 surface  seal

 300.70(b)(l)
 (iii)CA)
 impermeable
 barrier
                                      23-34
-------
     •  Submit  a  proposal  to  EPA,  ADPCE,  and  Hercules
        within  60  days of  receipt  of DISC  study  to meet
        the  goals  of  the  Consent  Decree with  regard to
        ground  water,  surface water runoff, cooling water
        pond, and  surface  conditions  at Vertac site

     •  Vertac  shall  implement  any plans approved by EPA,
        ADPCE,  or  the court

Rocky Branch Creek/Bayou Keto
     •  Within  60  days,  Vertac  shall  submit for EPA and
        ADPCE approval a plan and implementation  schedule
        for a   study of Rocky Branch  Creek, the  drainage
        ditch which  runs   from east side  of plant site to
        Rocky Branch Creek,  and  Bayou Meto, which will be
        based   in  part  on a  three-year  sampling  and
        analysis program to be performed by  the State

     •  Upon  approval  by  EPA and  ADPCE  of  the  plan and
        schedule   for  the  proposed  study,  Vertac  shall
        complete the study

     •  Vertac  shall pay the State  $15,000  in three  annual
        installments to help defray costs for sampling and
        analysis

     •  Vertac  shall submit  preliminary  report  to EPA and
        ADPCE  for  review  within six months which   summa-
        rizes data gathered in  1979,  1980,  and  1981, and
        submit  to  EPA  and  ADPCE  a complete  study no later
        than  6  months  after completion  of  sampling  and
        analysis program

Lake Dupree
     •  Within 60 days,  Vertac shall submit for  EPA  and
        ADPCE approval a plan and implementation  schedule
        for Lake Dupree, including decontamination,  remov-
        al,  permanent  sterilization,  or   containment of
        contaminated water and sediment

     •  Upon EPA,  ADPCE or court  approval of  the  above
        plan and schedule,  Vertac  shall make certain that
        the plan is performed and completed

On-Site Maintenance
     *  Within  90  days,  Vertac   shall  submit for SPA and
        ADPCE approval, a plan and  implementation schedule
        for the management  of accumulated chemical  wastes
        stored  at  the  Vertac site  including an  inventory
        of  on-site   was tes  and  conta Lnerization  or
        recontainerization of wastes presently on-site and
        to be generated in the future

                                     23-35
300.64
preliminary
assessment
3QQ.68(c)
evaluation of
clean-up pro-
posals
-------
     •  Upon approval of the plan by EPA and ADPCE, Vertac
        shall cause the plan to be performed and completed

     •  Vertac  shall  exercise  best efforts  to  reduce the
        volume of chemical wastes stored at the site in an
        orderly  and  exped itious  manner.    Using  a  list
        (that EPA will  provide Vertac  within 180  days)  of
        names, addresses, and management  methods  of waste
        transportation;  treatment;  storage;  or  disposal
        facilities, Vertac will  submit a report to EPA and
        ADPCE every  180 days describing  Vertac's  efforts
        to enter  into negotiations with  any facility for
        transportation, treatment, storage, or disposal of
        chemical wastes at the site

     •  Within 60 days, Vertac  shall  sample, analyze, and
        submit  to  EPA  and  ADPCE a report  characterizing
        the nature, volume,  and  const ituents of the waste-
        water discharge from existing  system by Vertac  to
        the JacksonviHe sewage  treatment plant

     •  Within 30  days  after submission  of above  report,
        Vertac  shall  submit to  EPA  and  ADPCE  a   set  of
        interim discharge  limitations  for  wastewater
        designed to prevent  increases  in  pollutant levels
        in receiving  st reams over  previously detected
        levels

     •  Vertac  shall  comply  with   interim  discharge
        standards   set  unless modified  by  agreement  with
        EPA,  ADPCE or the court

     •  Vertac  shall   provide   for  the  continuation  and
        maintenance of effectiveness  of all monitoring and
        remedial actions taken or  to be  taken  at  the  site
        from  the  present  time   to  a   period  of 30  years
        after closure of the manufacturing fac ility

     •  Vertac  shall  create  a   segregated  trust   fund  of
        $60,000 for post closure maintenance.

Extent of Response

     In addition to specifying what remedial actions  were
to  be  performed  with  respect   to  the Vertac  site,  the
Administrative Order, Preliminary  Injunction,  and  Consent
Decree largely determined  the extent of response.   Remedi-
al  actions  relating  to  the  Reasor-Hill  and  Hercules-
Transvaal  landfill  areas,  the   old  above-ground  storage
area, the  blow-out  area,  and  the equalization  basin  were
terminated once the  legally required   work  was  completed.
Because  the  legal  orders  came  one   after   another,  they

                                    23-36
-------
 ensured  that all required work was done.  For example, the
 ADPCE  Administrative Order  required  Vertac to  submit an
 engineering  report  on  alternatives  to  the  equalization
 basin; this had not  been  done  by the  time of the Prelimi-
 nary  Injunction,  so  it  was  included  as  one  of  the
 Injunction's tasks.   The various  ongoing  tasks,  such as
 monitoring  and  conducting  studies of  off-site  contamina-
 tion, are  continuing in expanded form  in accordance with
 the  Consent Decree.   The  Decree requires  that  Vertac
 undertake  any  future on-site or off-site remedial action
 indicated  by these  studies  and  ordered  by the  agencies or
 the court.
 DESIGN AND EXECUTION OF SITE RESPONSE

      Presently,  the  remedial actions  at  the Vertac  site
 are ongoing.  As of the time this case study was prepared,
 remedial actions at  five major  areas  of contamination had
 been completed.  These areas include the:

      •  Reasor-Hill landfill area

      •  Hercules-Transvaal  landfill area

      •  Former above-ground storage area
      •  Blow-out area

      •  Equalization  basin.

