EPA542-R-98-014
                                  September 1998
Remediation Case Studies
Ground water Pump and Treat
(Nonchlorinated Contaminants)

Volume 10
                  Federal
                Remediation
                Technologies
                 Roundtable
               
                Prepared by the

            Member Agencies of the
   Federal Remediation Technologies Roundtable

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Remediation Case Studies:
Groundwater Pump and Treat
(Nonchlorinated Contaminants)
    Volume 10
    Prepared by Member Agencies of the
    Federal Remediation Technologies Roundtable
       Environmental Protection Agency
       Department of Defense
           U.S. Air Force
           U.S. Army
           U.S. Navy
       Department of Energy
       Department of Interior
       National Aeronautics and Space Administration
       Tennessee Valley Authority
       Coast Guard
                September 1998

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                                           NOTICE
This report and the individual case studies and abstracts were prepared by agencies of the U.S.
Government. Neither the U.S. Government nor any agency thereof, nor any of their employees, makes any
warranty, express or implied, or assumes any legal liability or responsibility for the accuracy,
completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that
its use would not infringe privately-owned rights. Reference herein to any specific commercial product,
process, or service by trade name, trademark, manufacturer, or otherwise does not imply its endorsement,
recommendation, or favoring by the U.S. Government or any agency thereof.  The views and opinions of
authors expressed herein do not necessarily state or reflect those of the U.S. Government or any agency
thereof.

Compilation of this material has been funded wholly or in part by the U.S. Environmental Protection
Agency under EPA Contract No. 68-W5-0055.
                                                11

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                                         FOREWORD

This report is a collection of fourteen case studies of groundwater pump and treat (nonchlorinated
contaminants) projects prepared by federal agencies. The case studies, collected under the auspices of the
Federal Remediation Technologies Roundtable, were undertaken to document the results and lessons
learned from technology applications. They will help establish benchmark data on cost and performance
which should lead to greater confidence in the selection and use of cleanup technologies.

The Roundtable was created to exchange information on site remediation technologies, and to consider
cooperative efforts that could lead to a greater application of innovative technologies.  Roundtable member
agencies, including the U.S. Environmental Protection Agency, U.S. Department of Defense, and U.S.
Department of Energy, expect to complete many site remediation projects in the near future.  These
agencies recognize the importance of documenting the results of these efforts, and the benefits to be realized
from greater coordination.

The case study reports and abstracts are organized by technology in a multi-volume set listed below.
Remediation Case Studies, Volumes 1-6, and Abstracts, Volumes 1 and 2, were published previously, and
contain 54 case studies. Remediation Case Studies, Volumes 7-13, and Abstracts, Volume 3, were
published in September 1998. Volumes 7-13 cover a wide variety of technologies, including groundwater
pump and treat of nonchlorinated contaminants (Volume 10). The 14 pump and treat case studies in this
report include completed full-scale remediations and large-scale field demonstrations.  In the future, the set
will grow as agencies prepare additional case studies.

                                          1995 Series

       Volume 1:      Bioremediation, EPA-542-R-95-002; March 1995; PB95-182911

       Volume 2:      Groundwater Treatment, EPA-542-R-95-003; March 1995; PB95-182929

       Volume 3:      Soil Vapor Extraction, EPA-542-R-95-004; March 1995; PB95-182937

       Volume 4:      Thermal Desorption, Soil Washing, and In Situ Vitrification, EPA-542-R-95-005;
                      March 1995; PB95-182945

                                          1997 Series

       Volume 5:     Bioremediation and Vitrification, EPA-542-R-97-008; July 1997; PB97-177554

       Volume 6:      Soil Vapor Extraction and Other In Situ Technologies, EPA-542-R-97-009;
                       July 1997; PB97-177562

                                          1998 Series

        Volume 7:      Ex Situ Soil Treatment Technologies  (Bioremediation, Solvent Extraction,
                       Thermal Desorption), EPA-542-R-98-011; September 1998

        Volume 8:      In Situ Soil Treatment Technologies (Soil Vapor Extraction, Thermal Processes),
                       EPA-542-R-98-012; September 1998
                                               111

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                                     1998 Series (continued)

        Volume 9:     Groundwater Pump and Treat (Chlorinated Solvents), EPA-542-R-98-013;
                      September 1998

        Volume 10:    Groundwater Pump and Treat (Nonchlorinated Contaminants), EPA-542-R-98-014;
                      September 1998

        Volume 11:    Innovative Groundwater Treatment Technologies, EPA-542-R-98-015;
                      September 1998

        Volume 12:    On-Site Incineration, EPA-542-R-98-016; September 1998

        Volume 13:    Debris and Surface Cleaning Technologies, and Other Miscellaneous
                      Technologies, EPA-542-R-98-017; September 1998
                                           Abstracts

        Volume 1:     EPA-542-R-95-001; March 1995; PB95-201711

        Volume 2:     EPA-542-R-97-010; July 1997; PB97-177570

        Volume 3:     EPA-542-R-98-010; September 1998
Accessing Case Studies

The case studies and case study abstracts are available on the Internet through the Federal Remediation
Technologies Roundtable web site at: http://www.firtr.gov. The Roundtable web site provides links to
individual agency web sites, and includes a search function. The search function allows users to complete
a key word (pick list) search of all the case studies on the web site, and includes pick lists for media treated,
contaminant types, and primary and supplemental technology types. The search function provides users
with basic information about the case studies, and allows them to view or download abstracts and case
studies that meet their requirements.

Users are encouraged to download abstracts and case studies from the Roundtable web site.  Some of the
case studies are also available on individual agency web sites, such as for the Department of Energy.

In addition, a limited number of hard copies are available free of charge by mail from NCEPI (allow 4-6
weeks for delivery), at the following address:

       U.S. EPA/National Center for Environmental Publications and Information (NCEPI)
       P.O. Box 42419
       Cincinnati, OH 45242
       Phone:  (513) 489-8190 or
               (800) 490-9198
       Fax:    (513) 489-8695
                                              IV

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                                 TABLE OF CONTENTS
Section

INTRODUCTION .......................................... • ...................... l

GROUNDWATER PUMP AND TREAT (NONCHLORINATED CONTAMINANTS)
CASE STUDIES [[[ 9

       Pump and Treat of Contaminated Groundwater at the Baird and McGuire
       Superfund Site, Holbrook, Massachusetts  ........................................ H

       UV Oxidation at the Bofors Nobel Superfund Site, Muskegon, Michigan ................. 33

       Pump and Treat of Contaminated Groundwater at the City Industries Superfund
       Site, Orlando, Florida  ............. .......................................... 57

       Pump and Treat of Contaminated Groundwater at the King of Prussia Technical
       Corporation Superfund Site, Winslow Township, New Jersey ......................... 77

       Pump and Treat of Contaminated Groundwater at the LaSalle Electrical Superfund
       Site, LaSalle, Illinois [[[ 95

       Pump and Treat of Contaminated Groundwater at the Mid-South Wood Products
       Superfund Site, Mena, Arkansas .............................................. I*1

       Pump and Treat of Contaminated Groundwater at the Odessa Chromium I
       Superfund Site, OU 2, Odessa, Texas .......................................... 129

       Pump and Treat of Contaminated Groundwater at the Odessa Chromium IIS
        Superfund Site, OU 2, Odessa, Texas .......................................... 147

        Groundwater Containment at Site FT-01, Pope AFB, North Carolina ................... 165

        Groundwater Containment at Site SS-07, Pope AFB, North Carolina ............. . ..... 175

        Pump and Treat and Containment of Contaminated Groundwater at the
        Sylvester/Gilson Road Superfund Site, Nashua, New Hampshire ...................... 185

        Pump and Treat of Contaminated Groundwater at the United Chrome Superfund
        Site, Corvallis, Oregon  [[[ 205

        Pump and Treat of Contaminated Groundwater at the U.S. Aviex Superfund Site,
                                                                                      9*7 1

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This Page Intentionally Left Blank
              VI

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                                       INTRODUCTION

Increasing the cost effectiveness of site remediation is a national priority.  The selection and use of more
cost-effective remedies requires better access to data on the performance and cost of technologies used in
the field. To make data more widely available, member agencies of the Federal Remediation Technologies
Roundtable (Roundtable) are working jointly to publish case studies of full-scale remediation and
demonstration projects. Previously, the Roundtable published a six-volume series of case study reports.
At this time, the Roundtable is publishing seven additional volumes of case study reports, primarily focused
on soil and groundwater cleanup.

The case studies were developed by the U.S. Environmental Protection Agency (EPA), the U.S.
Department of Defense (DoD), and the U.S. Department of Energy (DOE). The case studies were
prepared based on recommended terminology and procedures agreed to by the agencies. These procedures
are summarized in the Guide to Documenting and Managing Cost and Performance Information for
Remediation Projects (EPA 542-B-98-007; October 1998). (The October 1998 guide supersedes the
original Guide to Documenting Cost and Performance for Remediation Projects, published in March 1995.)

 The case studies present available cost and performance information for full-scale remediation efforts and
 several large-scale demonstration projects. They are meant to serve as primary reference sources, and
 contain information on site background and setting, contaminants and media treated, technology, cost and
 performance, and points of contact for the technology application. The studies contain varying levels of
 detail, reflecting the differences in the availability of data and information. Because full-scale cleanup
 efforts are not conducted primarily for the purpose of technology evaluation, data on technology cost and
 performance may be limited.

 The case studies in this volume describe 14 pump and treat applications used to remediate contaminated
 groundwater, including 11 applications used to remediate contaminated groundwater, one application used
 only to contain groundwater, and two applications used to recover free product.  For these applications,
 groundwater was contaminated with a variety of contaminants including chlorinated solvents, petroleum
 hydrocarbons, polycyclic aromatic hydrocarbons (PAHs), pesticides/herbicides, and heavy metals (e.g.,
  chromium). The quantity of groundwater treated in these applications ranged from 23 to 1,200 million
  gallons, and project durations ranged from two to 13 years.  Many of these applications are ongoing, and
  the case studies are interim reports about these applications.

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 Table 1 provides a summary including information on technology used, contaminants and media treated,
 and project duration for the 14 pump and treat projects in this volume. This table also provides highlights
 about each application. Table 2 summarizes cost data, including information on quantity of media treated
 and quantity of contaminant removed. In addition, Table 2 shows a calculated unit cost for some projects,
 and identifies key factors potentially affecting technology cost. (The column showing the calculated unit
 costs for treatment provides a dollar value per quantity of groundwater treated and contaminant removed,
 as appropriate.) Cost data are shown as reported in the case studies and have not been adjusted for
 inflation to a common year basis. The costs should be assumed to be dollars for the time period that the
 project was in progress (shown on Table 1 as project duration).

 While a summary of project costs is useful, it may be difficult to compare costs for different projects
 because of unique site-specific factors. However, by including a recommended reporting format, the
 Roundtable is working to standardize the reporting of costs to make data comparable across projects.  In
 addition, the Roundtable is working to capture information in case study reports that identify and describe
the primary factors that affect cost and performance of a given technology. Key factors that potentially
affect project costs for pump and treat applications include economies of scale, concentration levels in
contaminated media, required cleanup levels, completion schedules, matrix characteristics such as soil
classification, clay content and/or particle size distribution, hydraulic conductivity, pH, depth and thickness
of zone of interest, total organic carbon, oil and grease or total petroleum hydrocarbons, presence of
NAPLs, and other site conditions.

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Table 1. Summary of Remediation Case Studies: Groundwater Pump and Treat
                     (Nonchlorinated Contaminants)
', ' ,
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Baird and McGuire Superfund Site, MA
(Pump and Treat with Aeration, Air Stripping,
Chemical Treatment, Clarification, and Filtration)
Bofors Nobel Superfund Site - OU 1, MI
(Pump and-Treat with Air Stripping, Carbon
Adsorption, Chemical Treatment, Filtration, and
UV/Oxidation)
City Industries Superfund Site, FL
(Pump and Treat with Air Stripping)
King of Prussia Technical Corporation Superfund
Site,NJ
(Pump and Treat with Air Stripping, Carbon
Adsorption, and Electrochemical Treatment)
LaSalle Electrical Superfund Site, IL
(Pump and Treat with Air Stripping, Carbon
Adsorption, and Oil/Water Separation)

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Groundwater
(80 million gallons)
Groundwater
(700 million gallons)
Groundwater (151.7
million gallons)
Groundwater (151.5
million gallons)
Groundwater
(23 million gallons)

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Groundwater contaminated with a wide
variety of contaminants; relatively
expensive remediation, with high
capital costs for treatment system
The extraction system has contained
the contaminant plume; the treatment
system has consistently met discharge
requirements since system startup in
1994
The hydrogeology at this site is
relatively simple and hydraulic
conductivity relatively high
Treatment system consists of a
treatment train designed for removal of
metals and organics
System consists of collection trenches
instead of extraction wells; relatively
low groundwater flow, contaminants
include PCBs and chlorinated solvents


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Table 1. Summary of Remediation Case Studies: Groundwater Pump and Treat
                (Nonchlorinated Contaminants) (continued)
r:'SiJ'>
Mid-South Wood Products Superfiind Site, AR
(Pump and Treat with Carbon Adsorption,
Filtration, and Oil/Water Separation)
Odessa Chromium I Superfiind Site, OU 2, TX
(Pump and Treat with Chemical Treatment,
Flocculation, Multimedia Filtration,
pH Adjustment, and Precipitation)
Odessa Chromium IIS Superfiind Site, OU 2, TX
(Pump and Treat with Chemical Treatment,
Flocculation, Multimedia and Cartridge Filtration,
pH Adjustment, and Precipitation)
Pope AFB, Site FT-01.NC
(Free Product Recovery)
Pope AFB, Site SS-07, Blue Ramp Spill Site, NC
(Free Product Recovery)
Principal Contaminant**
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Groundwater (100.6
million gallons)
Groundwater
(125 million gallons)
Groundwater
(121 million gallons)
Groundwater and
Free Product
Groundwater

'/, 
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              Table 1. Summary of Remediation Case Studies: Groundwater Pump and Treat
                                 (Nonchlorinated Contaminants) (continued)
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Sylvester/Gilson Road Superfund Site, NH
(Pump and Treat with Air Stripping, Biological
Treatment, Chemical Treatment, Clarification,
Flocculation, and Mixed-media Pressure
Filtration; Cap; Soil Vapor Extraction; Vertical
Barrier Wall)
United Chrome Superfund Site, OR
(Pump and Treat with Reduction and
Precipitation)
U.S. Aviex Superfund Site, MI
(Pump and Treat with Air Stripping)
Western Processing Superfund Site, WA
(Pump and Treat with Air Stripping and Filtration;
Vertical Barrier Wall)
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A combination of technologies was
used to remediate the site; cleanup
goals were met for all contaminants
with one exception (1,1-DCA) which
was reported as below the detection
limit
Extracted groundwater was treated on-
site at the beginning of this
application; however, because
concentrations dropped over time, on-
site treatment was discontinued
Performed modeling for system
optimization (MODFLOW and
Randomwalk); contaminants included
diethyl ether and chlorinated solvents
Met goals for off-site plume within
eight years of operation; shallow well
points recently replaced with deeper
wells to provide containment
* Principal contaminants are one or more specific constituents wilhin Ihe groups shown that were identified during site investigations.

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Table 2. Remediation Case Studies: Summary of Cost Data
Site Name> State £reeb»oI0g$
Baird and McGuire Superfund Site,
MA
(Pump and Treat with Aeration, Air
Stripping, Chemical Treatment,
Clarification, and Filtration)
Bofors Nobel Superfund Site - OU 1,
M
(Pump and Treat with Air Stripping,
Carbon Adsorption, Chemical
Treatment, Filtration, and
UV/Oxidation)
City Industries Superfund Site, FL
(Pump and Treat with Air Stripping)
King of Prussia Technical
Corporation Superfund Site, NJ
(Pump and Treat with Air Stripping,
Carbon Adsorption, and
Electrochemical Treatment)
LaSalle Electrical Superfund Site, 1L
(Pump and Treat with Air Stripping,
Carbon Adsorption, and Oil/Water
Separation)
Mid-South Wood Products Superfund
Site, AR (Pump and Treat with
Carbon Adsorption, Filtration, and
Oil/Water Separation)
Odessa Chromium I Superfund Site,
OU 2, TX (Pump and Treat with
Chemical Treatment, Flocculation,
Multimedia Filtration,
pH Adjustment, and Precipitation)
Icc&HBtogy
€»st<$)«
Total:
$22,726,000
C: $14,958,000
O: $7,768,000
Total:
$13,726,000
C: $12,200,000
O: $763,000
Total: $1,674,800
C: $1,094,800
0: $580,000
Total: $2,816,000
C: $2,031,000
O: $785,000
Total: $6,138,576
C: $5,314,576
O: $824,000
Total: $1,212,600
C: $465,300
0: $747,300
Total: $2,742,000
C: $1,954,000
O: $728,000
l^aatily Treated
80 million gallons
700 million
gallons
151.7 million
gallons
151. 5 million
gallons
23 million gallons
100.6 million
gallons
125 million
gallons
Qtt8Bl%
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Table 2. Remediation Case Studies: Summary of Cost Data (continued)
'- m^m^^te&w3mfr^
Odessa Chromium IIS Superfund
Site, OU 2, TX (Pump and Treat
with Chemical Treatment,
Flocculation, Multimedia and
Cartridge Filtration, pH Adjustment,
and Precipitation)
Pope AFB, Site FT-01,NC
(Free Product Recovery)
Pope AFB, Site SS-07, Blue Ramp
Spill Site, NC
(Free Product Recovery)
Sylvester/Gilson Road Superfund
Site,NH
(Pump and Treat with Air Stripping,
Biological Treatment, Chemical
Treatment, Clarification,
Flocculation, and Mixed-media
Pressure Filtration; Cap; Soil Vapor
Extraction; Vertical Barrier Wall)
United Chrome Superfund Site, OR
(Pump and Treat with Reduction &
Precipitation)
U.S. Aviex Superfund Site, M
(Pump and Treat with Air Stripping)
f
I TD&elHLttlflgsr '
r e«$$>*
Total: $2,487,700
C: $1,927,500
O: $560,200
Total: $355,600
C: $289,000
O: $66,600
Total: $490,200
C: $394,000
0: $96,200
Total:
$27,600,000
C: $9,100,000
O: $18,500,000
Total: $4,637,160
C: $3,329,840
O: $1,307,320
Total: $1,942,000
C: $1,332,000
0: $610,000
t t ' .. ', "
OwttfttyTZtwiteti'
121 million
gallons
Not provided
Not provided
1,200 million
gallons
62 million gallons
329 million
gallons
Qttafttitydf ,
.CttlJfcJfltiBiffit
JfcemfiTOJ
131 Ibs
5,163 gals
3,516 gals
427,000 Ibs
31,459 Ibs
664 Ibs
f
Cakala&iCtostfor -
lrestiaeB0 ''
$26/1,000 gals GW
$19,000/lb of cont.
O (average): $12.90/gal
of free product
O (average): $27.36/gal
of free product
$23/1,000 gals GW
$64/lb of cont.
$75/1,000 gals GW
$140/lb of cont.
$5/1,000 gals GW
$2,925/lb of cont.
ft* - f *, '>\
Key f actors PfllemtiaayAifecittag i
f 
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                         Table 2. Remediation Case Studies: Summary of Cost Data (continued)
SiteJfsmw, State fF«ch»o!0g$
Western Processing Superfund Site,
WA
(Pump and Treat with Air Stripping,
and Filtration; Vertical Barrier Wall)
Tectoiotegy
CusH$}«
Total:
$48,730,112
C: $16,032,629
O: $32,697,483
t2raa^l=ice«*c
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Groundwater Pump and Treat (Nonchlorinated Solvents)