      The remedial actions taken at each of  these  areas  is
 described  below.  In all cases, Vertac acted as a general
 contractor  and supervisor for the design and  installation
 of  remedial  actions.   In  addition,  a  recycling technology,
 an  alternative technology,  and  future  remedial actions are
 discussed.

 Reasor-Hill  Landfill  Area
      The Reasor-Hill  landfill  area was  originally capped
 in  the latter  portion of  1979 as required   under  the  June
 15,  1979  Administrative  Order.   The area  was   recapped
 following  the  May  12,  1980  injunction  because  there was
 evidence which  indicated that the original cap had  eroded.

     The  Reasor-Hill  landfill,  shown  in Figure  13   con-
 tains 30,000   cubic  yards  (22,800  m3)   of  hazardous
material.  The   landfill was  recapped with  on-site   clay
 taken  from a clay pit in the  northeast area of the Vertac
property (see Figure 2).  One foot (0.3m) of clay was  used
to  cap the  Reasor-Hill  area.  Trucks,  backhoes,  graders,
and  a  sheepsfoot  roller  were   used  to  distribute  and
compact  the  clay  from  the  pit  to   the  landfill  area
300.70(b)(ii)
surface water
controls
300.70(b)(l)(ii)
(A)
surface seal
                                     23-37
-------
ro
UJ
 I
U)
oo
                                                  OCVCU1KM MTEHHATIOHM. UHVICCI COU

                                                       • *^«« DISC •n~n^t
                                                       mi in •     WMim   	

                                                                                FNVIMNMENUI.  AMCUMCNT
           Figure  13.  Details of Reasor-Hill Waste  Burial  Area and Barrier Walls

           Soruce:   Walton,  1982.
-------
 Similarly,  the same equipment  was  used to place  a  6  inch
 (15 cm)   soil cover  over the  clay cap.    The  soil cover
 was  seeded  over and   is now  covered with grass.  Vertac
 hired  an   excavation  contractor,   Helena  Construction
 Company  (Helena), to place the clay cap  and  soil  cover on
 the Reasor-Hill  area.

      In  addition  to the clay cap,  the  Reasor-Hill  landfill
 area is  surrounded  on three  sides by clay  barrier walls
 extending from bedrock to one or  two feet (0.3-0.6m) above
 ground  level, (as seen  in Figures  13  and  2)  while  the
 downgradient  side was  left open.    This design is  intended
 to  prevent  run-on of  surface  rainfall  into the landfill to
 keep it  free  from  contact  with  any  other  materials,
 particularly  liquids.   The downgradient side  was left  open
 because  the area  is  not susceptible to flooding.

      The  barrier  walls were  also  constructed  by  Helena.
 They were  trenched  to  rock at a  depth  between 8  and  10
 feet (2.4-3.0 m)  and  were then  filled  in  and compacted
 using on-site clay.   They are approximately  2  feet  (0.6m)
 in  width (the width of  a backhoe  bucket)  and  in  combina-
 tion with  the  clay  cap,  have   served  to  contain   the
 Reasor-Hill site  area.

 Hercules-Transvaal Landfill Area
      Vertac  voluntarily  recapped   the Hercules-Transvaal
 area in   response  to  a  recommendation made  from   a  1979
 Shreeve Engineering Report.   The procedure followed  at  the
 Hercules-Transvaal landfill area  was  very much like  that
 at  the  Reasor-Hill area.   The  recapping  was  completed  by
 January 1980.

      The  Hercules-Transvaal  landfill has  a waste volume of
 approximately  100,000 cubic yards (76,000  m3)-   An outside
 contractor  was hired to excavate on-site  clay and   soil to
 be   placed  over   the   area for  capping  and  soil  cover,
 respectively.  The clay cap is one  foot (0.3m) deep and  a
 6 inch  (15  cm) soil  cover is maintained.   The Hercules-
 Transvaal   site is seeded   over and  appears  to  be   stabi-
 lized.  No  barrier walls were constructed   there.  Figures
 14a, b and  c  collectively  show  details  of the  Hercules-
 Transvaal landfill area.

 Former Above-Ground Storage Area
     As   a  result  of  the  June  15, 1979, Administrative
Order, Vertac  was required to  address the  problem  of  an
estimated   3,000  drums of 2,4,5-T still bottoms which were
being stored  in an area known as the  former  above-ground
 storage  area.   A severe contamination  problem was  found  in
 this 300 foot by 200 foot  (91  x 61m)  area because  many of
these drums  were  leaking.
 300.70(b)(l)(ii)
 (D)
 revegetation
300.70(b)(l)(ii)
(A)
surface seal
300.70(b)(l)(ii)
surface water
controls
300.70(b)(l)(ii)
(D)
revegetation
                                     23-39
-------
                    © - *


          H*rcul««-Truuv«al Landfill
Figure 14a. Details o£ Hercules-Transval1  Landfill
Source:     Walton, 1982.
                              23-40
-------

                 lt*tt /*.J,* J**tt
                                         '\
                          r~\
                                                       -©•
Figuie  I4b.  Details of Hercules-Transvaal Landfill
Source:      Walton, 1982.
                             23-41
-------
                                                             1'  - 0"
                6" Topsoil
             Existing
             Ground
             Line
                                  Burial Area Limits
                                                        Natural
£                                                        Ground
                                                     .  -
I
•p-
fo
Typical Section of Clay Cover
Not to Scale
            Figure 14c.  Details of Hercules-Transvaal Landfill Area
            Source;      Walton, 1982.
-------
     Vertac was required to build a secure on-site storage
warehouse  for  these  drums,  as  well  as  to  repack  those
which  were  badly  cracked  and/or leaking.   Additionally,
any contaminated topsoil resulting from the leaking drums,
had to  be removed and  safely  secured.   Therefore, Vertac
containerized  Che  contaminated  topsoil  along  with the
the  drums  of  2,4,5-T  still  bottoms  that  had  to  be
repacked.  Out of 3,000 drums stored in this area, approx-
imately 2,000 were  repacked.  Vertac  personnel  repacked
the drums in standard  85-galIon (323  1)  overpack drums.
While  the  special  storage  warehouse  was being constructed
during  the  fall   of   1979,   the  drums  and  contaminated
topsoil were  repacked together  and  kept outside until the
warehouse  was completed in late 1979.   The former above-
ground  storage  area was filled and capped as part of the
Hercules-Transvaal landfill in early 1980.

     The  special storage warehouse, located on the site as
shown at  the top of Figure 2, was built by an outside con-
tractor at a cost of  approximately $71,000.  The warehouse
measures  100 feet by  200 feet (30 x 61ra) and consists of  a
concrete  pad with  dikes  along  each  side  and  a  roof  of
steel.    Once  the warehouse  was completed,  the  repacked
drums  and  those  original  drums that  were  intact,  were
moved by  truck and placed in the warehouse.

     At  the  present   time  these  drums  are still  being
stored  in the special  warehouse and inspected  weekly  to
detect  any  leaks.    Vertac   is  examining  several  alter-
natives as to the ultimate disposal of these drums.  These
include various types of incineration methods.

Blow-out Area
     Vertac was required to cover and secure the  blow-out
area with asphalt or  clay  to prevent penetration  by sur-
face waters  under the  May 12,  1980 Temporary Injunction.
Vertac  hired  outside  contractors to  conduct the remedial
work at the  blow-out  area.   The remedial action taken was
to  cover  this  1.5  acre  (0.6  ha) area with asphalt  and
clay.   The  asphalt  was  placed  in  a  semicircle with   a
radius  of 200  feet (61m) around  the  former process  area.
Two-thirds of the  entire surface area  is now covered with
asphalt while  one-third" is covered with  clay.   The  clay-
covered portion is the outlying area that was contaminated
from valve  rupture blow-outs  during  trichlorophenol pro-
duction.  The capping of  the  blow-out  area took six weeks
and was completed by  the fall of 1980.

Equalization Basin
     Following a  September  26, 1980,  court  decision,
Vertac went ahead with  its original design for closing out
the equalization basin.   The equalization  basin  had been
300.70(c)(2)
removal of
contaminated
soils
300.70(b)(l)(ii)
(A)
surface seal
300.70(b)(l)(ii)
(A)
surface seal
                                     23-43
-------
 used to  neutralize  process wastewater  prior  to discharge
 to  the  Jacksonville  sewage  treatment  plant.    Vertac's
 design was  to  first construct a  new wastewater treatment
 system  and  have  that  operating  before  closing  out  the
 equalization basin.   Vertac acted as a general contractor
 for  the  work  at  the  equalization  basin  using  outside
 equipment and an outside  operator for the equipment.

      The location  of the  new wastewater treatment system
 in relation   to the   closed out  equalization basin can be
 seen in Figure  15a.   Figures 15b  and  c show the profile of
 the  equalization basin  in detail.   The new  system is an
 aboveground  pH  stabilization system  whereby highly  acidic
 2,4-D  process  wastewater (pH of  1.0)  is  neutralized  to a
 pH between 6 and 7 by a  lime dosing  apparatus.  This  pro-
 cess takes   place  in a  monitoring house  through the addi-
 tion of ground   lime  into an effluent mixing basin.   Once
 the wastewater   has  been  neutralized it  runs  through  an
 outfall and  into the Jacksonville  sewage treatment  plant.

      Once the new wastewater treatment  system  was  on-line
 in January  1981, Vertac started its  procedure  for  closing
 out the equalization basin.   The  remedial action for  the
 equalization basin included  the following steps:

      •  Dewatering of the basin

      •  Solidification  of the  sludge

      •  Installation of barrier walls and  French drain
      •  Capping  of the  entire  area.

      The  equalization basin was approximately   150  feet  by
 100  feet  (46 x  30m)  with  a  depth of  2 feet   (0.6m).
Approximately 225,000 gallons   (851,718  1) of water  had  to
removed and   filtered before the remaining process sludges
could be  solidified.  A dewatering system was devised by a
Vertac  engineer  using  equipment  available  at  the  Vertac
site.   Quite simply, the  water from  the basin was  pumped
through a crushed limestone  filter and then a sand  filter
that  were each  enclosed in tanks  that had been located  at
the  Vertac site.   The  filtered water  was then sent  to the
Jacksonville sewage treatment plant.  A  schmematic diagram
of  the  dewatering system  is  shown  in  Figure  16.   The
dewatering process, which  began in February  1981,  was not
completed until  early May  1981.

     As the dewatering progressed, Vertac began the  solid-
ification process.    The  sludges  left in the equalization
basin  were   very  high  concentrations of  chlorophenols,
 300.70(b)(2)(ii)
 neutralization;
 equalization
300.70(b)(2)(ii)
direct waste
treatment
methods
300.70(b)(2)
(iii)(C)
solidification
                                     23-44
-------
ro
uj
I
            Figure 15a.   Details of Closed Out Equalization Basin

            Source:       Walton, 1982.
-------
UJ
I
                         140*0* fit i
             a   fa
                                           Profile  of Equalization Basin
                                    Scale:   1"  =  20MIORZ  As of Date:  (llov,  1968)
                                             1"  =  5'  VERT
                  Figure 15b.  Details of  Closed Out Equalization Basin
                  Source:      Walton, 1982.
-------
              ft*
Lo
I
-P-
              JOS
                                                                                                  SS4
                  Figure  15c.   Details of Closed Out  Equalization Basin
                  Source:       Walton, 1982.
-------
KJ
OJ
I
4>
00
                  Figure 16.  Schematic Drawing of Dewatering  System
                  Source:     U.S. EPA, 1982.
-------
  phenoxy acids,  and other process wastes  from 2,4~D produc-
  tion.  These  were solidified through the addition of  Lime
  during May 1981.