                   Case Studies

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This Page Intentionally Left Blank
               10

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Pump and Treat of Contaminated Groundwater at
     the Baird and McGuire Superfund Site,
           Holbrook, Massachusetts
                     11

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                   Pump and Treat of Contaminated Groundwater at
                         the Baird and McGuire Superfund Site,
                                  Holbrook, Massachusetts
Site Name:
Baird and McGuire Superfund site
Location:
Holbrook, Massachusetts
Contaminants:
Volatiles - nonhalogenated
(BTEX); semivolatiles -
nonhalogenated; polycyclic
aromatic hydrocarbons (PAHs,
acenaphthene, naphthalene, 2,4-
dimethylphenol); organic
pesticides/herbicides (dieldrin,
chlordane); heavy metals (lead);
and nonmetallic elements (arsenic)
- Maximum initial concentrations
measured at the site were VOCs
(>1,000 ug/L), SVOCs  (>10,000
ug/L); concentrations of specific
contaminants not provided
Period of Operation:
Status: Ongoing
Report covers:  4/93 - 2/97
Cleanup Type:
Full-scale cleanup (interim results)
Vendor:
Metcalf & Eddy Services
Walsh Contracting
Barletta Engineering

Treatment System Operator:
Tim Beauchemin
U.S. Army Corps of Engineers
696 Virginia Road
Concord, MA 01742-2751
(978)318-8616
State Point of Contact:
Harish Panchol
Massachusetts DEQE
(617)292-5716
Technology:
Pump and Treat
- Groundwater is extracted using 6
wells, located on site, at an average
total pumping rate of 60 gpm
- Extracted groundwater is treated
with chemical treatment (addition
of ferric chloride, lime slurry,
phosphoric and sulfuric acids, and
ammonium sulfate), clarification,
aeration, filtration, and carbon
adsorption
- Treated groundwater is reinjected
through infiltration basins
Cleanup Authority:
CERCLA Remedial
-RODDate: 9/30/86
EPA Point of Contact:
Chet Janowski, RPM
U.S. EPA Region 1
John F. Kennedy Federal Building
One Congress Street
Boston, MA 02203
(617) 573-9623
Waste Source:
Surface impoundment/lagoon,
hazardous materials storage,
discharge to septic system,
discharge to wetlands
Purpose/Significance of
Application:
Groundwater contaminated with a
wide variety of contaminants;
relatively expensive remediation,
with high capital costs for
treatment system.
Type/Quantity of Media Treated:
Groundwater
- 80 million gallons treated as of February 1997
- LNAPL observed in several monitoring wells on site
- Groundwater is found at 10-15 ft bgs
- Extraction wells are located in 3 aquifers, which are influenced by a
nearby surface water
- Hydraulic conductivity ranges from 0.5 to 45 ft/day
                                               12

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                   Pump and Treat of Contaminated Groundwater at
                         the Baird and McGuire Superfund Site,
                           Holbrook, Massachusetts (continued)
Regulatory Requirements/Cleanup Goals:
-  Cleanup goals were established to be maximum contaminant levels (MCLs) as defined by the primary
   drinking water standards and the state of Massachusetts drinking waster quality criteria.  Cleanup goals were
   established for benzene (5 ug/L), toluene (2,000 ug/L), ethylbenzene (680 ug/L), xylene (440 ug/L), 2,4-
   dimethyl phenol (2.12 ug/L), naphthalene (0.62 ug/L), acenaphthene (0.52 ug/L), dieldrin (0.000071 ug/L),
   chlordane (0.00046 ug/L), arsenic (0.05 ug/L), and lead (0.05 ug/L).
-  Additional goals were to remediate the contaminated aquifer within a reasonable time to prevent present or
   future impacts to groundwater drinking water supplies, and to protect the Cochato River from future
   contaminant migration by establishing hydraulic containment of the plume.
Results:
-  During the first two years of operation, the pump and treat system reduced average VOC and SVOC
   concentrations. From 1994 to 1995, average VOC concentrations decreased by 16% and average SVOC
   concentrations by 48%. However, contaminant concentrations in some individual wells did not decline over
   this period and concentrations have not been reduced to below treatment goals. As of December 1995,2,100
   pounds of organic contaminants have been removed from the groundwater.
-  Contaminants have been detected in down-gradient monitoring wells and plume containment has not been
   achieved. A  1995 study made recommendations for achieving plume containment.
Cost:
-  Actual costs for pump and treat were $22,726,000 ($14,958,000 in capital and $7,768,000 in O&M), which
   correspond to $284 per 1,000 gallons of groundwater extracted and $10,822 per pound of contaminant
   removed.
-  Operating costs are relatively high because of the need to analyze for a large number of contaminants and the
   need for an operator to be on-site 24 hours per day.
Description:
Baird and McGuire Inc. conducted chemical mixing operations at this site from 1912 to 1983.  Contamination of
an on-site public drinking water well was first detected in 1982 by the town of Holbrook.  Also in 1982, a citizen
complaint of an oily substance in the Conchato River, which runs along the eastern boundary of the site led to an
inspection by DEQE.  This inspection revealed that a tank farm was not lined or diked, sewage waste, process
waste, and surface water runoff were collected in an open cesspool; and a black oily substance was being
discharged to on-site wetlands. During emergency removal actions by EPA in 1983 and 1985, a plume of VOCs
and SVOCs was identified in the groundwater beneath the site. The site was added to the NPL in October 1982
and a ROD was signed in September 1986.

The groundwater extraction system consists of six wells placed in the part of the plume where the highest levels
of contamination were detected. Groundwater treatment includes equalization and removal of free floating
product, chemical treatment (with ferric chloride and lime in one stage, and phosphoric and sulfuric acids and
ammonium sulfate in a second stage), fiocculation/clarification, aeration, pressure filtration, and carbon
adsorption, prior to discharge to infiltration basins. Above-ground biological treatment (using activated sludge)
was included in the original design for this site, but was found to be not necessary, and deleted from the
treatment system.  After three years of operation, the system has not met the cleanup goals established for this
site.  In addition, the report discusses the impacts of having concurrent groundwater and soil remediation
activities at this site.
                                                13

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                                                              Baird and McGuire Superfund Site
                                    SITE INFORMATION
Identifying information
Baird and McGuire Superfund Site
Holbrook, Massachusetts

CERCL1S#: MAD001041987

ROD Date: September 30, 1986



Background fS.6.71	
Treatment Application
Type of action: Remedial

Period of operation:  1993 - Ongoing
(Data collected through February 1997)

Quantity of material treated during
application:  80 million gallons of groundwater
[9]
Historical Activity that Generated
Contamination at the Site:  Chemical mixing
and batching operations

Corresponding SIC Code: 2841 (Soap and
other detergents), 2879 (Pesticides and
agricultural products), 2491 (Wood preserving)

Waste Management Practice That
Contributed to Contamination: Surface
impoundment/lagoon, hazardous materials
storage, discharge to septic system, discharge to
wetlands

Location:  Holbrook, Massachusetts

Facility Operations:
•   Baird and McGuire Inc. (BMI) conducted
    chemical mixing operations at this site from
    1912 to 1983.

•   Contamination of an on-site public drinking
    water well was first detected in 1982 by the
    Town of Holbrook. This well had to be
    abandoned after contamination was
    detected.  In 1982, a citizen complaint of an
    oily substance in the Cochato River, which
    runs along the eastern property boundary,
    led to a DEQE inspection. This inspection
    revealed the following: the tank farm was
    not lined or diked; sewage waste, process
   waste, and surface water runoff were
   collected in an open cesspool; and a black
    oily substance was being discharged to on-
   site wetlands.
    On May 2, 1983, BMI's permit to store
    chemicals at the site was revoked by the
    Town of Holbrook. As a result, BMI was
    forced to cease operations.

    EPA-initiated two emergency removal
    actions in 1983 and 1985. During these
    emergency removals, a plume of volatile
    organic and base neutral/acid extractable
    compounds was identified in the
    groundwater beneath the site.

    BMI voluntarily implemented a series of
    remedial actions. These included: installing
    a catch basin near the tank farm; filling the
    cesspool with concrete; installing booms on
    the Cochato River; removing the wetlands
    discharge pipe; and constructing a clay dike
    around the creosote lagoon to prevent a
    release.

    The site was listed on the National Priorities
    List (NPL) in October 1982.

    An Rl was conducted in 1984 and 1985.
    Contaminants identified in the groundwater
    included PAHs, halogenated and
    nonhalogenated organics, inorganics, and
    pesticides.

    Source removal actions at the site included
    excavation and on-site incineration of
    contaminated soils. These removal actions
    took place in 1983, 1985, and 1995 through
    1997.
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                                                            Baird and McGuire Superfund Site
                              SITE'INFORMATION (CONT.)
  ai*lfnmiinri fftont1
Regulatory Context:
•  Site activities are conducted under
   provisions of the Comprehensive
   Environmental Response, Compensation,
   and Liability Act (CERCLA) of 1980, as
   amended by the Superfund Amendments
   and Reauthorization Act (SARA) of 1986
   §121, and the National Contingency Plan
   (NCR), 40 CFR 300.
•  A Record of Decision (ROD) was issued in
   September 1986.

Groundwater Remedy Selection:
The groundwater remedy initially selected for
this site consisted of extraction and treatment
through biological activated sludge. The
treatment system has been modified, and the
activated sludge tanks are currently used as air
stripping units.
Site Lead: EPA

Remedial Project Manager:
Chet Janowski*
U.S. EPA Region I
John F.  Kennedy Federal Building
One Congress Street
Boston,  Massachusetts 02203
617-573-9623
State Contact:
Harish Panchol
Massachusetts DEQE
617-292-5716

Treatment System Vendor:
Metcalf & Eddy Services
Walsh Contracting
Barletta Engineering

Treatment System Operator:
Tim Beauchemin
U.S. Army Corps of Engineers
696 Virginia Road
Concord, MA 01742-2751
(978)318-8616
 Indicates primary contact.
                                  MATRIX DESCRIPTION
    rix Identification
 Type of Matrix Processed Through the
 Treatment System: Groundwater

 Contaminant Characterization F5.6.71
 Primary Contaminant Groups: Halogenated
 and nonhalogenated volatile organic compounds
 (VOCs), semivolatile organic compounds
 (SVOCs), inorganics, and pesticides.

 •   Selected index contaminants at the BMI site
    include: arsenic, lead, BTEX, trans-1,2-
    dichloroethylene (trans-1,2-DCE), 4-methyl
    phenol, 2,4-dimethyl phenol, naphthalene, 2-
    methyl naphthalene, acenapthene,
    dibenzofuran, fluorene, phenanthrene,
    dieldrin, and chlordane. Attachment 1
    provides a complete list of contaminants
    detected at the site. Maximum
    concentrations for individual contaminants
    are not provided in available documentation.

            U.S. Environmental Protection Agency
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                                                               Baird and McGuire Superfund Site
                              MATRIX DESCRIPTION (CONT.)
 Contaminant Characterization (Cont.)
    Concentrations of contaminants at the site
    were greater than 10,000 ug/L for total
    SVOCs and greater than 1,000 ug/L for total
    VOCs.

    Figures 1 and 2 illustrate the contaminant
    contours detected in 1988 and 1995,
    respectively, for total VOCs.

    The areal extent of the initial plume was
    estimated to be more than 700,000 square
    feet and approximately 70 feet thick. Based
    on a standard porosity of 30%, the plume
    volume was estimated at 111 million gallons.
Matrix Characteristics Affecting Treatment Costs or Performance
 A light nonaqueous phase liquid (LNAPL)
 has been observed in several on-site
 monitoring wells.  The material was identified
 as an immiscible oily substance that floats
 on the water table in the 1985 Rl.
Hydrogeology [6,7]:

Four distinct hydrogeologic units have been identified beneath this site. They are:


  Unit 1A        Stratified material consisting of silty sands, sand, and silt.

  Unit 1B        Stratified material consisting of fine to medium, fine to course sand.

  Unit 2          Unstratified glacial till.

  Unit 3          Fractured bedrock.

Figure 3 shows an east-west cross-section through the site that depicts the hydrogeology of the site. The
upper stratified units (Unit 1A and 1 B) pinch out on the west side of the site.  A bowl-shaped depression is
formed by bedrock beneath the site. Shallow groundwater is found at 10 to 15 feet below ground surface.
Groundwater discharges to the Cochato River along the eastern site boundary.

The toe of the plume has migrated beyond the river. However, it reached a stagnation point in 1988.
Figure 4 shows the same east-west cross-section and depicts the vertical plume distribution as detected
in 1985. Measured flow velocities indicate that groundwater in Units 1  and 2 can move between 50 and
500 feet per year.
      EPA
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                                                    Baird and McGuire Superfund Site
                    (MATRIX DESCRIPTION (CONT.)
   Figure 1.  Total Volatile Organic Compounds, in yg/L (1988) (Best Copy Available) [8]
EPA
       U.S. Environmental Protection Agency
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                                                       Baird and McGuire Superfund Site
                        MATRIX DESCRIPTION (CONT.)
   Figure 2. Total Volatile Organic Compounds, in yg/L (1995) (Best Copy Available) [8]
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                                                                Baird and McGuire Superfund Site
                             MATRIX DESCRIPTION (CONT.)
   MO
                                    , ,,53.7)
COCHATO
 RIVER
                                                                             SEWER 915 (123.2)
                                                                             UME       BW-1S (124.4)
                                                                                             A'
                                              BH-36 (128.0)     PW-1 (122.0) 914(119.7)
                                 Figure 3. Site Hydrogeology [6]
1
                                                                                     A*
                      Figure 4.  Vertical Extent of Total VOC Plume (ug/L) [6]
                                                                U.S. Environmental Protection Agency
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                                                                	Technology Innovation Office
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                                                              Baird and McGuire Superfund Site
                             MATRIX DESCRIPTION (CONT.)
 Tables 1 and 2 include technical aquifer information and technical well data. A discussion of extraction
 wells is included in the following section.

                              Table 1. Technical Aquifer Information
Unit Name
Unit 1A
UnitIB
Unit 2
Units
Thickness
(ft)
10-20
25-50
10-20
>50
Conductivity
(ft/day)
3
45
10
0.5
Average Velocity
(ft/day)
NA
0.3 - 0.7
0.1 -1.25
0.3-3
Flow
Direction
East1
East1
East1
East1
Source: [6,7]
NA - Not characterized
1West side of Cochato River only; flow direction may vary on the east side of the Cochato River.
                          TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology

Pump and treat with air stripping and
hydroxide precipitation/ferric chloride treatment
[3].

System Description and Operation
Supplemental Treatment Technology

Filtration, carbon adsorption, sludge dewatering
[3].
Table 2. Technical Well Data
Well Name
EW-1
EW-2
EW-3
EW-4
EW-5
EW-6
Unit Name
Units 2 and 3
UniMB
UnitIB
Units 2 and 3
UnitIB
UnitIB
Depth (ft)
64
30
38
84
32
30
Note: Represents initial design conditions. Average system extraction rate is 60
the actual volume of water pumped since operations began and a 93% operation
_1.993 to December 1995.
Design Yield
(gal/day)
28,800
43,200
43,200
43,200
28,800
28,800
gpm based on
rate from April
Source: [3]

System Description [3,8,9]
•  To accommodate soil remediation activities
   scheduled for 1995, the original groundwater
   extraction system, installed between 1990
   and 1992, was constructed with temporary
   piping placed in contaminated soils.  As
   discussed earlier, contaminated soils were
   excavated and incinerated under a separate
   remedial action. The temporary piping and
   wells had to be removed when the
   excavation of contaminated soils began in
   1995. The following section describes the
   system as originally installed and operated
   through February 1997; however,
   modifications were made after soil
   remediation was complete in 1997.

   The extraction system consisted of six wells
   and associated piping. Four wells were
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                                                               Baird and ftfcGu ire Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation (Cont.)
    completed in the stratified material (Units 1A
    and 1B) and two were screened in both the
    till (Unit 2) and bedrock (Unit 3). The wells
    were placed in the part of the plume where
    the highest levels of contaminants were
    detected. The extraction system design was
    intended to restore the aquifer and contain
    the contaminant plume.

    Figure 5 shows a groundwater treatment
    plant flow diagram. An 8,000-gallon
    equalization tank is used as the first element
    of the treatment train to allow for constant
    flow rate and to remove free floating product.
    Two stages of hydroxide precipitation are
    used in the treatment system to allow for
    maximum metals removal efficiency at
    different pH levels.

    The original remedial design for the
    treatment system specified biological
    treatment of organic contaminants via an
    activated sludge process. However,
    because no biological mass existed, the
    biological treatment process did not achieve
    effluent limits. Historical analytical data
    indicate that sufficient organic removal rates
    are attained without the use of biological
    treatment [12].

    The activated sludge tanks are currently
    being used as modified air strippers.
    Following the air stripping step, rapid sand
    filtration is used to remove any suspended
    solids.  Filtration is followed by two stages of
    activated carbon adsorption as a final
    polishing step.

    Effluent from the treatment system is re-
    injected into the aquifer through four gravel
    bed infiltration basins located upgradient of
    the plume.

    Off-gas generated from each of the unit
    operations is collected and vented to an on-
    site fume incinerator (separate from the soil
    incinerator), which destroys organics by
    thermal oxidation at a temperature of
    1,800°F.  The fume incinerator is soon to be
    replaced by vapor phase carbon.

    Solid waste including precipitate and
    activated carbon from the treatment system
    is disposed of off site.
•   A total of 49 monitoring wells were installed
    in units 1B, 2, and 3 to evaluate contaminant
    concentration levels from 1993 to 1995.
    During soil excavation activities from 1995 to
    1997, nearly half of the monitoring wells
    were damaged and not usable. The
    monitoring wells were replaced in 1997.

System Operation [8,9,10]
•   From April 1993 to June 1995, the extraction
    system was operated using all six wells.
    After soil excavation began in June 1995,
    only one well, on average, was operating.
    Extraction wells were taken off line to allow
    for excavation activities, and because of
    poor well yield. There was no change to the
    treatment system until early 1997 when
    several upgrades were completed.  Since
    startup, the treatment system has operated
    at an average extraction rate of 60 gpm, and
    has been unable to operate at its design rate
    of 150 to 200 gpm because of several
    problems, including undersized pumps and
    sludge thickener loading rates. Pumps were
    replaced and a larger sludge thickener
    installed in early 1997.  These changes have
    enabled the treatment system to operate at
    its design rate since then.

•   According to site engineers, at the time
    excavation and incineration activities began,
    the groundwater extraction system had not
    provided the required extraction rate to
    achieve hydraulic containment of the plume.
    In 1995, new well locations and screen
    intervals were chosen to increase the
    extraction rate. Other activities that were
    planned included replacing three of the
    extraction wells, installing two additional
    extraction wells, and  retrofitting two existing
    extraction wells with collection equipment to
    enhance LNAPL removal.  A groundwater
    model was used to optimize the extraction
    system. Extraction system upgrades should
    be completed in late 1997 when the P&T
    system is scheduled to resume full-scale
    operation.
      EPA
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                                                    Baird and McGuire Superfund Site
               TREATMENT SYSTEM DESCRIPTION (CONT.)

                   5. Groundwater Treatment Plant Flow Diagram [12]
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                                                              Baird and McGuire Superfund Site
                     TREATMENT SYSTEM (DESCRIPTION (CONT.)
Svstem Description and Operation (Cont.)
    Quantity of groundwater pumped from
    aquifer in gallons:
             Total Volume
    Year    Pumped (gallons)      Unit Name
    1993        18 million           1B,2,3

    1994        34 million           1B,2,3

    1995        28 million           18,2,3

    As of February 1997, the treatment system
    has been 93% operational. Down time has
    been primarily due to problems with
    computer control instrumentation and lime
    buildup in feed lines.

    Excavation and on-site incineration of soils
    took place from 1995 to 1997. Wastewater
    from dewatering and incineration blowdown
    operations was pumped to the groundwater
    treatment system during this time. Since
    January 1996, the majority of flow to the
    treatment system has come from these
    operations.

    The wastewater generated from soil
    dewatering and incineration activities was
    estimated to be 100 gpm. The treatment
    system was required  by contract to handle
    this additional wastewater flow and would
    reduce the volume of groundwater being
    sent from extraction wells if needed.
    However, this was not required because the
    groundwater extraction  rate was
    approximately 50 gpm at that time.
Once excavation and incineration activities
began, piping and extraction wells were
removed and replaced as contaminated soils
were excavated and clean fill was replaced.
During this time, the average extraction rate
was approximately 25 gpm.

The carbon units have been changed out
approximately every two months or every
eight million gallons treated. Approximately
115,000 pounds of spent carbon were
regenerated or disposed of from 1993 until
1997.

During soils excavation activities, the
excavating contractor accidentally damaged
or destroyed over 25 of the 49 monitoring
wells. As a result, the site engineer has not
been able to adequately monitor the
contaminant plume  during soil remediation
activities. The excavation contractor will
replace the damaged wells after soil
remediation activities are complete.

The long-term groundwater monitoring
procedure approved by EPA stated that 20
perimeter wells would be monitored on a
quarterly basis.  After two consecutive
sampling events from a well where no
contaminants are detected, a different well
nearer to the source area is chosen for the
next sampling event.
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                                                            Baird and McGuire Superfund Site
                     TREATMENT SYSTEM DESCRIPTION (CONT.)
 Operating Parameters Affecting Treatment Cost or Performance
 Table 3 shows operating parameters affecting cost or performance for this technology.

                               Table 3: Performance Parameters
Parameter
Average Extraction Rate
Performance Standard (effluent)
and
Remedial Goal (aquifer)
(ug/L)







Rvalue ' *-
60gpm
Arsenic
Lead
Benzene
Toluene
Ethylbenzene
Xylene
2,4-dimethyl phenol
Naphthalene
Acenapthene
Dieldrin
Chlordane
0.05 pg/L
0.05 ug/L
5 pg/L
2,000 ug/L
680 pg/L
440 ug/L
2.12 ug/L
0.62 pg/L
0.52 ug/L
0.000071 pg/L
0.00046 U9/L
         Source: [5]
Timeline
Table 4 presents a timeline for this remedial project.
                                  Table 4: Project Timeline
Start Date
9/86
5/87
9/87
5/90
1/93
6/95
2/97
8/97
End Data
—
—
6/89
1/93
—
5/97
—
—
' • - Activity *' ""--'-."' "' ' ;- ' N<
Date of ROD for this OU
Remedial design accepted
Design document prepared by Metcalf & Eddy
Construction of the groundwater treatment system
Groundwater treatment plant begins operations and compliance monitoring
begins
Incineration activities performed
Groundwater treatment plant modified to increase capacity to 200 gpm
Anticipated date for restart of P&T full-scale operation


Source: [3, 8, 9,10]
                        TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards
Cleanup goals were established during the
design phase to be maximum contaminant levels
(MCL), as defined by the Primary Drinking Water
Standards and the State of Massachusetts
Drinking Water Quality Criteria. Specific criteria
are included in Table 3.  These goals must be
met in all monitoring wells located on site [5].
Additional Information on Goals

In the cases where no MCL is available, the
applicable regulation is EPA Ambient Water
Quality Criteria for Freshwater Aquatic
Organisms and Criteria for Human Consumption.
Of the pollutants listed in Table 3, only arsenic,
lead, and BTEX compounds have MCLs
established [5].
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                                                             Baird and McGuire Superfund Site
                    TREATMENT [SYSTEM PERFORMANCE (CONT.)
Treatment Performance Goals [3.51
•   To remediate the contaminated aquifer
    within a reasonable time to prevent present
    or future impacts to groundwater drinking
    water supplies.

Performance Data Assessment [8.9.10.11.121
To protect the Cochato River from future
contaminant migration by establishing
hydraulic containment to capture the
contaminant plume.
For the purposes of this report, total
contaminants refers to the broad classes of VOC
and SVOC compounds detected at this site.

•   During the first three years of operation, the
    P&T system reduced average VOC and
    SVOC concentration levels.  The maximum
    concentration of contaminants detected in
    individual wells after three years of system
    operation were total SVOCs (7,967 ug/L)
    and total VOCs (11,870 ug/L).

    Figure 6 illustrates changes in average
    contaminant concentrations in the
    groundwater from 1994 to 1995.  The data in
    Figure 6 show an overall decline of 16%
    (VOC) and 48% (SVOC) in average
    groundwater concentration from 1994
    through 1995.  However, contaminant
    concentrations in some individual wells did
    not decline over this period, and contaminant
    concentrations have not been reduced to
    below treatment goals.

•   Contaminants have been detected in
    downgradient monitoring wells as noted in
    the 1995 Annual  Report. On the basis of
    this information, plume containment has not
    been achieved. A 1995 groundwater study
    made recommendations for achieving plume
    containment.

•   Groundwater models run by site engineers
    estimated that an extraction rate of
    approximately 150 gpm is  required for plume
    containment.  However, the treatment plant
    was not able to operate at its design rate of
    150 to 200 gpm due to undersized pumps
    and sludge thickener.
The extraction network also could not
achieve the design extraction rate of 150
gpm due to well placement, clogging
problems, and the shut-down of wells for soil
remediation.

As shown in Figure 7, the P&T system
removed approximately 2,100 pounds of
organic contaminant mass from the
groundwater as of December 1995. Mass
removed from metals precipitation units was
not estimated for this report.

Figure 7 presents the mass removal of
contaminants through the treatment system
from June 1994 to December 1995. A total
of 80 million gallons of groundwater have
been treated.  The daily average treatment
rate was 60 gpm as determined by the on-
site contractor.

The contaminant removal rate has fluctuated
over the 1994-1995 operating period. The
data presented in Figure 7 show a reduction
in mass flux rate from 1994 to 1995. This
decrease is due primarily to a decrease in
flow rate to the treatment system. Available
data indicate that influent concentrations
have remained relatively constant.

Several modifications are planned for
groundwater remediation after the soils
remediation activities are complete.
Implementation of these modifications has
reportedly begun. The  first new extraction
well is scheduled to be  on-line by April 1998.
An additional extraction well plus two LNAPL
extraction wells are scheduled for later this
year.
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                                                          Baird and McGuire Superfund Site
                 TREATMENT SYSTEM PERFORMANCE (CONT.)
I
!§
o>
u
6
U
1,000

 900

 800

 700

 600

 500

 400
     300
    200
     100
      0
      Apr-94
                                •c 11
                                                                     -«•,  -   -*-
                     Jul-94
Oct-94
     Jan-95
             Apr-95
                                 . Total VOC
                                             . Total SVOC
                Figure 6.  Average Contaminant Concentrations (1994-1995)
                                                                                 2,500
   Jun-94      Sep-94      Dec-94
                                Mar-95
   Jun-95
Sep-95
Dec-95
                                  . Mass Rux
                                                 . Mass Removed
           Figure 7. Mass Flux Rate and Cumulative Contaminant Removal (1994-1996)
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                                                            Baird and McGuire Superfund Site
                   TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Completeness
   Performance sampling for the treatment
   system is completed on a weekly basis.
   Influent concentration, effluent
   concentration, flow, chemical usage, and
   sludge production data are available in
   monthly reports.

   Monthly reports for 1994 and 1995 were
   used for mass flux analyses performed in
   this report.  No data were available for
   performance evaluation from April 1993 to
   June 1994.
Contaminant mass removal was determined
using analytical results from weekly influent
and effluent sampling, along with average
flow rate data. One weekly event per month
was used for this calculation.

Concentration data for the six extraction
wells are available for April 1994, October
1994, March 1995 and April 1995 sampling
rounds only. These data were used to
compute the average groundwater
concentration presented in Figure 6. A
geometric mean was  used to estimate
average groundwater concentrations and
provide a trend for the entire plume.
Performance Data Quality
The QA/QC program used throughout the remedial action met the EPA and the State of Massachusetts
requirements. All monitoring was performed using EPA-approved methods, and the vendor did not note
any exceptions to the QA/QC protocols.
Procurement Process
                              TREATMENT SYSTEM COST
The U.S. EPA is the lead agency for this site. The U.S. Army Corps of Engineers (USAGE), N.E. Division,
has been contracted to provide operations and maintenance of this site for the first ten years of operation.
The New England Division of the USAGE is managing all on-site activities. Metcalf & Eddy Services was
awarded the contract for treatment system design and subsequently subcontracted Barletta Engineering
to construct the treatment system. Metcalf & Eddy Services has been contracted to provide operation and
maintenance services for the groundwater treatment system.

Cost Analysis

•  All costs for remedial activities at this site were shared by the U.S. EPA and Massachusetts DEQE.
   The costs presented are for the groundwater pump and treat system only. No costs for the soil
   excavation and incineration, performed under a separate remedial action, are included.
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                                                               Baird and McGuire Superfund Site
                          TREATMENT SYSTEM COST (CONT.)
Capital Costs F4,91
 Remedial Construction
 Administrative, Mobilization,         $3,490,595
 and Demobilization
 Monitoring Wells and Sampling         $230,222

 Site Work                          $159,016
 Ground Water Extraction/             $633,884
 Infiltration
 Treatment System                 $9,274,652
 Corps Management Costs           $1,169,292
     Total Remedial              $14,957,661
     Construction
Operating Costs T4.91
 Operation and Maintenance         $4,902,878

 Chemicals                          $61,016

 Metal Sludge Disposal               $568,670

 Biological Sludge Disposal             $30,259

 Carbon Regeneration/Purchase       $175,044

 Utilities                           $685,351

 Laboratory Supplies                 $772,211

 Site Security                       $408,159

 Lab Services                      $140,076

 Equipment for collection and            $25,110
 storage of LNAPL

 Total Cumulative Operating        $7,768,780
 Expenses from April 1993 to
 February 1997


Other Costs T4.91	
                                                    Remedial Design
                                                    Remedial Design
                                                    State Oversight
                                 $3,364,222

                                   $39,911
Cost Data Quality
Actual capital and operations and maintenance cost data are available from the Army Corps of Engineers
contact for this site.
                       OBSERVATIONS AND LESSONS LEARNED
    Total cost for the P&T system at the BMI site
    was approximately $22,726,000
    ($14,958,000 in capital costs and
    $7,768,000 in cumulative operation and
    maintenance costs).  The unit costs for this
    clean-up are calculated to be $284 per 1,000
    gallons of groundwater treated, and $10,822
    per pound of organic contaminant removed.

    According to the site contact, substantial
    time and money were spent during the first
    year of operation in an attempt to acclimate
    biological organisms to the wastewater
    stream [4].
      EPA
    Operating costs are high due to high
    analytical costs for the large number of
    contaminants and the cost for an operator to
    be on-site 24 hrs per day.

    The management plan to have concurrent
    groundwater and soil remediation activities
    resulted in high construction costs and
    logistics problems. A temporary
    groundwater extraction system was installed
    and then removed two years later when soil
    excavation began.  In addition, monitoring
    wells installed across the site made it difficult
    to operate heavy machinery without

            U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
            	Technology Innovation Office
                                              28
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                                                          Barn/ and McGuire Superfund Site
              OBSERVATIONS AND LES$ONS LEARNED (CONT.)
damaging well heads. Ultimately, over 25
monitoring wells were accidentally damaged
or destroyed during the soil excavation
activities. Replacement costs for these wells
will be paid by the excavation contractor.

In early 1997, plant upgrades such as pump
replacement and sludge thickener unit
replacement were required to achieve
design capacity of 200 gpm.  Upgrades were
completed at a cost of $100,000 which is
included in the $14.9 million [9].

The treatment system performance data
indicate that over 2,100 pounds of organic
contaminants were removed from the
groundwater as of December 1995. The
P&T system has not met the cleanup goals,
and maximum VOC and SVOC
concentrations in extraction wells remain in
excess of 11,000 and 7,000 ug/L,
respectively.

LNAPL material has been observed in two
on-site wells, indicating the presence of a
subsurface source of pollutants.
Fluctuations in  contaminant concentration
levels were noted within several wells placed
near the center of the plume. These
fluctuations are also indicative of possible
subsurface source zones contributing to the
dissolved groundwater plume.
During excavation and incineration activities,
extraction wells and associated piping were
replaced. These activities disrupted the
groundwater extraction program and may
have resulted in further off-site plume
migration.  Plume migration cannot be
assessed at this time because of the
interruption of the groundwater monitoring
program.

From 1993 to 1996, the overall extraction
rate was 60 gpm, which is less than the
design extraction rate of 150 to 200 gpm.
Modifications to the extraction system will be
made in 1997.  According to the site
engineer, the modifications will include
repairing three wells and adding two new
wells. The 1995 annual groundwater study
and a calibrated groundwater  model of the
site were used to locate the two additional
wells. Several wells will also be equipped to
remove  LNAPL material [9].

The 1995 annual groundwater study
included an optimization section which, with
the aid of the groundwater model, made
recommendations for enhancing the P&T
system performance.  Most
recommendations were targeted at
improving  plume containment and increasing
mass flux to the treatment system.
   EPA
         U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
                Technology Innovation Office
                                          29
                                                                         TIO3.WP6\0116-03.stf

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                                                             Baird and McGuire Superfund Site
1.  Final Work Plan Focused Feasibility Study.
    Ebasco Services, February 1988.

2.  Water Supply Feasibility Study. Ebasco
    Services, May 1990.

3.  Remedial Action Report. Baird and McGuire
    Superfund Site, Holbrook, MA, Operable
    Unit#1, Groundwater Treatment Facility,
    March 1993.

4.  Correspondence with Mr. Chet Janowski,
    Remedial Project Manager, U.S. EPA
    Region I, April 10,1997.

5.  Superfund Record of Decision. U.S. EPA,
    September 1986.

6.  Remedial Investigation Report. Baird &
    McGuire Site, Holbrook, MA. GHR
    Engineering Associates, Inc., May 1985.

Analysis Preparation	
                                      REFERENCES
7.  Remedial Investigation Addendum Report.
    Baird & McGuire Site, Holbrook, MA. GHR
    Engineering Associates, Inc., June 1986.

8.  Evaluation of Extraction System
    Performance at the Baird & McGuire
    Superfund Site. Metcalf & Eddy Services,
    July 1995.

9.  Correspondence with Mr. Chris Zevitas, Site
    Engineer, U.S. Army Corps of Engineering
    (USAGE), April 14, 1997.

10.  Monthly Process Summaries, 1994-1996,
    USAGE.

11.  Dense Nonaqueous Phase Liquids. Huling,
    S.G., and J.W. Weaver, U.S. EPA, March
    1991.

12.  Monthly Process Summary, February 1997.
This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
Emergency Response, Technology Innovation Office. Assistance was provided by Eastern Research
Group, Inc. and Tetra Tech EM Inc. under EPA Contract No. 68-W4-0004.
     EPA
           U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
   	Technology Innovation Office
                                            30
                                                                           TIO3.WP6\0116-03.stf

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                                                    Baird and McGuire Superfund Site
                             ATTACHMENT A
                     Detected Compounds Listed in the ROD
1 , 1 -Dichloroethy lene
1,2-Dichloroethane
Aldrin
Arsenic
Benzene
Benzidine
Benzo(a)pyrene
Beryllium
BHC-Alpha
BHC-Beta
BHC-Delta (Tech)
BHC-Gamma
Cadmium
Chlordane
Chloroform
Dieldrin
Heptachlor
Heptachlor Epoxide
Nickel
Tetrachloroethylene
Trichloroethylene
Vinyl Chloride
1 ,2-frans-dichloroethylene
1 ,3-frans-dichloropropylene
2-Butanone
Parius
Ethylbenzene
Fluoranthene
Lead
Silver
Toluene
Xylenes (TOT)
Zinc
Dibenzofuran
Total Other PAHs:
2-Methylnaphthalene
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Chrysene
Dibenzo(a,h)anthracene
Fluorene
ldeno(1 ,2,3-CD)pyrene
Naphthalene
Phenanthrene
Pyrene
 "Individual pollutant levels were not provided.
EPA
       U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
              Technology Innovation Office
                                      31
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              32

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UV Oxidation at the Bofors Nobel Superfund Site
            Muskegon, Michigan
                      33

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                     UV Oxidation at the Bofors Nobel Superfund Site
                                       Muskegon, Michigan
  Site Name:
  Bofors Nobel Superfund Site •
  Operable Unit 1	
 Location:
 Muskegon, Michigan
 Cleanup Type:
 Groundwater Remediation
 Project Management:
 U.S. Army Corps of Engineers
 Carl Plate
 Grand Haven Area Office
 P.O. Box 629
 Grand Haven, Michigan 49417
 (616)842-5510
 SIC Code:
 2869 (Industrial Organic
 Chemicals)
 Contaminants:
 VOCs and SVOCs
 • Benzene, Benzidine, 2-Chloroaniline,
  1,2-Dichloroethene, Trichloroethene,
  3,3-Dichlorobenzidine, Aniline, Vinyl
  Chloride
 • Selected Maximum concentrations in
  ug/kg - Benzene (60,000),
  2-Chloroaniline (63,000), Aniline
  (10,000), 3,3-Dichlorobenzidine
  (2,600)
Period of Operation:
• Full-Scale Treatment System
  Operation since September 1994.
• Treatment Currently ongoing and
  expected to last 50+ years.
Cleanup Authority:
CERCLA and State
ROD date
- September 17, 1990
 Technology:
 Groundwater Extraction and On-Site
 treatment by UV Oxidation
 • Groundwater is extracted from 13
   wells at the site.
 • Total flow rate from the network of
   wells ranges from 390 to 500 gpm.
 • Extracted water was initially sent
   through a chemical precipitation
   step. This step has since been
   removed from the system.
 • Treatment steps include: dual-media
   filtration, UV Oxidation, GAC
   treatment (polishing), pH
   adjustment, stripping for ammonia
  removal and neutralization.
 • Treated water is discharged to an-
  onsite surface water body (Big
  Black Creek)
 Vendor:
 Kevin Dulle
 Sverdrup Environmental
 400 South 4* Street
 St. Louis, Missouri 63102
 (314)436-7600
Type/Quantity of Media Treated:
Groundwater
  700 million gallons extracted since
  1994.
  7,500 pounds of organic contaminants
  removed from extracted groundwater
Waste Sources:
Disposal of process wastes in
10 unlined impoundments at the site
Regulatory Requirements/Cleanup Goals:
The following list contains current discharge limits for selected
contaminants. All limits have been established by MDEQ and are maximum
allowable concentrations, based on weekly effluent sampling.