      As the   equalization basin was being closed  out, two
  clay  barrier   walls  and  a  French   drain  system  were
  installed  around  the  equalization  basin.  The  barrier
  walls  were  built along the  north and  east sides of the
  closed  out  equalization  basin.  These  can  be  seen in
  Figures 15 and  2.  The  French drain, located on the Rocky
  Branch Creek  side of the  site,  was  installed  to collect
  subsurface runoff.   It  replaced  the interceptor ditch and
 barrier ditches built in  1964 when the  original equaliza-
  tion basin  was  installed.  The French  drain,  designed by
 Vertac, discharges into a 10,000 gallon (37,854 1) storage
  tank.  As  subsurface liquid  is  intercepted  by  the drain,
  it  is  is   pumped  into  the   storage  tank  where  it  is
 accumulated.    At  the  present  time,  an estimated  1,000
 gallons (3,800  1)  of leachate has been collected  in  the
 tank.  The drain is approximately 40 feet (12.2m) long and
 is made of  6  inch (15 cm) clay  pipe (It should  be  noted
 that a true French drain does not  contain  a pipe, however
 for purposes of consistency with  the  information gathered
 for this  case  study,  this  term has been  retained).

      The   entire  equalization  basin  was   backfilled  and
 capped  by   June  18,  1981.   The  volume of  the   backfilled
 equalization  basin  is estimated  to be 20,000 cubic  yards
 (15,200 m ) including the  clay  cover.   The clay  cover  is
 approximately  2  feet  (0.6m) deep.   During construction,  it
 was found  that  the  French  drain  and  barrier  walls were
 being  placed^over  weathered rock.   Construction  personnel
 packed clay into any  fissures  which were  present  along  the
 trench  as  a  precaution  against  vertical   migration   of
 leachate at  the  trench.

 Recycling
     Another  remedial action  that  has been  taken at  the
 Vertac  site is  one  that has  been  implemented  to  relieve
 the  previously  mentioned  cross-contamination   problem.
 Since October  1979,  Vertac has been accumulating drums of
 2,4-D process  wastes  but has  not  been  allowed  to dispose
 of  them because  they may have  been  cross-contaminated with
 2,4,5-T process  wastes  during a changeover  from 2,4,5-T
 production  to  2,4-D  production because the process equip-
 ment  was  not  changed.   A  special  TSCA  Section  6 ruling
 prohibited Vertac from removing  any   of  these  wastes
 generated prior  to May  12,  1980.   In  response  to this,
Vertac developed a recovery  process to separate and reuse
 2,4-D still  bottoms.   This  process  has  been  used since
July  1982   and  appears  to  be  working well.   The  2,4-D
wastes generated prior to May  12,  1980,  have been used as
300.70(b)(l)
impermeable
barriers;
leachate control
300.70(b)(l)(ii)
(A)
surface seal
                                     23-49
-------
raw  materials  for  further  2,4-D  production  with  EPA
approval.   Any 2,4-D production-related trash is disposed
of in an  approved PCB landfill. The potential for  further
cross-contamination has  been eliminated by Vertac  through
the use of new process equipment.

Alternative Technology
     Late  in   1979,  Vertac  wanted  to  start  up   2,4,5-T
produc tion again  using a  chemical  destruct ion technology
which  they  had  patented.    The  idea  was  to  manufacture
2,4,5-T  from  the  toluene  still  bottoms  at the  site and
then chemically destroy any waste that would be generated.
Vertac applied  for a  research  and  development grant from
EPA to  pi lot  this  technology;  however, EPA  had  reserva-
tions about produc ing  any more dioxin  at  this site which
might cause  further hazard,  therefore  the grant  was not
approved.

Future Reraed ial Actions
     At the present  time,  Vertac is under  court  order to
proceed with  clean-up  activities at  the  cooling  pond and
Lake Dupree as  well as continual  monitoring,  inspection,
and  development  of a  hazardous  waste management plan.
Because these  issues  are  ongoing  and  involve  many legal
aspects, the  remed ial  actions being  considered  cannot be
disc losed at this  time.
300.70(c)
off-site trans-
port for secure
disposit ion
COST AND FUNDING

Source of Funding

     Vertac  has  provided  most of the funds  for reraed ial
action,  monitoring,  and  analysis  at the plant site.  A
Vertac official estimates that the total cost  as of August
1982 was approximately $1,946,000.  Hercules has agreed to
pay for up to $75,000 for remedial work at the Reasor-Hi11
landf i 11  area  and  up  to $40,000  for the  environmental
study required by the Consent Decree.  Vertac  has paid  for
the  remaining costs,  which  are  over  94  percent  of  the
est imated  total  costs  as of  August  1982.    Negotiat ions
between the companies over cost sharing are continuing.

Selection of Contractors

     Vertac  served  as  its  own general contractor,   using
its  personnel,  machinery and  materials to  implement  the
remedial  ac tion  plans.   This  work  included;  redrumming
3,000 drums  containing  2,4,5-T still bottoms; maintaining
drums  containing  2,4-D  wastes   for  eventual   recyc1 ing;
developing a  recyc1 ing  process;  developing an alternative
300.68(c)
private clean-up
                                     23-50
-------
 process wastewater  treatment  system;  developing a solidi-
 fication   process   for  the  equalization  basin;   and
 monitoring, sampling, and laboratory analyses.

      Vertac contracted with McClelland Engineers of Little
 Rock, Arkansas on a cost plus fixed fee basis to work with
 the State  in conducting  the  initial  subsurface  investiga-
 tion at the  site.   McClelland was selected  for this  work
 based  on   its   reputation.    Southwestern  Engineers,  of
 Little Rock, was  hired by EPA  to do a  second  subsurface
 investigation at  the Vertac  site.    Subsequently,  Vertac
 hired  the  firm to  conduct   permeability  and  compaction
 tests  on  the  landfill  caps.    Vertac  hired  Shreeve
 Engineers, which  is based in Little  Rock, to  prepare  an
 engineering report  for capping and containing the  Reasor-
 Hill  and   Hercules-Transvaal  landfills.    Shreeve was
 selected because it previously had done work for Vertac  at
 the Jacksonville plant, and was  hired  on a  cost  plus  fixed
 fee basis.