Purgeable Halocarbons - 5 ug/L (each)
Purgeable Aromatics - 5 ug/L  (each)
Aniline - 5 ug/L
2-Chloroaniline - 10 ug/L
Purpose/Significance of Application:
The extraction and treatment system has successfully contained migration of
contaminants from the site and consistently met discharge requirements
since system startup in 1994.
                                     Regulatory Points of Contact:
                                     John Fagiolo
                                     USEPA Region V
                                     77 West Jackson Blvd
                                     Mail Code: SR6J
                                     Chicago, Illinois 60604
                                     312)886-0800

                                     Dennis Eagle
                                     MDEQ-ERD
                                     Knapps Centre
                                     '.O. Box 30426
                                     ^ansing, Michigan 48909
                                     517)373-8195
                                                 34

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                   UV Oxidation at the Bofors Nobel Superfund Site
                              Muskegon, Michigan (continued)
Results:
• The extraction and treatment system is containing
  the ground-water contamination plume at the site.
  Contaminant concentrations in the treatment
  system effluent have been consistently below
  surface water discharge limitations for the site.
Costs:
The total capital cost for construction of the treatment system
was $12,200,000. Yearly O&M costs average $763,000. Over
three years, the capital plus O&M costs translate to $19.61 per
1,000 gallons of groundwater treated, or $1,830 per pound of
organic contaminants removed. Yearly O&M costs translate
to $3.27 per 1000 gallons of groundwater treated, or $305 per
pound of organic contaminants removed.	•
Description:
For approximately 20 years, chemical process waste liquids and sludge were routinely disposed in 10 unlined surface
impoundments at the site. In addition, impoundment berms occasionally failed, releasing sludge into nearby surface
water bodies. In 1978, thirteen extraction wells were installed at the site to collect contaminated groundwater down
gradient of the impoundments. Collected water was treated in an existing system located at a nearby facility, and was
subsequently sent the local POTW for additional treatment. A Record of Decision (ROD) was signed in September
1990, specifying construction of a new on-site treatment system with UV oxidation as the primary treatment
technology.

Under direction of the USAGE, treatability testing and treatment system design were performed in 1991 and 1992. In
1992 a contract was awarded for construction of the treatment system. In September 1994, construction of the system
was completed and full-scale treatment was begun. The treatment system originally consisted of: metals precipitation
pretreatment, dual media filtration, UV oxidation treatment for removal of organics, GAC treatment (polishing), pH
adjustment,  stripping to remove ammonia and neutralization. After one year of operation, the metals precipitation step
was determined to be unnecessary, and was removed from the treatment train. Treated water is discharged to an on-
site surface water body (Big Black Creek).

The treatment system is currently in operation and is successfully containing groundwater contamination at the site. It
is estimated that significant reductions in groundwater contaminant concentrations will not be realized until the
sources of contamination (impoundment soils and sludge) are removed or isolated.
                                                    35

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                                                                , Bofors Nobel Superfund Site
                                     SITE INFORMATION
 IDENTIFYING INFORMATION
 Site Name:
 Location:
 Operable Unit:
 CERCLIS #:
 ROD Date:
 Technology:
 Type of Action:
Bofors Nobel Superfund Site
Muskegon, Michigan
OU1
MID006030373
September 17, 1990
Ultraviolet (UV) Oxidation
Groundwater Remediation
 Figure 1 shows the location of the Bofors Nobel Superfund Site in Michigan.

 TECHNOLOGY APPLICATION

 Period of Operation:

 September 1994 - Ongoing

 Quantity of Material Treated During Application (to date):

 Approximately 700 million gallons of contaminated groundwater has been extracted and treated at the site
 Approximately 7,500 pounds of  organic compounds have been removed from the groundwater These
 quantities are cumulative through October 1997.

 This application is  part of an ongoing  project  to contain  contaminated  groundwater at  the facility
 Groundwater extraction and treatment has been  performed at the site since 1978  The ultraviolet (UV)
 oxidation treatment application has been in operation since 1994. Additional contamination in site surface
water, soil, and sediment is being addressed under a later phase of this Operable Unit (OU) and is not a
direct part of this application.
Site Background:

       The Bofors Nobel Superfund Site is located on 85 acres in a chemical manufacturing area six miles
       east of Muskegon, Michigan in Egelston Township. The site includes an operating specialty chemical
       manufacturing plant that is currently owned by Lomac, Incorporated. The Muskegon, Michigan area
       is home to a number of superfund sites as a result of past chemical manufacturing production The
       geological conditions at the Bofors Nobel site include a sandy soil horizon which allowed for the rapid
       infiltration of contaminated liquids generated by chemical wastes which were regularly discharged to
       ten separate, unlined surface impoundments at the site.
              Prepared by:	
              U.S. Army Corps of Engineer;
                                                                     Final
              Hazardous, Toxic, Radioactive Waste
              Center of Expertise
                                                                              Octobers, 1998
                                             36

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                                                       , Bofors Nobel Superfund Site
BOFORS 1.DWG DC-RTG 5/8/98
             Bofors
           Nobel  Site
  NOTE: NOT DRAWN TO SCALE
     Figure 1. Site Location Map, Bofors Nobel Superfund Site, Muskegon, Michigan
         Prepared by;
         U.S. Army Corps of Engineers
         Hazardous, Toxic, Radioactive Waste
         Center of Expertise
	Final
 Octobers, 1998
                                        37

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1                                                                  Bofors Nobel Superfund Site

 •      Prior to 1970, the facility produced chemicals such as 3,3-dichlorobenzidine (DCB), benzidine, and
        azobenzene for use in alcohol based detergents and as die intermediates. Raw materials used in the
        production of detergents included fatty alcohol, fatty ether alcohol, sulfur dioxide, aqueous ammonia
        and caustic. In the production of dye intermediates, raw materials utilized included muriatic acid,
        suifuric acid, nitrobenzene, methanol, benzene, caustic, sodium chloride and zinc.

 •      Lakeway produced a lauryl alcohol base detergent, dye intermediates, pesticides,  and  herbicides
        during the 1970s.

 •      In September 1977, Lakeway Chemicals merged with  Bofors Industries, Incorporated to become
        Bofors  Lakeway, Incorporated. On December 31, 1981, Bofors  Lakeway, Inc. merged with Nobel
        Industries of Sweden  and the company name was changed to  Bofors  Nobel, Incorporated.  In
        December 1985, the corporation filed for bankruptcy, claiming that the company had expended in
        excess of $60 million dollars for environmental cleanup.

•      The Bofors Nobel, Inc. assets were sold to Lomac, Inc. in March of 1987. As a part of the sales
        agreement, an "Agreement and Covenant Not to Sue" was entered  into between the  State and
        Lomac  for  site contamination caused  by previous facility operators.  These agreements  and
        covenants allowed Lomac to operate the facility independently of site remediation activities.

•      In March 1989, the Bofors Nobel site was placed on the National Priorities List (NPL).

Figure 2 shows  the layout of the Bofors Nobel facility.

SIC Code: 2869 (Industrial Organic Chemicals)

Waste Management Practices that Contributed to Contamination:

For approximately 20 years, chemical process waste liquids and sludge were  routinely disposed in ten
unlined surface impoundments at the  site. In addition,  lagoon berms occasionally failed,  releasing
impoundment sludge into nearby surface water bodies.

Site Operation  History:

•       Lakeway Chemicals, Incorporated began producing industrial chemicals at the site in 1960. During
        the late 1960s and 1970s, process wastes were discharged through open trenches to ten  unlined
        Surface Impoundments located south of the plant area.

•       During the 1970s, berm failures at the impoundments resulted in the discharge of sludge directly into
        Big Black Creek.

•       Use of the surface impoundments for waste disposal was discontinued  in 1976 when the facility
        began discharging its liquid wastes to the Muskegon County Wastewater Treatment System. At that
        time, the Michigan Department of Environmental Quality (MDEQ) requested that Lakeway perform
        hydrogeologic tests at the site to define aquifer characteristics and define extraction well placement
        to prevent migration of site contamination.
              Prepared by:	
              U.S. Army Corps of Engineers
              Hazardous, Toxic, Radioactive Waste
         Final
Octobers, 1998
              Center of Expertise
                                              38

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                                               , Bofors Nobel Superfund Site
                                BOFORS NOBEL
                                SITE BOUNDARY
                         BIG BLACK CREEK
           Figure 2. Layout of the Bofors Nobel Facility
Prepared by:
U.S. Army Corps of Engineers
Hazardous, Toxic, Radioactive Waste
Center of Expertise
                               39
                                                                        Final
Octobers, 1998

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                                                                , Bofors Nobel Superfund Site
        Groundwater extraction wells were installed along the southern boundary of the site and began
        operating in 1978.
 SITE LOGISTICS/CONTACTS

 Carl Plate
 USAGE, Grand Haven Area Office
 P.O. Box 629
 Grand Haven, Michigan 49417
 (616) 842-5510
Ted Streckfuss
CENWO-ED-D
USAGE, Omaha District
215 North 17th Street
Omaha, Nebraska 68102
(402) 221-3826

Dennis Eagle
MDEQ-ERD
Knapps Centre
P.O. Box 30426
Lansing, Michigan 48909-7926
(517)373-8195
 John Fagiolo
 USEPA, Region V
 77 West Jackson Boulevard
 Mail Code: SR6J
 Chicago, Illinois 60604
 (312) 886-0800

 Kevin Dulle
 Sverdrup Environmental
 400 South 4th Street
 St. Louis, Missouri 63102
 (314) 436-7600

 Site Investigations

 •       The site has been divided by the EPA into two operable units, OU 1 and OU 2. OU  1 consists of
        addressing soil and groundwater contamination in the lagoons area. OU 2 consists of addressing soil
        and groundwater contamination in the northern portion of the facility (The Lomac plant area).

 •       OU 1  has been subdivided into two phases. The first phase, termed the Groundwater Operable Unit
        (GOU), included  installation of  the Groundwater Treatment Plant (GWTP). The second  phase,
        termed the Lagoon Operable Unit (LOU), will include remediation or containment of contaminated
        soil in the lagoons area of the facility. This report refers only to the first phase of OU 1 (The GOU).

 •       Because of the nature and extent of the contamination on the  Bofors Nobel site,  the State of
        Michigan contacted the U.S. EPA to evaluate the site for placement on the National Priorities  List
        (NPL), pursuant to  the Comprehensive Environmental Response, Compensation and Liability  Act
        (CERCLA) as amended by the Superfund Amendments and Reauthon'zation Act (SARA).

 •      The EPA conducted a site evaluation, and nominated the Bofors Nobel site to the NPL in July 1988,
       with listing occurring in March 1989. A Remedial Investigation/Feasibility Study (RI/FS) was initiated
        in August 1987 and was completed in June 1990.

•      A Record of Decision (ROD) for the Bofors Nobel site was signed on September 17,1990. The ROD
       addressed remediation of the sludge lagoons as well as restoration of the groundwater aquifer.

•      Supplemental groundwater monitoring was performed by the USAGE during the design of the GWTP
       and for design of an on-site landfill remedy. This monitoring was performed from March 1991 to June
       1994.
              Prepared by:	
              U.S. Army Corps of Engineers
              Hazardous, Toxic, Radioactive Waste
              Center of Expertise
                                        Final
                               Octobers, 1998
                                             40

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                                                                , Bofors Nobel Superfund Site
                       MATRIX AKip CONTAMINANT DESCRIPTION
MATRIX IDENTIFICATION

Groundwater (ex situ)

SITE GEOLOGY/STRATIGRAPHY

The regional geology of the Bofors site can be characterized as surficial Pleistocene sediments of varying
compositions above Paleozoic sedimentary bedrock occurring on the margin of the Michigan Basin. These
two different depositional age sediments rest on a Pre-cambrian basement complex.

The surficial geology is comprised of material deposited by the Wisconsin advance during the glacial
periods of the Pleistocene Epoch. As the Wisconsinan glacier began to recede across Michigan, it re-
established a lobate character subdividing into the Michigan, Saginaw, and Lake Erie lobes. During this
general retreat, end moraines developed parallel to the margins of the several lobes with some local
development of interlobate moraine. The development of these  moranic systems impounded meltwater
behind them and initiated the first stages of the Great Lakes. Continued retreat and advances of the
glacial ice created additional moranic systems and lacustrine and outwash plains. The final retreat of
glacial ice left Michigan with a complex landscape generally less than 20,000 years old, developed on drift
deposits. The landscape is composed of low-relief features such as outwash, till, and lacustrine plains and
greater relief features including moraines, drumlins, kame, kettles,  eskers, wave-cut cliffs, and dunes.

Surficial  geology near the  Bofors site can be  characterized as  Pleistocene glacio-lacustrine  sands,
outwash sediments, and tills overlying the lower Mississippian Marshal Sandstone and Coldwater Shale
Formations. These latter two formations are part of the geologic structure known as the Michigan Basin.
Surficial geology consists of alluvium comprised of laminated sand and silt with peaty and fibrous material
associated with Big Black Creek, and three glacially derived zones described below:

The uppermost zone is a predominately fine to medium grained sand with generally less than five percent
fines  passing the No. 200 sieve.  Occasional coarser-textured beds with  higher percentage of fines do
occur, but these beds are sporadic. Low percent of fines, good sorting, uniform texture, and consistency of
occurrence characterize this zone.

The next lower sequence consists of sand deposits that are variable in texture,  generally greater than five
percent fines, with some units containing more than 30 percent, commonly interbedded with units of silty
clay.  Occasional  sand beds of the uppermost zone-type occur within this zone. However, these  are
generally thin  and sporadic. General variability and lack of uniformity characterize this sequence, with
represents a highly complex pattern of sedimentation.

The basal zone of the glacial stratigraphic section is a  silty clay commonly containing 60  percent or
greater fines. In addition, there are local minor beds of silt and sand with gravel. This zone appears to be
related to deposits  of the Morainal uplands because the total thickness of the two upper zones thins
adjacent to the Morainal areas, and the basal unit is encountered at progressively  higher levels.

Paleozoic rocks make up the majority of the structure known as the Michigan  Basin.  These sedimentary
formations are bowl-shaped and tend to thin towards the basin's margins. Muskegon County is located on
the margin  of the  Michigan  Basin. The upper Paleozoic rocks in this  region are the Osagean and
Kinderhookian Series of the lower Mississippian age, consisting of sandstones and  shales. Below the
               Prepared by:
               U.S. Army Corps of Engineers
               Hazardous, Toxic, Radioactive Waste
               Center of Expertise
	Final
 Octobers, 1998
                                               41

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                                                                             , Bofors Nobel Superfund Site
             Osagean  and Kinderhookian Series are Paleozoic age sedimentary rocks comprised  in  general of
             mudrocks, sandstones, carbonates, and evaporates. The bedrock topography along the western margin of
             the Southern Peninsula of Michigan near Muskegon County increases gradually in elevation from the Lake
             Michigan shoreline.

             The stratigraphic column beneath the Bofors site, beginning with the youngest formation, includes:

             a)      Recent sediments of alluvium and swamp deposits associated with Big Black Creek.
             b)      Quaternary lacustrine sand formation consisting of three subunits;  the upper, middle and lower
                     units.
             c)      Quaternary glacial till formation.
             d)      Mississippian Marshall sandstone formation.

             The topography at the Bofors Nobel Superfund site slopes from a high elevation of approximately 660 feet
             Mean Sea Level (MSL) at the northern edge of the site to Big Black Creek, which flows along the southern
             border of the project boundary, at an elevation of approximately 617 MSL. Groundwater beneath the site
             is steeply sloping, and is located between elevations 621 and 625 MSL. Depth to groundwater at the site
             ranges from the ground surface at  Big Black Creek, to approximately 34 feet below grade at the northern
             edge  of the site. At the extraction well points,  the estimated depth  to groundwater ranges from 25 to
             SOfeet. It has been estimated that the primary aquifer at the site is 80 feet thick.

             Local Climate

             Regional climate characterization  indicates  a humid, continental  climate  influenced by  nearby Lake
             Michigan.  Lake Michigan influences Muskegon's climate by reducing summer  maximum temperatures,
             and by moderating arctic air masses during winter. Strong north-westerly air flow during the winter months
             overrides the relatively warm water of Lake Michigan, producing snow squalls along the eastern shoreline.
             Consequently,  snowfall in Muskegon  is considerably higher than what is observed across the lake in
             Wisconsin or inland toward the center of lower Michigan. A thick snow cover  results during winter months
             which may reduce the potential for wind-blown particulates. The influence of Lake Michigan is observed
             when comparing the Muskegon area with Grand Rapids,  approximately 40 miles inland. The mean annual
             number of days with maximum temperatures of 90°F or greater is six at Muskegon, and thirteen at Grand
             Rapids. The mean number of days where minimum temperatures are below 32°F is 144  at Muskegon
             compared  to 150 days at Grand  Rapids. The mean monthly temperature in Muskegon during January is
             approximately 23°F, with total precipitation averaging three inches, including  33 inches of snow. Inland at
             Grand Rapids, the mean temperature is 21 °F, with 2.5 inches precipitation, including 22 inches of snow.
             CONTAMINANT CHARACTERIZATION
             Primary Contaminant Groups:
             Key Specific Contaminants:
Volatiles (Halogenated)
Semivolatiles (Halogenated)

Benzene
Benzidine
2-Chloroaniline
1,2-Dichloroethene
Trichloroethene
3,3-Dichlorobenzidine
Aniline
Vinyl Chloride
_
                           Prepared by:	
                           U.S. Army Corps of Engineers
                           Hazardous, Toxic, Radioactive Waste
                           Center of Expertise
                                                     Final
                                            Octobers, 1998
                                                           42

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                                                                , Bofors Nobel Superfund Site
Over sixty contaminants have been detected in the groundwater beneath the site. The following table
provides a partial list of contaminants of concern at the site.