      Helena Construction  Company  based in  West  Helena
 Arkansas,  was selected  by  Vertac to  excavate,  transport[
 place,  and compact  clay  for  the   landfill caps,  according
 to specifications  in the Shreeve  report.  Vertac  selected
 Helena  because  it  was the low bidder, and used  a  lump sum
 contract.

      As required  by  the  Consent  Decree,   Vertac  hired
 Developers,  International Services Corporation  (DISC), of
 Memphis, Tennessee  to review on-site conditions.  DISC was
 selected  based  on   its  bid and  good reputation  and  was
 hired  under  a   cost  plus  fixed   fee  contract.    Also as
 required   in   the  Consent   Decree,  Vertac   selected
 Environmental and Toxicological Consultants (ETC) to study
 and  report on off-site  conditions.   ETC was chosen based
 on  bid  and  reputation.   A lump  sum contract  was used.
 Vertac  hired Environmental Protection  Systems  (EPS),  of
 Pensacola,  Florida  and  Jackson,  Mississippi,  pursuant to
 the  Consent  Decree  to do sampling and analysis on process
 wastewater  and the  cooling  pond  for phenol, chlorophenol,
 chlorobenzene, and  phenoxy  acids.   This  firm was selected
 because of  its bid  and  reputation  and  a lump sum contract
 was used.  Specialized Assay (SA) of Nashville, Tennessee,
 was hired by Vertac  in  accordance  with the  Consent Decree
 to perform  sampling  and  analysis  relating only to dioxin.
 Selected by bid and reputation, SA worked under a lump sum
 contract.

Project  Costs

     Analysis of costs for this remedial action depends on
the  nature  and   extent  of data made  available  by  Vertac

                                     23-51
-------
Chemical Corporation, because this is a privately fLnanced
clean-up and Vertac did much of the work itself.  A Vertac
representative  provided   summary  information  regarding
spec if ic  reined ial  act ions,  such  as  for  the  Reasor-Hi 11
Landfi 11  or  the equalization  basin,  which he  then  broke
down into  the  costs  for outside  contractors  and Vertac' s
own costs.   It should  be  noted  that the  latter  figures
include  Vertac's   overhead   but   that  the  proportion  of
overhead  to  total  cost  was  not  given.   The  task  of cost
analysis  is  further  complicated  by  the  fact  that  for  a
period  of  time  (from  June  15,  1979,  the  date  of  the
Administrat ive Order,  to  September  22, 1979)  Vertac
stopped  all  produc tion  at  the   plant  and  shifted  all
suitable  manpower   to   complying  with   the  Order.    The
Federal  District Court  noted  that  this  resulted in a loss
to Vertac of $1 million for 1979 based  on gross sales of
$8 million.  While it might  be  argued that the $1  million
represents the opportunity cost of the remedial work, this
does not  aid  the  analysis of actual  costs.   In addition,
some details re 1at ing to  costs  are not  available,  such as
the number  of man-days worked,  types of  equipment  used,
and  amounts  of materials  used.   Consequently,  in  some
instances  it   is   impossible  to  compute  meaningful  unit
costs,

     Nevertheless,   the  available data  allow   a  general
discussion of costs.   These data are  presented in Table 1.
Cost figures supplied by a Vertac representative regarding
several  specific remed ial  actions taken at the plant total
$2,016,000.   Broken  down  according to the major areas of
remedial  work  discussed  in  this  study,  the  costs  are as
follows:

     *   Reasor-Hill landfill area ($159,500)

     •  Hercules-Transvaal  landfill  and  above-ground drum
         storage areas ($135,000)

     •   Blow-out area ($37,000)

     •   Equalization basin ($143,000)

     •   2,4,5-T waste management ($370,000)

     •   2,4-D waste management ($931,000).

These cost items are discussed in more detail below.

Landfills and Above-Ground Drum Storage Area
     A Vertac  official  estimates  that a total of $295,000
was spent  for  chemical  analysis,  engineering studies and
                                     23-52
-------
                TABLE  1.  SUMMARY OF COST INFORMATION - VERTAC CHEMICAL CORPORATION, JACKSONVILLE, ARK
ho
LO
Task
I.
Reasor-Hlll Landfill
A. Engineering studies and
chemical analysis
B. Capping and barrier walla
Subtotal
II. Hercules-Transvaal Landfill
& old drum storage area
A. Engineering studies and
chemical analysis
B. Capping
Subtotal
III. Blow-out area
A. Engineering Study
B. Clay and asphalt capping
Subtotal
IV. Equalization basin
A. Engineering study and
chemical analysis
B. Lime for solidification
C. Capping .barrier walls
and French Drain
0. Construction of above ground
replacement system
Subtotal
Quantity

















Actual .
Expenditure ^a'


$63, 500 (b)
$96,000
$159,500

$62, 500 (b)
$73,000
5135,500

$15,000
-------
                                              TABLE  1.   (continued)
LO
I
-P-

Task
V. 2,4,5-T Waste Management
A. Engineering studies and
chemical analysis
B. Re-drummlng(materlal and
labor)
C. Construction of drum
Su'-l-tal
VI. 2,4,-D Waste Management
A. Engineering studies and
chemical analysis
11, Ru-drummlug (material and
labor)
•;. Construction of new
Subtotal
'11. Misc. Studies
t. Effectiveness of Remedial
Actions
1. Engineering studies and
chemical analysis
t. Sampling and Analysis
1. Process waste water
2. Coo Ling pond
3. Reimbursement of
state's costs
Subtotal
TOTAL
Quantity