                       Table 1. Partial Listing of Contaminants of Concern
Acetone
Benzene
bis(2-Ethylhexyl)phthalate
Chlorobenzene
1 ,2-Dichlorobenzene
1 ,2-dichloroethane
Ethylbenzene
Tetrachloroethylene
Trichloroethylene
1 ,1 ,2,2-Tetrachloroethane
1 ,1-Dichloroethylene
3,3'-Dichloro-2,4'-diaminobiphenyl
Aniline
Benzidine
Butyl Benzyl Phthalate
Chloroisophorone
1 ,3-DichIorobenzene
Dichlorobiphenyl
Isophorone
Toluene
2-MethyIphenol
Vinyl Chloride
Xylene
3,3-dichlorobenzidine isomer
Azobenzene
2-chloroaniline
3-chloroaniline
Dichloroazobenzene
1 ,4-DichIorobenzene
1 ,2-dichloroethylene
Phenols
1,1,1 -Trichloroethane
Trimethylphenol
di-n-Propyl formamide
Trans-1 ,2-dichloroethylene

CONTAMINANT PROPERTIES

Table 2 lists selected properties for several of the most common contaminants present at the Bofors Nobel
site.
                                Table 2. Contaminant Properties
fc ' ItofStlyl I
Chemical Formula
Molecular Weight
Specific Gravity
Vapor Pressure
Boiling Point
Octanol-Water Partition
Coefficient («„,)
4~
-
g/mole
-
mmHg
°C
-
; Benzene
C6H6
78.11
0.8765
76 (20°C)
80.1
135
''Benz|ftnje<|
C12H12N2
184.23
1.250
0.83 (20°C)
402
65
c
C6H6CIN
127.57
1.213
0.1 7 (20 C)
208.8
79
flilpilE'*;
C2H2CK
96.95
1.28 (cis)
1.26 (trans)
200 (trans)
(14°C)
60 (cis)
48 (trans)
123 (trans)
?'SJ*4I5r.
C2HCI3
131.5
1.46
57.8 (20°C)
86.7
339
NATURE AND EXTENT OF CONTAMINATION

Several environmental  investigations have been performed at the Bofors Nobel site.  In 1978, Bofors
Lakeway, at the direction of MDEQ,  completed installation and began operation of thirteen groundwater
extraction wells, primarily located along the southern boundary of the property. The wells were designed
to prevent the migration of contamination beyond the site boundaries.  Operation of the extraction wells
has continued since that time. Prior to 1994, extracted groundwater was treated at the Lomac facility and
discharged to the  Muskegon County  Wastewater Treatment Facility. Since 1994, groundwater treated by
the UV oxidation system has been discharged directly to Big Black Creek. No groundwater contamination
has been detected down  gradient of the project site. Modeling  has indicated that the existing extraction
system  is capable  of  retaining the  plume of contamination  on the project site. It is estimated  that
termination of extraction well  operation would allow contaminant migration offsite within three days of
pump cessation.
               Prepared by:
         Final
               U.S. Army Corps of Engineers
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               Center of Expertise
October 6,1998
                                              43

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                                                                 . Bofors Nobel Superfund Site
Remedial investigation field activities at the site have included:

a)      Surface soil sampling
b)      Subsurface soil sampling
c)      Groundwater sampling
d)      Geophysical investigation
e)      Air monitoring

Data from  hundreds of soil  boring and groundwater monitoring wells has allowed the development of
numerous two-dimensional contour diagrams illustrating the surface areas, groundwater elevations, and
contaminant concentrations  profiles.  These diagrams  have been  used to verify that current pumping
scenarios are adequate to provide capture of the site contamination.

The hydrogeologic unit located beneath the project site is consistent in composition and exhibits a range
of conductivity values commonly associated with a clean sand aquifer. The mean hydraulic conductivity for
the wells tested at the project site was 4.4 x 10'2 cm/sec. The transmissivity at the site ranges from 43,000
to 60,000 gpd/ft, with an average value of 48,000 gpd/ft. These values are judged to be representative of
the aquifer, based upon its characterization. The storage coefficient, also felt to be consistent for a sandy
aquifer, was found to be approximately 0.27. Based upon the assumption that the aquifer is 80 feet thick
and the average transmissivity of 48,000 gpd/ft, the coefficient of permeability was found to be 600 gpd/ft2,
or 2.8 x 10"2 cm/sec, which correlates well with the previously stated  value of 4.4 x 10"2 cm/sec.

The most prevalent and highest concentration contaminants of concern at the Bofors  Nobel  site include
benzene, benzidine, 2-chloroaniline,  1,2-dichloroethene, trichloroethene, 3,3-dichlorobenzidine, aniline
and vinyl chloride.  The highest groundwater concentrations detected for each of the contaminants listed
above  are shown in Table 3. These concentrations are all  from groundwater samples collected prior to
installation of the GWTP (pre-1994).

                Table 3. Highest Detected Contaminant Concentrations (Pre-1994)
Constituent
Benzene
Benzidine
2-Chloroaniline
1 ,2-Dichloroethene
Trichloroethene
3,3-Dichlorobenzidine
Aniline
Vinyl Chloride
Maximum Concentration (ug/L)
60,000
1,300
63,000
1,900
43
2,600
10,000
1,000
. . - WeIlorii|illusl|llfc;;-;
WC-27
MW-108
WC-27
LW-3
PW-41
PW-41
WC-27
W-33
The average concentrations of the most prevalent groundwater contaminants over a 16-month period from
November 1994 through February 1996 are shown in Table 4.
               Prepared by:
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October 6,1998
                                              44

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                                                             , Bofors Nobel Superfund Site
            Table 4. Average Concentrations for Selected Contaminants (1994-1996)
*{*' ,"""
Benzene
Benzidine
2-Chloroaniline
1 ,2-Dichloroethene
Trichloroethene
3,3-Dichlorobenzidine
Aniline
Vinyl Chloride

350
315
270
180
100
80
40
33
As of October 1997, extracted groundwater contained approximately 1.5 mg/L of total organic compounds
prior to treatment. The metals concentrations in the plant influent have not exceeded the regulatory limits
established by the MDEQ.

OU 01  (GOU) was intended as a remedy for contaminated groundwater at the site. To summarize the
aquifer parameters discussed in the previous paragraphs, the critical aquifer characteristics have been
estimated as follows:

                               Table 5. Aquifer Characteristics
""?" „* ^ *•
' o ;• Unit' ' "
Operable Unit 1
Apparent, , '.'
•^'" '^thickness
80 feet
-i~ Hydraulic
Conductivity SI .
600 gpd/ft-2
^Transnyssfvity* .
48,000 gpd/ft
/»/
^ FI6w Direction
Southerly
Groundwater at the southern boundary of the project site and across the entire Bofors Nobel site acts as
an unconfined aquifer.
                        TREATMENT SYSTEM DESCRIPTION
PRIMARY TREATMENT TECHNOLOGY

Pump and Treat with UV Oxidation

SUPPLEMENTAL TREATMENT TECHNOLOGIES

Pretreatment (water) - Chemical (chemical precipitation) and Filtration
Post-Treatment (water) - Carbon Adsorption and Air Stripping
Post-Treatment (solids) - Sludge Dewatering (filter press)

TIMELINE

Table 6 shows a timeline of significant activities that have occurred on the Bofors Nobel project.
              Prepared by:
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Octobers, 1998
                                            45

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                                                                 , Bofors Nobel Superfund Site
                                    Table 6. Project Timeline
Date
September 1991
September 1991 through April 1992
August 1992
October 1992
November 1992
June 1994
September 1994
' ^ -, ' .Activity *" - ,, ,„ , '"' .
Advanced Oxidation Treatment Demonstration Testing
System Design
Bid Submittal Deadline
Contract Award
Construction Mobilization
Construction Complete
Initiate Treatment Operations
TREATMENT SYSTEM SCHEMATIC AND TECHNOLOGY DESCRIPTION AND OPERATION

Figure 3 shows a schematic diagram of the groundwater treatment system.

The extraction well network was constructed in 1978 as part of a proactive approach to site cleanup by the
state  of Michigan. No  additional  extraction wells were installed  during construction of the groundwater
treatment facility. Records providing extraction well details, pump types and casing/screen intervals are
limited and were not available for the preparation of this document.

The facility design flow has been  established  as 782 gpm, with a maximum of 732 gpm derived from the
wellfield, and 50 gpm as plant recycle. The current operating flow rate varies between 390 and  500  gpm,
depending upon the season. Groundwater is  discharged to the treatment facility from the extraction well
network and was initially directed to a metals precipitation unit (solids contact unit 1) for pretreatment prior to
organics removal. The metals precipitation unit was operated for approximately two years after system  start-
up. Because it  was determined to be  unnecessary at that time,  it has since been taken out of service.
Following  solids contact unit 1, water is sent through a  dual media gravity filter. Filtered water gravity  flows
through a  UV Oxidation system to treat organic contaminants. Treated water gravity flows into a sump, from
which it is pumped through four columns of granular activated carbon (GAG).  GAG treatment is provided for
polishing,  and as a backup measure in the event the UV system is offline.  Following polishing,  the pH is
elevated in solids contact unit 2 to convert ammonium ions  (NH4+ - present at neutral  pH) to  strippable
ammonia  (NH3), for removal  within the ammonia stripping columns. The pH-adjusted water travels from
solids contact unit 2 to the ammonia stripping sump, where it is then pumped through the ammonia stripping
column. After stripping,  the water is neutralized by  acid addition, and the water  is directed to the effluent
holding vault. The holding vault also serves as  a source of fire protection water at the facility. Water from the
holding vault overflows through a weir and discharges to Big Black Creek at the southern edge of the site.

Solids generated in the two solids contact units are pumped to a sludge thickener. Thickened  sludge is
amended with lime to improve handling and dewatering, and  is then pumped to  a sludge filter press. The
25 to 35 percent solid sludge cake from the filter press is further processed to remove excess water using
a sludge dryer.  The solids content in the sludge is increased to  approximately 90 percent in the sludge
dryer. Sludge exiting the sludge dryer is transferred to bags and is disposed at a solid waste landfill. Water
generated by the filter press is recycled to the  head of the treatment facility.
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                                               46

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                                                                                   , Bofors Nobel Superfund Site
                                                                                             TO
                                                                                          ATMOSPHERE
EXTRACTION
  WELLS   SOLIDS CONTACT
            UNIT t
             SLUDGE
           TO DISPOSAL
                 SOLIDS CONTACT UNIT 1
                 GRAVITY FILTER


                 SLUDGE THICKENING PROCESS/FILTER PRESS
                  UV/OXIDATION/GRANULAR
                  ACTIVATED CARBON
                  SOLIDS CONTACT UNIT 2
                  AIR STRIPPERS
Removes metols from woter by elevating pH and adding
polymer to form a slurry mixture.  Slurry sent to sludge
Thickening Process: remaining water sent to Gravity Filter.
Note: This unit was taken out of service in 1995 because
it was not needed to meet  discharge  limitations.


Removes fine particles from woter.


Forms sludge by adding lime to slurry and forcing it
through Filter Press.  Sludge sent  offsite  for disposal.
water recycled to Solids Contact Unit  1.


Removes organic compounds from  water.
Elevates the pH for ammonia removal and adds a
polymer to form o slurry mixture. Slurry sent to  sludge
Thickening Process.


Ammonia stripped from water prior to discharge to Big
Black Creek.
                                                                                                   TO BIG BLACK CREEK
                          Figure 3.  Groundwater Treatment Process Schematic
                            Bofors Nobel Superfund Site, Muskegon, Michigan
                Prepared by:
                U.S. Army Corps of Engineers
                Hazardous, Toxic, Radioactive Waste
                Center of Expertise                     4
                                                       	Final
                                                        Octobers, 1998

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                                                               , Bofors Nobel Superfund Site
 KEY DESIGN CRITERIA

 The expected operational lifetime of the treatment system is estimated to be greater than 60 years.

 OPERATING PARAMETERS AFFECTING TREATMENT COST OR PERFORMANCE

 The following table lists several of the key operating parameters for the GWTP. Where possible, design
 values are compared to actual values.
Parameter
Pumping Rate
Water Temperature
Influent
UV Oxidation Unit
Effluent
Influent and Effluent Contaminant Concentrations
Influent (9 Primary Contaminants)
Effluent (9 Primary Contaminants)
Pressure Loss Through GAG Columns
System pH (influent)
Chemical Feed Rates
Caustic (50% NaOH)
Acid (96% H2SO4)
Polymer
Hydrogen Peroxide
Ozone Generated
Head Loss Through the Dual Media Filtration System
• '•-'>' Units'!***1*-?
gpm
—
OF
OF
OF
—
ug/L
Mg/L
PSI
NA
—
gal/day
gal/day
gal/day
gal/day
Ibs/day
Feet
Design Value
782
—
NA
NA
NA
—
5,218
43
1-3
7.0
—
380
687
18
NA
NA
2.57
^ActualWalue(1)r
390 - 500
—
56
54
54
	
<1500
<9
NA
7.3
...
NA
NA
39
8.0
49.7
NA
 (1)-1998 Information
 NA - Not Applicable
                        TREATMENT SYSTEM PERFORMANCE
PERFORMANCE OBJECTIVES

The overall objective of the GOU at the Bofors Nobel Superfund Site is to control the offsite migration of
contaminated groundwater, and to reduce the contaminant mass remaining in the aquifer. Limitations have
been established by the MDEQ for discharge of treated groundwater from the site. Table 7 lists the MDEQ
limitations for water discharged from the GWTP to Big Black Creek. Weekly sampling is required for all
parameters listed in the table.
The treatment strategy for OU 01 at the Bofors Nobel site is to first address the contaminated groundwater
beneath the project site by preventing offsite migration. After successfully achieving this goal, the source
of the site contamination (soil and sludge in the lagoons) must be addressed in order to allow the site to be
remediated. Contaminated soils at the project site have not yet been addressed through any type  of
remediation activity, therefore, a continuous source of contaminant loading to the aquifer remains at the
site.  To date, alternatives that  have been considered  to  address the  contaminated soils  include
incineration,  excavation  with consolidation  in  an  onsite landfill,  and  placement  of a slurry
              Prepared by:    	
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October 6,1998
                                             48

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                                                              , Bofors Nobel Superfund Site
                         Table 7. Discharge Limitations for the GWTP
JC
COD
Ammonia Nitrogen
12/1-4/30
5/1 - 9/30
10/1-11/30
Purgeable Halocarbons
Each
Purgeable Aromatics
Each
Aniline
2-Chloroaniline
Carbon Disulfide
2-Butanone
2-Methylphenol
Benzidine
3,3-Dichlorobenzene
2,4-Dinitrophenol
1,1-Dichloroethane
1,1-Dichloroethene
Total Copper
Total Lead
Total Mercury
Total Zinc
Dissolved Oxygen
5/1 - 9/30
10/1 -4/30
pH
t^Jf:'*^ •:M^^^^-^M:ff:,:^
20 mg/L
—
29 mg/L
2.0 mg/L
12 mg/L
—
5 Mg/L
—
5 Mg/L
10 pg/L
20 Mg/L
5 Mg/L
500 Mg/L
5 Mg/L
0.12 Mg/L (1)
0.18 Mg/L (1)
29 Mg/L (1)
5 Mg/L
5 Mg/L
62 Mg/L/ 38 Mg/L (1)
11M9/L(1)
0.001 3 Mg/L (1)
320 Mg/L/ 185 Mg/L (1)
—
6.5 mg/L (minimum)
4.0 mg/L (minimum)
6.5 - 9.0 (acceptable range)
(1) - Allowable Monthly Average Concentration
               Prepared by:
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	Final
 October 6,1998
                                              49

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 ——————————^—___-^_— Bofors Nobel Superfund Site

 wall combined with installation of an impermeable cap at the site. At the time this report was prepared, no
 final action had been selected to address the issue of soil and sediment contamination.

 In 1991, treatability testing was performed to assess the performance of several groundwater treatment
 technologies. Technologies  tested included: UV/peroxide oxidation,  UV/ozone  oxidation, and carbon
 adsorption. Test results indicated that UV/ozone oxidation was the superior technology for treatment of
 groundwater at the Bofors Nobel site.

 TREATMENT PERFORMANCE DATA

 The concentration of contaminants in the influent to the groundwater treatment facility has consistently
 been less than design values. As  previously indicated, the total concentration of organic compounds in
 extracted groundwater is approximately 1.5 mg/L (versus a design estimate of greater than 5 mg/L), and
 has not varied significantly  since project start-up. The consistency of the influent concentration is
 expected, since the source of soil and sediment contamination at the site has  not yet been addressed. It is
 likely that  future  soil remediation at the site will include removal  and/or capping of the contamination,
 ultimately leading to a reduction in the amount of contamination being carried to the site groundwater. It
 has been estimated that long-term cleanup of the site groundwater will take 50 to 70 years.

 The groundwater treatment facility has consistently treated  the target contaminants to  concentrations
 below the limits established by the MDEQ. The site  has not exceeded the permit limits for any  individual
 contaminant since start-up in  1994. Toxicity testing was not required under the original operating contract,
 but has since been added to the facilities  operating charter.  Since initiation of toxicity testing,  some
 difficulties have been encountered when testing 100 percent effluent on the target specie, Daphnia magna
 or D. pulex. Toxicity testing issues are currently being addressed at the facility,  and  should be closely
 coordinated with state regulatory personnel.

 Since 1994, over 7,500 pounds of  organic compounds have been  removed from the groundwater at the
 Bofors Nobel site. The principal treatment technology employed by the groundwater treatment system at
 the site is UV oxidation. This technology treats organic compounds by destruction as opposed to phase
 transfer. Destruction treatment technologies function  by converting (either by physical or chemical means)
 contaminants into less harmful substances, many of which can be discharged directly to the environment.
 Phase transfer technologies collect contaminants from one medium (e.g.,  water) and concentrate them in
 or on another medium (e.g., granular activated carbon). The concentrated contaminants are subsequently
 easier and less expensive to transport and dispose.  Destruction technologies are typically preferable  to
 phase transfer technologies because with destruction, the need for further handling or treatment of wastes
 is minimized or eliminated.

As of October 1997, the Bofors  Nobel  groundwater  treatment facility has processed approximately 700
million gallons of  contaminated groundwater  without  exceeding  any of  the  discharge limitations
established  by the state of Michigan. The  treatment facility has been operating since  September 1994,
effectively preventing migration of the site contaminants. The facility has treated an average of six pounds
of organic compounds per day since startup, with little variation in  the contaminant plume configuration.
There have been no adverse air emissions caused by the operation of the treatment facility. The system is
able to operate with  no downtime (100% operability) as a result of system flexibility and operating flow
rates below system design flow rates. During an average monthly operating cycle in 1997, the facility used
between 190,000 and 200,000 kwhrs of electricity, and approximately 10,000 CCF (therms) of natural gas,
depending upon ambient temperature and treatment flowpath.  In 1997, treatment system chemical usage
rates averaged 500 gallons per month for hydrogen peroxide, and 2500 pounds per month for ozone.
Pretreatment prior to the UV oxidation system is not currently being practiced, with no adverse findings.
               Prepared by:   	
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         Final
Octobers, 1998
                                               50

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                                                                 , Bofors Nobel Superfund Site
Since system startup, there have been periodic shutdowns for scheduled maintenance activities. The
replacement of six concrete C-5000 reactor vessels with stainless steel reactor vessels  has been
completed. This change was required  as a result of leakage that was occurring along cracks in the
concrete vessels and at the piping entry points.