3,000 drums(c)




10,000 drums(c)









Actual
Expenditure

$30,000(b)
$269,000 (b)
$71,000 (b)
$370,000

$75,000 (b)
$156,000 (b)
$700,000 (b)
$931,000



$200,000 (b)
$15,000 (b)
$10,000 (b)
$15,000 (d)
$240,000
Unit Cost


$67/drum (c)




$67/drum(c)










Funding Source

Vertac
Vertac
Vertac


Vertac
Vertac
Vertac




Vertac
Vertac
Vertac
Vertac

	 ~* — j — f 	 "r^^~"
Performance













1/9/82*
8/10/82
1/9/82-preaent
n n

$2.016.000 6/i3//*-preaeni
          (a) all data  supplied  by Vertac
          (b) includes  in-house  and outside work
(c)  estimate by Vertac Official
-------
 plans, and remedial work on  the  Reasor-Hill  and  Hercules-
 Transvaal  landfills  and the  former above-ground  storage
 area.  Of  this  amount,  approximately $41,000 was  paid  to
 both McClelland  Engineers  for the subsurface  investigation
 and Shreeve Engineers for the engineering  study  and  plan.
 Vertac broke the $41,000 figure  into $21,000 and  $20,000
 for work at the Reasor-Hill  and  Hercules-Transvaal areas,
 respectively (the  company treated the drum  storage  area  as
 part  of  the Hercules-Transvaal  area cost  for purposes) .
 About  $5,000 was  paid to  Southwestern  Engineers for
 permeability and  compaction  tests  on  the landfill  caps
 (since this  was  not  broken down   further,  it  will   be
 assumed that the cost was divided equally  between  the two
 landfills).  Vertac also estimated  its  in-house  costs for
 monitoring, chemical  analysis and supervision, as well  as
 provision of an  undetermined amount of labor,   materials
 and equipment,  to  total $80,000, divided  evenly between
 the landfills.   Thus,  the  total estimated  engineering and
 analytical  costs were $63,500 for Reasor-Hill and $62,500
 for Hercules-Transvaal.

      There  was  no  expenditure for  the  clay used  to cap
 these  areas because the  clay was taken  from another  loca-
 tion on-site.  Consequently,  the  remaining  item of expense
 for the landfill remediation was the contract with Helena
 Construction  Company  for moving  and compacting  the  clay
 caps  and   constructing  the  clay barrier  walls  at  the
 Reasor-Hill  landfill.    The  Hercules-Transvaal   cap  cost
 $73,000,  while  the  Reasor-Hill cap and barrier walls  cost
 $96,000.  A Vertac  official  stated that  the unit  cost for
 this  construction  work  was   $2.85  per  cubic  yard
 ($2.18/m  );  while  no  figure  was  given  for  the amount  of
 clay used,  this can be computed to be approximately 25,614
 cubic  yards  (19,584.5  m3)   fr>r  Hercules-Transvaal  and
 33,684 cubic yards (25,754.9 m ) for Reasor-Hill.

 Equalization Basin
     Vertac designed  and  supervised   the work on  the
 equalization basin.   The company  hired  outside operators
 and  equipment on an hourly  basis  to  do  the construction,
but  Vertac  officials  could  not   give   the  names of  the
 people  or  types  of equipment  used,  nor  the  hourly  rates
charged.  Total  cost  was estimated  to be $93,000 which  a
Vertac official  broke  down as follows:

     •  Monitoring,  chemical  analysis,   development  of  a
        solidification  process  for basin sludges,  and
        development  of  an   above-ground  alternative
        treatment systera-$45,000

     •  Lime for  solidification of sludges-$10,000  for an
        undisclosed  amount

                                     23-55
-------
     •  Capping the area with clay, topsoil and grass seed
        and  instal1 ing  the  French drain  and  clay barrier
        walls-$38,000.

The  total  figure  of $93,000 does  not  include  the cost of
buiId ing  the  above-ground  treatment  system,   although  a
company official estimated that this cost about $56,000.

Blow-out Area
     Vertac was  the  general contractor  for  remedial work
on  the  blow-out   area  and  hired  outs ide  personnel  and
equipment  to  construct  the  asphalt and clay cap.   Vertac
stated  that  the total  remedial  action cost  was  $37,000,
which included:  sampling and chemical analysis at $15,000
and capping with asphalt and clay at $22,000.   No data are
available regarding the portion of capping costs allocable
to asphalt as opposed to clay capping.

Monitoring, Sampling and Analysis
     Vertac has spent a substantial amount of money pursu-
ant  to  administrative  or  court  orders  to determine  the
nature  and extent  of  both  on-site and off-site pollution.
In add it ion  to  the monitoring and  chemical  analysis done
specifically  for  the  two landfill  areas  discussed previ-
ously,  Vertac had  additional  work done  on other  areas.
DISC performed a $125,000 study of on-site conditions such
as geology,  ground water,  surface water  runoff,  surface
soils,  and the  cooling water  pond.    A Vertac  official
estimated that Vertac spent an  additional  $75,000 for its
own  in-house  sampling  and  analytical  work  related  to the
DISC study.   Thus, a total  of  $200,000 was  spent  to study
on-s ite cond it ions.

     Environmental and Toxicological Consultants performed
off-site monitoring  and analytical  work on Rocky  Branch
Creek,  a drainage  ditch running from  the eastern  side of
the  plant  to Rocky  Branch  Creek,  and Bayou  Meto.   This
work cost $20,000.  Vertac  has  not spec ified  any  in-house
costs relating to this study.

     The  Consent   Decree  also  required  Vertac  to  have
chemical  analyses  for  dioxin performed  on both  cooling
pond and off-site  samples.  This  work went  to  Specialized
Assay at a  cost  of $13,000.  Vertac  was  ordered  to reim-
burse  the  State  of Arkansas  for  the  costs   of  certain
analytical  work  regarding  dioxin,  which  amounted  to
$15,000  to  be  paid  over 3  years.    The  total  cost  for
dioxin  analysis,  then,  was  $28,000.   Vertac  specified no
in-house costs associated with these studies.