Hydrodynamic Performance

Thirteen extraction wells are located along the southern boundary of the project site, adjacent to Big Black
Creek. All extraction wells are not operated simultaneously. Typically, nine wells are sufficient to provide
capture of the contaminant plume. Selection of operating extraction wells is based on total system flow
rate. The  extraction wellfield has a history of problems associated with the development of biomass
around  the well screens and within the  well packs. A proprietary rejuvenation process, blended chemical
heat treatment  (BCHT), has been implemented  to improve flow rates in the wells. The flow  rates from
individual  wells vary significantly, and  can range from 40 to  100 gpm, depending upon the degree of
fouling  and aquifer characteristics.  It  is estimated  that the contaminant  plume at the site has been
contained horizontally and vertically by the extraction well network.
                                Treatment System Cost
PROCUREMENT PROCESS
The Feasibility Study and the project ROD called for Ultraviolet Oxidation (UV Oxidation) as the selected
technology for destruction of organic contaminants present in the groundwater.  UV/ozone oxidation was
determined to be the most appropriate treatment technology for this site based on a treatability study that
evaluated  UV/ozone oxidation, UV/peroxide oxidation  and GAG. The ROD also directed final effluent
discharge to a cold water trout stream located on site (Big Black Creek). Rapid and complete evaluation of
the chosen technology was performed  by the  Corps to determine whether the low discharge standards
established by the state could be achieved. The evaluation results indicated that the selected technology
would allow the discharge limitations to be met. One of the primary concerns was the contracting effort
related to the procurement of the selected treatment system. The number of vendors capable of meeting  the
treatment performance requirements was limited, and the proposed life cycle costs for the various vendors
was an important consideration.

The relatively recent development of the oxidation  technology (mid 1970s) is  one of the  reasons that
corporate competition was limited. At the time design was initiated on the  groundwater treatment facility
(September 1991), only three vendors had  exhibited  the capabilities necessary to  effectively treat a
groundwater contaminated with both volatile and semivolatile constituents on a high flow rate (greater than 1
MGD) basis. Because it was anticipated that the treatment system would operate for a long period of time
(greater than 30 years),  it was anticipated that operation and maintenance (O&M) costs might be more
significant  than capital costs.  Based on this, consideration was given to procurement of the  UV Oxidation
system based upon life cycle cost rather than capital cost. Based upon the outcome of the predesign testing,
a sole source justification was used to  procure the UV Oxidation vendor most appropriate for this specific
groundwater application. Justification was contingent upon two primary criteria: the capability of the process
to treat the contaminated groundwater to acceptable levels, and life cycle cost for the end user. The outcome
of this logical progression was a "treat-off" between three vendors ,io allow the  government to obtain  the
services of the vendor that  could most cost effectively address the contaminants present in  the  site
groundwater.

The contract to construct and operate the GWTP for one year was awarded on a firm fixed-price (FFP) basis
 to Sverdrup of St.  Louis,  Missouri. The O&M period was later expanded from one year to 2.5 years. At  that
 time, the O&M contract was awarded to Ayers,  Lewis, Norris and May of Muskegon, Michigan.
                Prepared by:
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	Final
 Octobers, 1998
                                                51

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                                                                 , Bofors Nobel Superfund Site
 TREATMENT SYSTEM COST
 Cost data for the Bofors Nobel project has been developed using available records at the facility. It is
 estimated that 7,500 pounds of organic compounds were removed from extracted groundwater between
 September 1994 and October 1997. It is also estimated that 700 million gallons of groundwater have been
 extracted from the site over the same time period. The following tables list capital and annual O&M costs
 for the project.
 Capital Costs:
"DIRECT COSTS •:.•-.•'•.•.•.•:::;:::;.:,•••• •• —•:::.;•• :o'' ';.?••
System Mechanical
Ultraviolet Oxidation System
Granular Activated Carbon
Ammonia Stripping
Solids Contact Units
Filter system
Sludge Handling
Chemical Feed
Chemical Storage
Hydrated Lime Feed System
Tankage and Pumps
System Plumbing/HVAC
Miscellaneous Equipment
Architectural/Structural
Electrical/Controls
Civil/Site
One Year O&M and System Startup
Contract Amount •-.. 'n^v:. '>'•$!;&„,.

2,200,000
420,000
1,200,000
600,000
300,000
400,000
60,000
50,000
150,000
150,000
900,000
250,000
1,500,000
800,000
520,000
2,700,000
.,.,-. «$12,2CKM)00 W-. -
 Operating Costs:
          Staffing/Labor
                            1997 Average Values
          Offsite Laboratory Testing
          Process Chemicals
          Parts Replacement and Onsite Lab
          Extraction Well Maintenance
          Interior/Exterior Maintenance
          Miscellaneous Expenses
          Electricity (at $0.06 per kwh)
                               Utility Usage
          Natural Gas (at $0.50 per therm (CCF))
                           Annual Operating Cost
                                                                          260,000
 160,000
                                                                           70,000
                                                                           20,000
                                                                           10,000
                                                                           40,000
                                                                            5,000
 138,000
  60,000
$763,000
Based on these costs, it can be calculated that $13,726,000 has been spent over the first three years of
treatment system  operation.  This  total  cost  translates  to treatment costs of $1,830  per  pound  of
contaminant removed, or $19.61 per 1000 gallons of groundwater treated. If removals are compared to
annual O&M costs, yearly treatment costs are equal to $305 per pound of contaminant removed or $3 27
per 1000 gallons of water treated.
               Prepared by:
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                                                                                          Final
        Octobers, 1998
                                              52

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                                                                , Bofors Nobel Superfund Site
                          REGULATORY/lNSTiTUTiONAL ISSUES
Surface water discharges from the treatment system are regulated by MDEQ. Discharge limitations for the
site are listed in a previous section of this report (Treatment System Performance).

Groundwater cleanup criteria have not yet been established for this site. It is expected that the USEPA will
develop these criteria in September 1998 in the form of a second amendment to the ROD for the site.
                        OBSERVATIONS ANDiI_EssoN$ LEARNED
Procurement Issues:
It appeared that a FFP contract worked well overall for this project. It is possible that a cost-reimbursable
contract would have allowed a higher level of responsiveness to field modifications (especially smaller
modifications)  to  the system during the construction phase. These modifications  might have  been
processed and implemented more rapidly under a cost-reimbursable contract.

Implementation Considerations:

A  preliminary  understanding  of the site characteristics was obtained  through  the  operation of the
groundwater extraction  system, which went online in 1978.  It was recognized that until a remediation
decision  is made on the source of the contamination (the  sludge lagoons), significant headway into
reducing the volume of contamination annually treated would be difficult to achieve. It is anticipated that it
will be easier to reduce the volume of contamination in the groundwater at the site following a capping  or
removal action. A preventive maintenance program to insure  uninterrupted operation of the groundwater
extraction system has been implemented to reduce downtime associated with biofouling and plugging  of
the well screens.

During selection of the principle treatment technology (UV Oxidation), it was recognized that water quality
parameters associated  with deposition of various  species on the ultraviolet light quartz sheaths could
impact system performance,  and ultimately  increase treatment cost if not addressed during system
design. As a result of these concerns, pretreatment components were included in the treatment system to
minimize the possibility of poor performance in the principal treatment units.

The establishment of effluent discharge criteria early in the design process is critical in order to provide a
treatment system that will be capable of meeting all requirements. Toxicity testing of the plant effluent was
stipulated following completion of construction. It is important that the designer be aware of the potential
for chronic and acute toxicity testing, so that consideration may be given to alternative treatment schemes
that may be necessary  to meet toxicity requirements. At a minimum, the designer should closely consult
and coordinate with the regulatory personnel responsible for developing the permit requirements to ensure
that issues relative to specie selection and  dilution concentrations are appropriately addressed for the
specific site characteristics.

The concept of having the construction contractor perform initial (first year) O&M of the treatment system
appeared to be a good  idea. This allows more continuity and a smoother transition from the construction
to O&M phase of the project.

Consideration  should be given on future projects  to the possibility that more system  operators will  be
required  during the early stages (first 2 years) of O&M. After this period, it is likely that most operational
issues will have been addressed, and that less system troubleshooting will be necessary.
               Prepared by:
                                                                                          Final
               U.S. Army Corps of Engineers
               Hazardous, Toxic, Radioactive Waste
               Center of Expertise
Octobers, 1998
                                               53

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                                                                  , Bofors Nobel Superfund Site
 Technology Limitations:

 Until an overall remediation strategy is developed to address contamination still present within the ten
 onsite lagoons, this technology is not expected to reduce the in-situ contamination in the site groundwater
 to below the levels required by MDEQ. The inability of the constructed system to rapidly reduce the level
 of site groundwater contamination is a result of the presence of a contamination source area overlying the
 impacted aquifer. Until the source area is addressed under a separate remediation action, contaminants
 will continue to leach to the groundwater. No alternative systems have been recommended or identified to
 improve upon what is currently in place at the Bofors Nobel  superfund site  for treatment of the
 contaminated groundwater.

 While continuing plume  containment appears to be successful,  the  overall concentrations  of VOCs,
 SVOCs and metals have not been significantly decreased after several years of extraction and treatment.

 Future Technology Selection Considerations:

 The following observations were made based on conversations with the construction contractor, various
 vendors, the site construction manager and the using agency.

 Perhaps  the  most important aspect of  any  project  is  communication.  Maintaining open lines  of
 communication between different agencies insures that the needs of all parties are incorporated into the
 final product. This aspect of the project was important not only in relation to the UV Oxidation process, but
 also  in regard to  items  such as  establishment  of discharge criteria for the completed  groundwater
 treatment  facility.   Due  to the  complexity  and  uniqueness  of  the  selected  contracting  vehicle,
 communication was especially critical in this project.

 The Treat-Off test associated with the predesign stage of the project required a concerted  effort by the
 designer to insure that the goals of the "treat-off1 were clearly  communicated to the vendors. This was
 necessary to insure that the vendors realize that the "treat-off1 test is the vehicle by which the selection of
 the full-scale process will be made. As a lesson learned, communication  between the designer and the UV
 Oxidation vendors regarding the ultimate goals of the pilot testing should be emphasized.

 Following selection of the most appropriate vendor for the UV Oxidation  system, it was  important that
 good communication was maintained during the design  process. Items such as electrical connections,
 system control,  cooling water requirements,  system  placement,  foot print sizing  and a host of other
 technical issues had to be presented to the supplier of the UV Oxidation system.

 It is always important, when developing any proprietary  specification, that an equitable project cost be
 maintained,  and that cost increases following notification to the vendor of choice be minimized. During
 predesign activities, it should be emphasized  to the prospective suppliers that the final report that they
 supply to the using agency will be used as the basis of selection for the finished product. It should also be
 emphasized that the vendor will be held to the costs presented within the report for the full-scale system,
 provided the final design assumptions do not change. It may be appropriate to enter into a legally binding
agreement with the selected vendor to establish capital and operating costs. It should  be recognized that
operational costs for the full-scale system are an integral part of the projected system costs, and little can
be done other than estimate the costs based upon supplier projections. The  project designer should
review the vendor costs for accuracy. Another potential option is to provide a fixed cost line item within the
bid  package, so that all  prime  contractors are  aware of the costs associated with the  UV Oxidation
package.
               Prepared by:
               U.S. Army Corps of Engineers
               Hazardous, Toxic, Radioactive Waste
               Center of Expertise
         Final
Octobers, 1998
                                               54

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                                                              , Bofors Nobel Superfund Site
Following award of the contract, it is important to develop a  strong working  relationship between the
contractor, supplier, and designer, so that a quality product will be supplied. As a part of this process, it is
very effective to hold  pre-submittal  conferences on all major equipment packages to insure that the
contractor, supplier, and designer are all fully aware of the requirements of the specific process, and are
aware of the responsibilities of each individual. The pre-submittal conferences will set the tone  for the
subsequent dealings between all of the parties.
                                      REFERENCES
Major Sources for Each Section:

Site Characteristics:
Treatment System:
Performance:
Cost:
Regulatory Institutional Issues:
Schedule:
Lessons Learned:
Source #s (from list below) - 3, 4
Source #s - 6, 8
Source #s-1,2
Source #s - 1, 2
Source #s - 4, 7
Source #s - 5
Source #s - 7, 8
Chronological List of Sources and Additional References:

1.      1997 Annual Monitoring information - Facility Operations

2.      Monthly Operating Reports 1994 - 1997

3.      Remedial Investigation Report for the Bofors Site, Muskegon, Michigan; February 1990.

4.      Phase II Remedial Investigation Report for the Bofors Site, Muskegon, Michigan; March 1990.

5.      Record of Decision, Bofors Nobel Superfund Site, Muskegon, Michigan; September 1990.

6.      Streckfuss, Ted H. "Lessons Learned:  So!e Source Procurement of a UV/Oxidation System
        and Operating Problems  in a Biological  Groundwater Treatment Plant."   Third USAGE
        Innovative Technology Transfer Workshop, June 1993.

7.      Streckfuss, Ted H.,  Olson, Craig R.  "Innovative Contracting Strategies  for  Equipment
        Procurement, Bofors Nobel  Superfund Site,  Muskegon, Ml."  Fourth Forum on Innovative
        Hazardous Waste Treatment Technologies: Domestic and International." November 1992.

8.      Streckfuss, Ted H. "The  Greening of Groundwater."  American Society of Civil Engineers Civil
        Engineering. April 1995.
                                  ACKNOWLEDGEMENTS
                             This analysis was originally prepared by:

                               Omaha District Corps of Engineers
                                    12565 West Center Road
                                   Omaha, Nebraska 68144
                              Contact: Ted H. Streckfuss, Eny. P.E.
                                        (402) 697-2560

 This report was modified for the U.S. Army Corps of Engineers under USAGE Contract No. DACA45-96-
 D-0016, Delivery Order No. 12.
               Prepared by:
               U.S. Army Corps of Engineers
               Hazardous, Toxic, Radioactive Waste
               Center of Expertise
                                    	Final
                                     Octobers, 1998
                                              55

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               56

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Pump and Treat of Contaminated Groundwater at
       the City Industries Superfund Site
              Orlando, Florida
                     57

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                   Pump and Treat of Contaminated Groundwater at
                            the City Industries Superfund Site
                                      Orlando, Florida
Site Name:
City Industries Superfund Site
Location:
Orlando, Florida
Contaminants:
Chlorinated solvents and BTEX
- Initial contaminants of concern
included 1,1,1-DCA, 1,1-DCE,
methylene chloride, vinyl chloride,
PCE, TCE, 1,1,1-TCA, benzene,
toluene, ethylbenzene, acetone,
MEK, MIBK, and phthalates
-  Maximum concentrations
detected in 1988 included 1,1-DCE
(6,000 ug/L), acetone (146,000
ug/L), and MIBK (78,000 ug/L)
Period of Operation:
Status: Ongoing
Report covers: May 1994 through
May 1997
Cleanup Type:
Full-scale cleanup (interim results)
Vendor:
Design: Jerry Peters
PEER Consultants P.C.
12300 Twinbrook Pkwy, Suite 410
Rockville,MD 20852
(301)816-0700
Construction and O&M: ERM-
EnviroClean, Inc.
250 Phillips Blvd #280
Ewing,NJ 08618
(609) 895-0050
State Point of Contact:
Don Harris
Florida DEP(FDEP)
Twin Towers Office Bldg.
2600 Blair Stone Road
Tallahassee, FL 32301
(904)488-0190
Technology:
Pump and Treat with Air Stripping
- Extraction system consists of 13
recovery wells installed across the
width of the initial contaminant
plume
- Treatment includes an
equalization/neutralization tank
followed by an air stripping tower
- A network of 41 monitoring wells
and 13 recovery wells are used to
monitor quarterly changes in
groundwater quality
- The actual average pumping rate
for the system has been 195 gpm
Cleanup Authority:
CERCLA Remedial
- ROD Date: 3/29/90
EPA Point of Contact:
Pam Scully, RPM
U.S. EPA Region 4
345 Courtland St., N.E.
Atlanta, GA 30365
(404) 562-8898
Waste Source:
Improper disposal practices and
unauthorized dumping
Purpose/Significance of
Application:
The hydrogeology at this site is
relatively simple and hydraulic
conductivity relatively high,
conditions which should lead to a
successful application for pump
and treat technology.
Type/Quantity of Media Treated:
Groundwater
-151.7 million gallons treated as of May 1997
- No NAPL have been observed in monitoring wells on site
- Extraction wells are located in one aquifer at the site
- Hydraulic conductivity reported as 6.3936 fit/day
                                               58

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                  Pump and Treat of Contaminated Groundwater at
                            the City Industries Superfund Site
                               Orlando, Florida (continued)
Regulatory Requirements/Cleanup Goals:
- Cleanup goals are to remediate groundwater to levels set by the FDEP for the following constituents: acetone
  (700 ug/L), benzene (1 ug/L), 1,1-DCA (5 ug/L), 1,1-DCE (7 ug/L), cis-l,2-DCE (70 ug/L), trans-l,2-DCE (70
  ug/L), ethylbenzene (700 ug/L), methylene chloride (5 ug/L), MEK (200 ug/L), MIBK (350 ug/L), PCE (3
  ug/L), toluene (2,000 ug/L), 1,1,1-TCA (200 ug/L), TCE (3 ug/L), total phthalates (3 ug/L), and vinyl chloride
  (1 ug/L).
- The primary goal of the system is to achieve hydraulic containment of the plume.
Results:
- From May 1994 through May 1997, total concentrations of contaminants have been reduced 86% from 3,121
  to 444 ug/L.  However, concentrations of all VOCs remain above cleanup goals.  In addition, concentrations of
  acetone, 1,1-DCE, and MIBK remain at persistently elevated concentrations.  Through May 1997,
  approximately 2,700 pounds of contaminants have been removed from the groundwater.
- No contaminants have been detected in down-gradient monitoring wells since the beginning of remedial
  operations, and the plume has been contained.
Cost:
- Estimated costs for pump and treat were $1,674,800 ($1,094,800 in capital and $580,000 in O&M), which
  correspond to $10.60 per 1,000 gallons of groundwater extracted and $590 per pound of contaminant removed.
Description:
The City Industries site operated as a hazardous waste Treatment, Storage, and Disposal Facility (TSDF) from
1971 until 1983. From 1981 through 1983, EPA and county officials cited the facility for multiple violations of
RCRA.  In 1983, EPA, FDEP, and the county ordered the business to close, and the owner of the site abandoned
the property. FDEP completed a multi-phased remedial investigation in May 1986. The site was listed on the
NPL in March 1989 and a ROD was signed in March 1990.