     In  addition  to  the   dioxin  analysis,  Vertac  was
required by the Consent Decree to analyze samples from the

                                     23-56
-------
 cooling  pond,  process wastewater,  and  off-site  samples.
 Analytical work  was  to be  performed  for  chlorinated
 phenols,  chlorinated benzenes, chlorinated  anisoles,
 toluene  2,4-D,  2,4,5-T and  2,4,5-TP.   Environmental
 Protection  Systems  did  this  work  for  $15,000,  which  a
 Vertac official broke down to costs of $5,000 and $10,000
 for work  relating  to process  wastewater  and the cooling
 pond,   respectively.   Vertac  also  identified  $10,000 of
 in-house costs relating  to analytical work on the process
 wastewater.   In  sum,  the chemical  analysis  for the  sub-
 stances listed above  came to  $15,000  for process waste-
 water  and $10,000  for  the cooling pond.

 Waste  Management  for  2,4-D and  2,4,5-T
      The Consent  Decree  required  Vertac to develop a waste
 management plan  for  its  2,4-D  and  2,4,5-T  wastes,
 including  sampling,  chemical  analysis,   and redrumming.
 Furthermore,   Vertac  was required  to   "exercise  best
 efforts" to reduce  the  volume of  chemical  wastes stored
 on-site.    Vertac  did  all of  the redrumming  work itself.
 An official  estimated  that  about $269,000 was  spent
 redrumming 2,4,5-T wastes and $156,000  redrumming  2,4-D
 wastes.   These  figures  included  materials and  labor.
 Vertac stated  that  repacking  drums cost  about  $67  each.
 An official estimated that it  took  about  2  1/2  hours per
 drum   to  do the repacking.   A Vertac  official  estimated
 that the  company spent $105,000 for  sampling  and analyzing
 wastes, broken  down   to  $30,000   for  2,4,5-T wastes  and
 $75,000 for 2,4-D wastes.  The latter  sum included  costs
 of developing  a process to reuse  the 2,4-D wastes.  Vertac
 reported  that  it also  spent money to construct new facili-
 ties at its plant as well  as  to  modify  the  manufacturing
 process in  order  to   reduce  the   amount  of   new chemical
 wastes.    Approximately $71,000  was  spent  for   work
 associated  with  2,4,5-T  wastes  and  $700,000  for  2,4-D
 wastes.  The former amount represents the cost of building
 a  drum storage warehouse  and  the  latter  figure represents
 the  cost  of  modifying  the   2,4-D  formulating  process.
 Total  figures  for the various costs of managing both  types
 of wastes are  as follows:

     •   Sampling, analysis  and development   of  recycling
         process for 2 ,4-D-$105,000

     •   Redrumming - $425,000

     •   Construction of new facilities or  modification of
         process - $771,000.

Looking at these costs  across  waste types,  it  appears  that
managing 2,4-D  wastes  cost $931,000 and managing  2,4,5-T
                                     23-57
-------
wastes  cost $370,000.   Total  waste  management  cost  was
$1,301,000  as of August 1982.
PERFORMANCE EVALUATION

     At  the present  time  it  is  difficult to determine the
effectiveness  of  the remedial  action  at the Vertac site,
primarily because the contamination present was the result
of  several  factors  (combined  in many  instances),  all of
which have not  been  remedied.   Furthermore,  indicators of
contamination  off-site  in locations such  as Rocky Branch
and Lake Dupree have yet  to be  cleaned up.  Once they are
totally  cleaned  up,  continued  monitoring  will  indicate
whether  leaching  and  seepage  are  still occurring.    A
proposal  has   recently  been made  to;   (1) clean  up  Lake
Dupree,  (2) discontinue use of  the cooling pond, (3) clean
up  the  cooling pond, (4) establish a  strict plant house-
keeping  plan,  (5) cap the  surface  of   the  central ditch,
and (6)  establish a  new  east  drainage  ditch while filling
in  the  existing  ditch.   The proposal also  includes
stipulations concerning monitoring  that will be conducted
at  the   east  drainage ditch,   the  west  branch  of  Rocky
Branch  Creek  and  the confluence of the branches  of Rocky
Branch Creek as control points  to determine whether DISC's
groundwater mass  low balance  is correct.  DISC calculated
that  for the  entire site,  one  pound  per  year  of soluble
pollutants  would   leak  or  flow.    Therefore,   an overall
evaluation is difficult to make at this  time.  Hence, each
remedial action is evaluated independently below.

Reasor-Hill Landfi11 Area
     The  clay  cap  and  barrier  walls  at  the  Reasor-Hill
landfill area  have  apparently  reduced  the infiltration of
surface  precipitation  and  are  probably catching  a  good
amount of leachate  in  the area; preventing it  from infil-
trating into  or  out  of  the  Reasor-Hill  site.    The
effectiveness  of  these   remedial  actions   in  mitigating
vertical  migration  of contaminants   is   presently  being
monitored with  3  newly  installed monitoring  wells (#' s 9,
15 &  16),  in  addition to original monitoring  wells  1,  2
and 3 which are nested together to  monitor vertical flow.
Al though insitu  permeability tests  conducted by  DISC
indicate that  permeability  decreases with depth,  there is
still no monitoring data available with which a conclusion
can be  drawn  concerning  further contamination  of ground
water.

Hercules-Transvaal Landfill Area
     The  same  conclusions  reached  concerning  the  effec-
tiveness of  the remedial action  at  the  Reasor-Hill  area
                                     23-58
-------
  are  applicable to  the remedial  action at  the Hercules-
  Transvaal  area.   The clay cap  prevents surface infiltra-
  tion;  however,  there is no monitoring data available with
  which  a  determination  can   be  made   concerning  further
  vertical  contaminant migration.    It  should  also be noted
  that despite what monitoring  results are inside this area,
  no barrier  walls  have been installed,  hence the potential
  for  both  lateral   and  vertical  movement  outside  the
  confines of the area exists.