The extraction system used at the site consists of 13 recovery wells installed across the width of the initial
contaminant plume. Treatment includes an equalization/neutralization tank followed by an ah" stripping tower.
Total concentrations of VOCs have declined 86% at this site, but remain above cleanup levels. The
hydrogeology at this site is relatively simple and hydraulic conductivity relatively high, conditions which should
lead to a successful application for pump and treat technology. According to the RPM, contaminant levels at the
site in late 1997 and 1998 are lower than shown in the May 1997 monitoring data.	
                                                59

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                                                                  City Industries Superfund Site
                                   SITE INFORMATION
Identifying Information:
Treatment Application:
City Industries Superfund site
Orlando, Florida

CERCLIStf: FLD055945653

ROD Date: March 29,1990


Background	
Type of Action: Remedial

Period of operation:  05/94 - Ongoing (Data
collected through May 1997)

Quantity of groundwater treated during
application: 151.7 million gallons
Historical Activity that Generated
Contamination at the Site:  Hazardous waste
handling

Corresponding SIC Code: 4953 (Hazardous
Waste Material Disposal Sites)

Waste Management Practice That
Contributed to Contamination:  Improper
disposal practices and unauthorized dumping

Location: Orlando, Florida

Facility Operations [1,2,3]:
•   The City Industries site operated as a
    hazardous waste Treatment, Storage, and
    Disposal (TSD) facility from 1971 until 1983.
    From 1981 through 1983, U.S. EPA and
    Orange County officials cited the facility for
    multiple RCRA violations. In July 1983,
    EPA, the Florida Department of
    Environmental Protection (FDEP), and
    Orange County ordered the business to
    close under Resource Conservation and
    Recovery Act (RCRA) authority.

•   In 1983, the owner of the site abandoned the
    facility. That same year,  EPA and FDEP
    performed source control activities, including
    the FDEP removing 41 tons of waste drums,
    sludge, and liquid hazardous waste.  EPA
    also thermally treated 1,670 tons of
    contaminated soil off site, and returned the
    clean soil to the site as fill. EPA removing
    10 tons of highly contaminated soil and
    transported it to an off-site hazardous waste
    landfill. As a result of these activities, the
    only remaining media of concern at the site
    was the groundwater.

•   In 1984, EPA issued an Administrative Order
    to City Industries requiring cleanup;
     EPA
                                                                                         In
    however, the company ignored the order.
    December 1985, the facility owner was
    found guilty on 17 counts of hazardous
    waste handling violations and other criminal
    charges.

    FDEP completed a multiphased Remedial
    Investigation (Rl) in May 1986.
 •   In 1988, FDEP and the City Industries
    steering committee entered into an
    agreement to develop viable cleanup
    options. The Feasibility Study (FS) was
    conducted by the Potentially Responsible
    Parties (PRPs) under a consent agreement
    between the PRPs and FDEP and was
    completed in December 1989.

 •   In March 1989, the site was listed on the
    National Priorities List (NPL), and EPA
    assumed oversight responsibility from
    FDEP. A Record of Decision (ROD) for the
    site was signed on March 29, 1990.

 •   In 1991, EPA negotiated a consent decree
    with the PRPs to fund the necessary
    activities to clean up the site.

 Regulatory Context:
 •   The ROD for the site was signed in 1990.

 •   An Explanation of Significant Differences
    (ESD) was signed in  February 1994 to
    revise the selected remedy and to identify
    two new contaminants. The ROD called for
    secondary treatment of effluent to meet
    POTW pretreatment standards; however,
    the POTW refused to accept the discharge.
    The ESD revised the remedy to include air
    stripping with no secondary treatment and
    discharge to surface water under an NPDES
    permit.

            U.S. Environmental Protection Agency
     Office of Solid Waste and Emergency Response
	    Technology Innovation Office
                                            60
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                                                                  City Industries Superfund Site
                              SITE^ INFORMATION (CoNT.)
Backaround (Cont.)
•  Site activities are conducted under provisions
   of the Comprehensive Environmental
   Response, Compensation, and Liability Act of
   1980 (CERCLA), as amended by the
   Superfund Amendments and Reauthorization
   Act of 1986 (SARA) §121, and the National
   Contingency Plan (NCR), 40 CFR 300.

Site Loaistics/Contacts
Groundwater Remedy Selection: The selected
groundwater remedy for the site is pumping and
treating the contaminated groundwater through air
stripping with discharge to surface water, as
specified in the ROD and modified in the ESD.
Site Lead: PRP

Oversight:  EPA

Remedial Project Manager:
Pam Scully*
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 562-8898

State Contact:
Don Harris
Florida Department of Environmental Protection
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, FL 32301
(904)488-0190

* Indicates primary contacts
Treatment System Vendor:
Jerry Peters
PEER Consultants P.C. (Design)
12300 Twinbrook Parkway, Suite 410
Rockville, MD 20852
(301)816-0700

Stuart Bills*
ERM-EnviroClean, Inc. (Construction &
Operation/Maintenance)
250 Phillips Blvd. #280
Ewing, NJ 08618
(609) 895-0050
                                 MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed Through the
Treatment System:  Groundwater

Contaminant Characterization n.2.3.101
Primary Contaminant Groups: Halogenated
and nonhalogenated volatile organic compounds
(VOCs).

•   The initial 14 contaminants of concern at the
    site were acetone, benzene,
    1,1-dichloroethane (1,1-DCA),
 -• 1,1rdichloroethylene(1,1-DCE),
    irans-1,2-dichloroethylene (fra/?s-1,2-DCE),
    ethylbenzene, methylene chloride, methyl
    ethyl ketone (MEK), methyl isobutyl ketone
    (MIBK), tetrachloroethylene (PCE), toluene,
    1,1,1-trichloroethane (1,1,1-TCA),
    trichloroethylene (TCE), and total phthalates.
    During construction of the treatment system in
    1994, two additional contaminants of concern
    were identified and added to the list in the
    ESD: c/s-1,2-DCE and vinyl chloride.
                                                             U.S. Environmental Protection Agency
                                                      Office of Solid Waste and Emergency Response
                                                     	Technology Innovation Office
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                                                                     City Industries Superfund Site
                              MATRIX DESCRIPTION (CONT.)
Contaminant Characterization fCont.l
    The maximum concentrations of
    contaminants detected during a 1988 FS
    sampling event were acetone (146,000
    ug/L), benzene (100 ug/L), 1,1-DCA (500
    ug/L), 1,1-DCE (6,000 ug/L), methylene
    chloride (165,000 ug/L), MEK (20,000 ug/L),
    MIBK (78,000 ug/L), toluene (9,000 ug/L),
    TCE (27,000 ug/L), 1,2-DCE (24,000 |jg/L),
    1,1,1-TCA (430 ug/L), ethylbenzene (2,100
    ug/L), and PCE (380 ug/L).  The maximum
    concentrations of vinyl chloride and c/s-1,2-
    DCE detected during 1994 were 2,400 ug/L
    and 38,000 ug/L, respectively.

    Based on 1986 Rl data, site engineers
    estimated the initial plume covered
    approximately eight acres extending from
    the City Industries site toward the drainage
    canal east of the  site. Based on an area of
    eight acres, a plume thickness of
    approximately 50 feet, and a porosity of 0.3,
    the initial plume volume was estimated for
    this report to be approximately 39 million
    gallons.
Matrix Characteristics Affecting Treatment Costs or Performance
                                             Contamination has been detected in the
                                             upper aquifer (the Surficial Aquifer). Figures
                                             1 and 2 illustrate plume distribution in the
                                             Surficial Aquifer in August 1994.  Figure 1
                                             depicts concentration contours detected in
                                             intermediate zone wells; Figure 2 depicts
                                             concentration contours detected  in deep
                                             zone wells. Intermediate and deep
                                             monitoring wells are screened in  the top 40
                                             feet and lower 20 to 30 feet of the Surficial
                                             Aquifer, respectively.

                                             Figures 1 and 2 reveal that the majority of
                                             the contamination is in the top 40 feet of the
                                             Surficial Aquifer.  The plume in the top 40
                                             feet (Figure 1) is more concentrated than the
                                             plume in the lower 20 to 30 feet (Figure 2).
                                             The plume has migrated east of City
                                             Industries, concurrent with groundwater flow
                                             direction.
Hydrogeology:  [4]

Two distinct hydrogeologic units have been identified beneath this site.

  Unit 1    Surficial Aquifer

  Unit 2
Floridan Aquifer
Unconfined aquifer of fine to medium-grained quartz sand with
limestone, gravel, chert, and coarse-grained sand.
Interlayered clayey gravel, clayey sand, clay, and limestone.
The hydrogeology at the site consists of two units separated by a 140-foot thick aquitard.  Groundwater
flows in an easterly direction across the site through the 60- to 70-foot thick Surficial Aquifer.  This aquifer
is not used as a potable source in the vicinity of the site. Groundwater in the Floridan Aquifer has not
been characterized because it is not contaminated at the site; however, the City of Winter Park draws its
water from a well supply field in the Floridan Aquifer 1,900 feet west of the site.  The Surficial and Floridan
Aquifers are not hydraulically connected.  Tables 1 and 2 present technical aquifer information and well
data, respectively.

                               Table 1. Technical Aquifer Information
Unit Name
Surficial Aquifer
Floridan Aquifer
Thickness
(ft)
60-70
100
Conductivity
(ft/day)
6.3936
NA
Average Velocity
(ft/day)
0.064
NA
Flow
Direction
East
NA
NA - indicates not characterized
Source: [4]
      EPA
                                                      U.S. Environmental Protection Agency
                                              Office of Solid Waste and Emergency Response
                                                             Technology Innovation Office
                                               62
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                                                         City industries Superfund Site
                    ; MATRIX DESCRIPTION (GONT.)
      Figure 1. Total VOCs in Intermediate Zone Monitoring Wells, August 1994 [2]
EPA
       U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
              Technology Innovation Office
                                                                    TlO3.WP6\0319-04.stf
                                      63

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                                                             City Industries Superfund Site
                        MATRIX DESCRIPTION (CONT.)

•g
0
UK.
I s
"S V
!*
si
£?
^s.

.

~o _
                                                                         §r
                                                                          °
                                                             1
                                                             3
          F/gure 2. Total VOCs in Deep Zone Monitoring Wells, August 1994 [2]
EPA
        U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
	Technology Innovation Office
                                      64
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                                                                    City Industries Superfund Sfte
                          TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology
Pump and treat (P&T) with air stripping

System Description and Operation
                                                   Sunnlemental Treatment Technoloqv
Equalization/neutralization prior to air stripping
                                  Table 2. Extraction Well Data

Well Name
RW-1 through RW-8
RW-9 through RW-1 3

Unit Name
Surficial Aquifer
Surficial Aquifer

Depth (ft)
25-70
25-70
Design
Yield (gpm)
10
5
Source: [2]
System Description [2]
•   The groundwater extraction system consists
    of 13 recovery wells (RW-1 through RW-13)
    located on five adjacent properties east of
    the original site, as listed in Table 2. The
    recovery wells are divided into two groups,
    which are installed across the width of the
    initial contaminant plume.  The well
    placement is designed to intercept the plume
    and to achieve hydraulic containment of the
    plume as it flows east. The first group
    consists of eight recovery wells (RW-1
    through RW-8) which are located just
    downgradient from the site, perpendicular to
    the plume centerline, where most of the
    contamination has been found.  The second
    group consists of the remaining five recovery
    wells (RW-9 through RW-13). These wells
    are located further downgradient,
    perpendicular to the centerline and are
    estimated to be at the leading edge of the
    contaminant plume.

 •  The treatment system constructed in 1994
    consists of an equalization/neutralization
    tank followed by an air stripping tower. The
    1,500-gallon equalization  tank serves to
    settle aggregates and equalize flow to the
    tower. The air stripper has been designed
    for a 97% treatment efficiency.

 •  Treated water from the air stripper is
    transported via a gravity pipeline
    approximately 2,250 feet east to a county-
    maintained drainage canal (Crane Strand)
    where it is discharged in accordance with
    NPDES permit limits.
       EPA
•   A network of 41 monitoring wells and 13
    recovery wells is used to measure quarterly
    changes in groundwater levels and
    concentrations. Twenty additional
    monitoring wells are sampled on an annual
    basis. The monitoring wells are screened at
    various depths and some are in a series of
    clusters of shallow, intermediate, and/or
    deep wells.

System Operation [2,10]
•   Quantity of groundwater pumped from the
    aquifer in gallons:

      Year         Volume Pumped (gal)
     5/94-4/95              48,430,000
     5/95-4/96              47,750,000
     5/96-5/97              51,524,849
       6/97               3,990,000

    System operations began on May 19, 1994.
    As of June 1997, the P&T system has been
    operational approximately 90% of the time.

 •   A primary operational concern is biological
    growth on pumps  in the wells, in the
    equalization tank,  and  in the air stripping
    tower. Biological growth degrades system
    performance  below design  and permit
    requirements. In June 1996, the system
    was shut down for 24 hours and the pumps
    and treatment system  were shocked with a
    high dose of chlorine, which alleviated a
    biological growth problem.


             U.S. Environmental Protection Agency
      Office of Solid Waste and Emergency Response
                     Technology Innovation Office
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                                                                  City Industries Superfund Site
                     TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation fCont.)
   The air stripping tower packing continues to
   require cleaning approximately every six
   months.  The air stripping media has been
   removed and washed with a weak acid
   solution four times to remove scaling:
   August 1994, March 1995, November 1995,
   and April 1996. Discharges (liquid and solid)
   from the cleaning operations are tested and
   disposed of according to applicable
   regulations.

   The extraction system has pumped an
   average of 105 gpm from May 1994 through
   June 1997, which meets the design
   requirement for plume containment.

   EPA Region 4 completed an optimization
   study in December 1996 to maximize plume
   capture during pumping. The study
   examined what pumping rates from all the
   existing wells were best to maximize zones
   of influence and to minimize stagnation
   zones.  Pumping options were limited in that
   the total treatment capacity remained at 115
   gpm; however, the study found that zones of
   influence would increase by decreasing
 pumping from wells located along the
 upgradient edge of the plume and increasing
 pumping from those at the leading edge of
 the plume. The following recommended
 changes were incorporated in June 1997:
 increased pumping in three wells at the
 leading edge of the plume from 5 to 10 gpm
 and decreased pumping in three other wells
 at the upgradient edge from 10 to  5 gpm.

 Quarterly sampling data indicates  that
 several recovery wells are showing no
 contamination now. Wells with increased
 rates are drawing in more contaminants, but
 data are being analyzed to determine if
 stagnant zones are moving.

 In March 1998, four wells were shut down
 and the rates in the other wells were
 increased to try to increase recovery.
 Sampling was reduced to semi-annual.
 When results are available the  EPA will
 determine if the plume is still contained or if
 wells need to be restarted.
    EPA
         U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
	Technology Innovation Office
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                                                                  City Industries SuperfuncfSrte
                     TREATMENT SYSTEM jDESCRiPTiON (CoNT.)
Oneratina Parameters Affectina Treatment Cost or Performance
The major operating parameter affecting cost or performance for this technology is the extraction rate.
Table 3 presents the design value for this and other performance parameters.

                              Table 3. Performance Parameters

Design Pump Rate
Performance Standards
(Effluent)














Remedial Goals
(Florida MCLs)















115 gpm (actual average =
Acetone
Benzene
1 ,1 ,-Dichloroethane
1,1-Dichloroethene
c-1 ,2-Dichloroethene
frans-1 ,2-Dichloroethene
Ethyl Benzene
Methylene Chloride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Tetrachloroethylene
Toluene
1 ,1 ,1-Trichloroethane
Trichloroethylene
Vinyl Chloride
Xylenes, total
Acetone I
Benzene /
1,1,-Dichloroethane
1 ,1-DichIoroethene
c-1 ,2-Dichloroethene
t-1 ,2-Dichloroethene
Ethyl Benzene
Methylene Chloride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Total Phthalates
Vinyl Chloride

105 gpm*)
88,000 pg/L
53 ug/L
11 60 pg/L
303 |jg/L
1160|jg/L
11 60 pg/L
453 |jg/L
11 00 pg/L
56,400 pg/L
42.800 pg/L
84 pg/L
175 pg/L
530 pg/L
4,500 |jg/L
525 Mg/L
260 pg/L
700 pg/L
1pg/L
5 pg/L
7 pg/L
70 pg/L
70 pg/L
700 pg/L
5 pg/L
200 pg/L
350 pg/L
3 pg/L
2,000 pg/L
200 pg/L
3 pg/L
3 pg/L
1 pg/L
             Source: [1,2]
             *The average of 105 gpm was provided in the Interim Long-Term Response Action Report.
                                                              U.S. Environmental Protection Agency
                                                      Office of Solid Waste and Emergency Response
                                                     	Technology Innovation Office
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                                                                 City Industries Superfund Site
                     TREATMENT SYSTEM DESCRIPTION (CONT.)
 Timeline
 Table 4 presents a timeline for this remedial project.
Start Date
3/90
1992
2/94
5/94
5/94
End Date
—
—
—
_
ongoing
. Activity f~ •* '" ' > '"•*
ROD issued
Final remedial design completed
ESD issued
Construction of the treatment system and extraction wells completed
System operation begun
                         TREATMENT SYSTEM PERFORMANCE
 Cleanup Goals/Standards M^
 Cleanup goals are to remediate groundwater to
 levels set by the Florida Primary Drinking Water
 Standards (which for this site are the same as
 Maximum Containment Levels (MCLs) set by the
 Federal Primary Drinking Water Standards).
 These standards are listed in Table 3 and are
 applied throughout the aquifer.

 Treatment Performance Goals n. 21
    The primary performance goal of the P&T
    system is to achieve hydraulic containment
    of the plume.
Performance Data Assessment [2.5.6.9.10]
The performance goal of the treatment
system is to reduce effluent contaminant
concentrations to meet NPDES permit
requirements listed in Table 3.
For the purposes of this report, total VOCs
consist of acetone, benzene, 1,1-DCA, 1,1-DCE,
cis-1,2-DCE, trans-1,2-DCE, ethylbenzene
methylene chloride, MEK, MIBK, PCE, toluene,
1,1,1-TCA, TCE, total phthalates, and vinyl
chloride.

•   Figure 3 illustrates the trend of average total
   VOC concentrations from May 1994 through
   May 1997. Total concentrations of
   contaminants have been reduced 86%
   during this period, from 3,121 ug/L to 444
   ug/L. However, concentrations of all VOCs
   remain above cleanup goals.
     EPA
Although concentrations have been reduced
significantly, three of the VOCs show
persistently elevated concentrations:
acetone, 1,1-DCE, and MIBK. Nonetheless,
maximum levels of acetone have decreased
84%, from 146,000 ug/L to 23,000 ug/L.
Maximum levels of 1,1-DCE have declined
52% from 6,000 ug/L to 2,900 ug/L.
Maximum levels of MIBK have declined 93%
from 78,000 ug/L to 5,000 ug/L
        U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
	Technology Innovation Office
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                                                                  City Industries Superfund Site
                    TREATMENT] SYSTEM PERFORMANCE (CONT.)
Performance Data Assessment (continued) F2, 5. 6. 9,101
    Figures 4 and 5 illustrate contours of total
    VOCs detected during August 1996
    sampling events in intermediate and deep
    monitoring wells, respectively. Compared to
    the plume of total VOCs detected in August
    1994 (illustrated in Figures 1 and 2), the
    volume of total VOCs in the plume detected
    in August 1996 has decreased. The 55,000
    ug/L contour in the intermediate wells has
    decreased in size from 1994 to 1996. In
    addition, the level of maximum VOCs has
    decreased in the deep wells from 40,000
    ug/L in August 1994 to 8,000 ug/L in August
    1996.