  Former Above-Ground  Storage Area
      The removal  and repacking  of  the approximately 3,000
  drums  of 2,4,5-T  still  bottoms,  as well as the container-
  ization of contaminated soil  into a specially built above-
  ground  warehouse,  appears  satisfactory.    Vertac  is  now
  choosing  the  ultimate  disposal  method  for  these  drums.
 New  regulations  proposed  on April  4,   1983  will  make
 disposal of  the 2,4,5-T  still  bottoms possilbe once  the
  regulations are finalized.

      The capping  of  the  area as  part  of the  Hercules-
 Transvaal landfill  area was  a practical  remedy;  however,
 the  effectiveness  of  this  action cannot  be  determined
 totally for the reasons mentioned above.

 Blow-out Area
      The objective of the remedial action  at  the blow-out
 area  was to  prevent  the infiltration of surface precipita-
 tion  which  would in  turn prevent  runoff of contaminants  to
 the east.   The asphalt cap placed  over  the former  process
 area  should prove satisfactory  as  long as  it  is  checked
 periodically for cracks.   Although  the  asphalt  is suscept-
 ible  to deterioration  and corrosion  should  any chemical
 spills  occur at or   near  this area, it  was  selected and
 applied due to  the  heavy traffic  occurring  in the  area.
 If  clay were the only cap  it would  be much  too  easily worn
 away.   The clay  capped  portion, on  the  other hand, may not
 be  as  susceptible   to  cracking.    Furthermore,   if  any
 chemical  contamination  were  to   occur,  the clay may not
 deteriorate  as  completely  as  the  asphalt.   The clay could
 easily  be  removed and  replaced  with  on-site  clays   if
 contamination  occurred,  whereas   replacing  the  asphalt
 would not be as  readily  achieved.

 Equalization Basin
     The equalization basin that  was  installed has  proven
 to  be  effective  as  a  wastewater  treatment system.
 Constant monitoring  is  in  progress  to  ensure  that  the  pH
of the wastewater is  between 6 and 7 prior to discharge to
 the Jacksonville sewage treatment plant.
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     The  closure  procedure Vertac  implemented  appears to
be  effective  as  far  as  preventing  the  infiltration of
surface  water  through  the  closed  out  area.   The French
drain  system  and  barrier  walls  appear to  be  containing
leachate  seeps  laterally;   however,   as  stated   earlier,
monitoring  data  has  not  been   available  with   which  a
determination  can  be  made   concerning further   vertical
migration of contaminants.  Further, the barrier walls and
the  French  drain  were constructed over  weathered rock.
Although  any fissures  which  were  present under  the trench
were  packed  with clay,  the  effectiveness  of  this method
over time may be questionable.

Recycling
     The  procedure  of separating and  reusing  2,4-D still
bottoms  for  2,4-D  production  has been  very effective in
prevent ing  the  generat ion   of add it ional  waste   at  the
Vertac site.   The  problem of  crosscontamination has been
alleviated through  the use  of new  equipment.   Vertac  now
d isposes  of any  wastes generated  from 2,4-D production in
an approved PCS landfill.
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                                  BIBLIOGRAPHY
 Guild,  Dennis.   August 10,  1982.   Case Study Personal Interview Conducted at
      U.S.  EPA Region VI office with Mr. Dennis Guild, Environmental Engineer
      in U.S.  EPA Region VI  Superfund Branch, Dallas,  TX.

 Hughes, Doice.   August 11,  1982.   Case Study Site Visit Made to Vertac Site,
      Jacksonville,  AR.  Personal  Interview Conducted  With Mr.  Doice Hughes of
      Arkansas Department of Pollution Control and Ecology, Little Rock, AR.

 Karkkainen,  Richard D.  August 11,  1982.   Case Study  Site Visit Made to Vertac
      Site, Jacksonville, AR.   Personal Interview Conducted With Mr. Richard
      Karkkainen,  Director,  Environment and Safety, Vertac Chemical Corpora-
      tion, Memphis, TN.

 Karkkainen,  Richard D.  June  1982 - January 1983.   Personal Communication.
      Vertac  Chemical Corporation,  Memphis, TN.

 Sekelyhidi,  Irare  J.  11  August 1982.   Case Study Site Visit Made to Vertac
      Site, Jacksonville,  AR.   Personal Interview Conducted With Mr. Imre
      Sekelyhidi,  Field Investigator for U.S.  EPA Region VI from Ecology and
      Environment, Inc.,  Dallas, TX.

 Sekelyhidi,  Imre  J.   June 1982 -  November  1982.   Personal Communication.
      Ecology  and  Environment,  Inc.,  Dallas,  TX.

 Shreeve, Kent.  November  15,  1982.   Personal  Communication.  Shreeve
      Engineers, Little Rock,  AR.

 Soil  Conservation Service.  September  1975.   Soil  Survey of Pulaski County,
      Arkansas.  U.S.  Department of  Agriculture  in  Cooperation with Arkansas
      Agricultural Experiment  Station.

U.S.  EPA Region VI  Superfund  Branch Files.  August  10,  1982.  Case Study
      File  Review.   Conducted  at U.S. EPA Region  VI  with  the  Assistance  of
      Mr. Dennis Guild, U.S.  EPA Region VI  Superfund Branch,  Dallas,  TX.

Walton, John L. Sr.,  and Rohn  F. Droye, Jr.   October  1982.   Final  Report  for
      Environmental  Assessment  Study, Vertac Chemical  Corporation Site,
      Jacksonville, AR.  Developer's International  Services Corporation,
     Memphis, TN.
*USGPO:  1984-759-102-890
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