    No contaminants have been detected in
    downgradient monitoring wells since the
    beginning of remedial operations, and the
    plume has been contained. In addition,
    monitoring done since 1997 has shown that
    the plume has reduced in size. No plume
    map was available to demonstrate the
    change in size.
        ,500
Figure 6 illustrates total VOC concentrations
in wells MW-13D, MW-43I, and MW-22I,
where contamination is concentrated.
Concentrations have decreased
exponentially since operations began.  In
February 1996, an increase was seen in all
three wells; however, concentrations have
continued to decrease since 1996.

Effluent standards for the treatment system
have been met during system operation.

From  June 1994 through May 1997, the P&T
system removed approximately  2,700
pounds of contaminant mass from the
groundwater.  Figure 7 shows mass flux rate
and total contaminant removal from June
1994 through May 1997. The mass flux rate
spiked in April 1996, but the spike is
attributed to a high concentration of acetone
detected during that sampling event.
   ~  1,500
   0)
   o
          Mar-94      Sep-94      Apr-95      Oct-95      May-96     Dec-96     Jun-97
                                   .Average Concentration of Total VOCs
   Figure 3. Average of Total VOCs in all Monitoring Wells from May 1994 through May 1997 [2,5,6,9]
                                                              U.S. Environmental Protection Agency
                                                      Office of Solid Waste and Emergency Response
                                                                     Technology Innovation Office
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                                                          City Industries Superfund Site
              TREATMENT SYSTEM PERFORMANCE (CONT.)
                                                                       I?
                                                                       5 a

                                                                       1 o
                                                                       .o



                                                                       'S~;
                                                                       c t-

                                                                       II
                                                                      ^  S
                                                                      i
                                                                     * °!
      Figure 4.  Total VOCs in Intermediate Zone Monitoring Wells, August 1996 [2]
^
FP A
trM
       U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
              Technology Innovation Office
                                     70
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                                                City Industries Superfund Site
   TREAf MEN!) SYSTEM PERFORMANCE (CONT.)
                                                            SJ "8
                                                            a: £
                                                          * o
                                                     t  t
F/gure 5. Total VOCs /n Deep Zone Monitoring Wells, August 1996 [2]
                                            U.S. Environmental Protection Agency

                                    Office of Solid Waste and Emergency Response

                                                  Technology Innovation Office
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                                                              City Industries Superfund Site
                 TREATMENT SYSTEM PERFORMANCE (CONT.)
    1,000,000
I
¥
 0>
       10,000
          100
           Mar-94    Sep-94    Apr-95     Oct-95     May-96    Dec-96     Jun-97
                                             Date
                               .MW-43I
                                         .MW -22!
.MW - 13D
 Figure 6.  Total VOCs Concentrations in Highly Contaminated Wells, May 1994 through May 1997
                                      [2,5,6,9]
I
jo
8
i
   6.00
   5.00
4.00
   3.00
2.00
   1.00 ,
   0.00
                                    .„.,,',  „      ^y/
                                            •«     *^ ^~
                                    I(*W *M^HjMiM"rftff«t' l*4f*8t * ^W**>. S'li^K >
                                ^Ji^,^^^^ ^w^wtoLMMTOKla. S / 08^ "^i <*E
                                                                '» rf.
                                                                           3,000
     May-94     Nov-94     May-95     Nov-95      May-96     Nov-96     May-97
                                       Date
                      .Mass Flux (Ibs/day) _H_Cum.Mass Rem.(lbs)
    Figure 7. Mass Flux and Cumulative Mass Removal, June 1994 through May 1997 [2,6,9]


   EPA
                                                     U.S. Environmental Protection Agency
                                              Office of Solid Waste and Emergency Response
                                              	Technology Innovation Office
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                                                                  City Industries Superfund Site
                    TREATMENT|SYSTEM PERFORMANCE (CONT.)
Performance Data Completeness
•   Monthly data for contaminant concentrations
    in monitoring and recovery wells are
    available for June 1994 through May 1996 in
    the Interim Long-Term Remedial Action
    Report. Quarterly data for contaminant
    concentrations in monitoring and recovery
    wells are available in monthly reports from
    the site operators for September 1996
    through September 1997.  At the time of
    preparation of this report, the site contact
    (the EPA RPM) had not received reports
    past May 1997. For the analyses in this
    report, including the average concentrations
    of total VOCs shown in Figures 3 and 6,
    quarterly data were used from June 1994
    through May 1996 and annual data were
    used from May 1996 through May 1997.

Performance Data Qualitv              	
For Figure 3 analyses, the average
concentration of total VOCs was calculated
using a geometric mean of contaminant
concentrations in wells within the initial
contaminant plume. A geometric mean was
used to show the trend of contaminant levels
across the site. Where contaminant levels
were below detection limits, half of the
detection limit was used.

Monthly data regarding contaminant removal
through the treatment system are available
for June 1994 through May 1997  in the
Monthly Operations and Maintenance
Reports. For the mass removal analyses in
Figure 7 of this report, quarterly data were
used from June 1994 through May 1997.
The QA/QC program used throughout the remedial action met the EPA and the State of Florida
requirements. All monitoring was performed using EPA-approved methods, and the site contact did not
note any exceptions to the QA/QC protocols.
                              TREATMENT SYSTEM COST
Procurement Process
EPA contracted with Peer Consultants, P.C. to design the groundwater extraction and treatment system.
EPA awarded the construction, startup and O&M (2-year base period) contract to ERM-EnviroClean, Inc.
FDEP was the lead agency until 1989, at which time EPA took over the lead and maintained responsibility
for operation and maintenance of the treatment system.

Cost Analysis                                                                             _

All costs incurred for remedial activities at this site were borne by Potentially Responsible Parties (PRPs).
      EPA
         U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
     	Technology Innovation Office
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                                                                    City Industries Superfund Site
                          TREATMENT SYSTEM COST (CONT.)
Capital Costs 141
 Remedial Construction

 Mobilization and Preparatory
 Work
 Site Work

 Well Installation, Instrumentation,
 and Piping

 Install Well Manholes

 Air Stripper

 Effluent Pipeline

 Demobilization
 Total Construction
  $174,700


   $68,100

  $559,140


   $13,700

  $202,060

   $27,100

   $50,000

$1,094,800
Operating and Maintenance Costs T4.5]
 5/94-4/95                        $186,250

 5/95-4/96                         $186,250

 5/96-5/97                         $133,295

 Total O&M                        $505,795


Other Costs F41
 Remedial Design

 Remedial Design                   $190,234

 Preparatory Work                    $90,494

 Tank Removal                      $74,377

 Field Data Development              $147,922

 Treatability Studies                   $38,979

 Closeout                            $5,619

 Remedial Oversight                  $34,913

 Total Design                      $582,538

 EPA Personnel                     $99,675
Cost Data Quality
Capital and operations and maintenance cost data were supplied in a 1994 Cost Study of the site,
originated from the treatment vendor, and were updated by the RPM.
                       OBSERVATIONS AND LESSONS LEARNED
    Approximate costs for the P&T system at
    this site were $1,674,800, consisting of
    $1,094,800 in capital costs and $580,000 in
    cumulative operating and maintenance costs
    through May 1997, which corresponds to
    $590 per pound of contaminants removed
    and $10.60 per 1,000 gallons of groundwater
    treated.

    Total concentrations of VOCs have declined
    86% at this site, but remain above cleanup
    goals.

    The mass flux rate illustrated in Figure 6 is
    more constant over time than at many P&T
    sites. The hydrogeology at the site is
    relatively simple and hydraulic conductivity is
    relatively high compared to typical hydraulic
                     conductivities [7]. In addition, no pure
                     phase, or nonaqueous phase liquid (NAPL),
                     has been detected at the site [5J.

                     Given the matrix of contaminants at this site,
                     there is potential for cometabolic
                     degradation. Cometabolic degradation of
                     TCE, DCE, and vinyl chloride is supported in
                     the presence of aromatic compounds, such
                     as toluene [8].

                     Based on conversations with the RPM for
                     the site, contaminant levels in late 1997 and
                     1998 at the site are lower than the May 1997
                     monitoring data.
                                                              U.S. Environmental Protection Agency
                                                       Office of Solid Waste and Emergency Response
                                                      	             Technology Innovation Office
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                                                                  City Industries Superfuncf Site
                  OBSERVATIONSJAND LESS'ONS LEARNED (CONT.)
   The site contractor did not anticipate
   biofouling in the air stripper in the design.
   According to the contractor, design
   specifications assumed a different
   temperature and alkalinity for the
   groundwater from actual conditions.
   Chlorine treatment was found to alleviate
   biofouling and the system has been
   operational 90% of the time.
    The RPM also indicated that the P&T system
    has lowered contaminant concentrations in
    extracted water to levels below effluent
    NPDES requirements.  Thus, in the near
    future, the extracted water may be
    discharged directly to the POTW and
    treatment will not be necessary.
                                      REFERENCES
1.   Record of Decision. City Industries
    Superfund Site. U.S. EPA Region 4, March
    9, 1990.

2.   Interim Long-Term Response Action Report.
    City Industries Superfund Site. U.S. EPA
    Region 4, Undated.

3.   Explanation of Significant Differences. U.S.
    EPA Region 4, February 1994.

4.   Cost and Performance Profile. City
    Industries Superfund Site. U.S. EPA
    Hazardous Site Control Division Remedial
    Operations and Guidance Branch,
    unpublished.

5.   Correspondence with Pam Scully, EPA
    RPM.  April, May, and December 1997,
    February, March, and April 1998.
6.   Monthly Operation and Maintenance
    Reports, June 1996-May 1997. ERM-
    EnviroClean, Inc.

7.   Groundwater Regions of the United States.
    Heath, Ralph. U.S. Geological Survey
    Water Supply Paper 2242, 1984.

8.   Biofilm Reactor for Chlorinated Gas
    Treatment. Remediation Technologies, Inc.
    Internet publication, http://clu-in.com/site/
    complete/remedial htm, May 21,1998.

9.   Twelfth Quarterly Groundwater Sampling
    Results; City Industries Superfund
    Remediation Project, ERM EnviroClean,
    Inc., September 19, 1997.

10.  Comments on draft report provided by Pam
    Scully, Region 4 Remedial Project  Manager,
    July 1998.
Analysis Preparation
This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
Emergency Response, Technology Innovation Office. Assistance was provided by Tetra Tech EM Inc.
and Eastern Research Group, Inc. under EPA Contract No. 68-W4-0004.
      EPA
            U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
    	Technology Innovation Office
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This Page Intentionally Left Blank
               76

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   Pump and Treat of Contaminated Groundwater at
the King of Prussia Technical Corporation Superfund Site
           Winslow Township, New Jersey
                        77

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                   Pump and Treat of Contaminated Groundwater at
              the King of Prussia Technical Corporation Superfund Site
                              Winslow Township, New Jersey
 Site Name:
 King of Prussia Technical
 Corporation Superfund Site
 Location:
 Winslow Township, New Jersey
Contaminants:
Chlorinated solvents, BTEX,
Heavy metals
- Contaminants of concern include
l,l-DCA,trans-l,2-DCE, 1,1,1-
TCA, TCE, PCA, PCE, benzene,
toluene, ethylbenzene, beryllium,
chromium, copper, and nickel
- Maximum initial concentrations
included PCE (2,500 ug/L), trans-
l,2-DCE(12ug/L), 1,1,1-TCA
(2,200 ug/L), and chromium (1,040
Period of Operation:
Status: Ongoing
Report covers: April 1995 through
December 1997
Cleanup Type:
Full-scale cleanup (interim results)
Vendor:
Treatment System Vendor: Andco
Environmental Processes, Inc.
Operations: Geraghty and Miller,
Inc.
Additional Contact:
Frank Opet
PRP Coordinator
Johnson Matthey
200 INolte Drive
West Deptford, NJ 08066
(609) 384-7222
Technology:
Pump and Treat
- Groundwater is extracted using
11 wells at an average total
pumping rate of 175 gpm in the
upper aquifer and 25 gpm in the
lower aquifer
- Extracted groundwater is treated
with an electrochemical system for
removal of heavy metals, and air
stripping and granular activated
carbon for removal of organics
- Treated groundwater is reinjected
through infiltration trenches and
galleries
Cleanup Authority:
CERCLA Remedial
- ROD Date: 9/9/90
EPA Point of Contact:
Jon Gorin, RPM
U.S. EPA Region 2
290 Broadway, 19th Floor
New York, NY 10007-1866
(212) 637-4361
Waste Source:
Discharge of waste to surface
impoundment/lagoon; unauthorized
dumping
Purpose/Significance of
Application:
Treatment system consists of a
treatment train designed for
removal of metals and organics.
Type/Quantity of Media Treated:
Groundwater
-151.5 million gallons treated as of December 1997
- Groundwater is found at 15-35 ft bgs (shallow aquifer) and from 50-250
ft bgs (deep aquifer)
- Extraction wells are located in two aquifers
- Hydraulic conductivity ranges from 55 to 100 ft/day
Regulatory Requirements/Cleanup Goals:
- The remedial goal for the site is to reduce contaminant concentrations to below maximum contaminant levels
  (MCLs) set by the New Jersey Safe Drinking Water Act and the primary drinking water standards. Cleanup
  goals were established for beryllium (4 ug/L), cadmium (10 ug/L), chromium (50 ug/L), copper (1,000 ug/L),
  mercury (2 ug/L), nickel (210 ug/L), zinc (5,000 ug/L),  1,1-DCA (2 ug/L), trans-l,2-DCE (10 ug/L), 1,1,1-
  TCA (26 ug/L), TCE (1 ug/L), PCA (1.4 ug/L), PCE (1 ug/L), benzene (1  ug/L), toluene (2,000 ug/L), and
  ethylbenzene (50 ug/L).
- The extraction system was designed to create an inward hydraulic gradient to contain the plume.
                                               78

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                  Pump and Treat of Contaminated Groundwater at
              the King of Prussia Technical Corporation Superfund Site
                      Winslow Township, New Jersey (continued)
Results:
- Cleanup goals for metals and VOCs have been met in the deep aquifer and for all but some wells in the
  shallow aquifer (two for VOCs and four for metals). Groundwater monitoring data indicate that the plume
  appears to have been contained.
- From March 1995 through December 1997, the treatment system removed 1,510 pounds of organics and 3,910
  pounds of metals, for a total mass removal of 5,420 pounds.
Cost:
- Actual costs for pump and treat were approximately $2,816,000 ($2,031,000 in capital and $785,000 in
  O&M), which correspond to $19 per 1,000 gallons of groundwater extracted and $520 per pound of
  contaminant removed.
Description:
The King of Prussia Technical Corporation operated as a waste disposal and recycling facility from January 1971
until early 1974, with six lagoons used to process industrial waste. EPA estimates that the company processed at
least 15 million gallons of acid and alkaline wastes at this site. Drums of VOCs were buried at the site. In
addition, trash and hazardous waste are suspected to have been dumped at the site illegally between 1976 and
1988 after the company stopped operations.  Soil and groundwater contamination were detected by the state in
1976, and the site was added to the NPL in September 1983.  A ROD was issued for this site hi September
1990.

Groundwater is extracted at this site using six wells in the shallow aquifer and five wells in the deep aquifer.
Extracted groundwater is treated with an electrochemical system for removal of heavy metals, and ah- stripping
and granular activated carbon for removal of organics.  Treated groundwater is reinjected through infiltration
trenches and galleries. Cleanup goals for metals and VOCs have been met in the deep aquifer and for all but
some wells in the shallow aquifer.  As of December 1997, groundwater elevations have achieved steady-state
under the current pumping scheme. The groundwater flow and contaminant transport will be reevaluated using
models to evaluate remediation enhancements, including adding or removing  extraction wells.  In addition, the
site operator is considering pumping changes.          	
                                                79

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                                               King of Prussia Technical Corporation Superfund Site
                                    SITE INFORMATION
Identifying Information:
King of Prussia Technical Corporation
Winslow Township, New Jersey

CERCLIS # NJD980505341

ROD Date: September 9,1990


Background n.2.31	
Treatment Application:
Type of Action:  Remedial

Period of operation: April 1995 - Ongoing
Data collected through December 31, 1997

Quantity of groundwater treated during
application: 151.5 million gallons
Historical Activity that Generated
Contamination at the Site: Waste disposal
and recycling

Corresponding SIC Code:  4953, Sanitary
Services - Refuse Systems

Waste Management Practice That
Contributed to Contamination: Discharge of
waste to surface impoundment/lagoon;
unauthorized dumping

Location: Winslow Township, New Jersey

Facility Operations:
•  The 10-acre King of Prussia (KOP) site is
   located in a light industrial area and is
   bordered to the northeast, northwest, and
   southwest by a wooded state park and to the
   southeast by Piney Hollow Road.

•  The KOP Technical Corporation operated
   as a waste disposal and recycling facility
   from January 1971  until early 1974.

•  Six lagoons were used to process industrial
   waste. An on-site swale directed site runoff
   toward the Great Egg Harbor River, located
   approximately 1,000 feet southwest of the
   site.

•  The swale has been designated a wetlands,
   and the Great Egg  Harbor is used for
   recreational purposes.

•  EPA estimates that, while in operation, the
   KOP Technical Corporation processed at
   least 15 million gallons of acid and alkaline
   waste at this site. Drums of VOCs were
   buried at the site. Also, trash and
   hazardous waste are suspected to have
      EPA
    been dumped at the site illegally between
    1976 and 1988 after KOP ceased
    operations.

•   Soil and groundwater contamination were
    detected by the State of New Jersey in
    1976. Subsequently, the KOP site was
    added to the National Priorities List (NPL) in
    September 1983.  As part of initial removal
    actions conducted from 1985-1989, EPA
    excavated plastic containers and metal
    drums.

•   Elevated levels of metals were identified in
    soils, lagoon sludges, swale sediment, and
    groundwater at the site. Elevated levels of
    volatile organic compounds (VOCs) were
    detected in soils in the drum disposal  area
    and in the groundwater.

•   Soil and sediment were remediated on site
    by soil washing in  1993. Tankers and
    buried drums were removed and disposed
    of off site.

•   A cost and performance report entitled Soil
    Washing at the King of Prussia Technical
    Corporation Superfund Site, Winslow
    Township, New Jersey was previously
    prepared about the soil washing application
    at this site.

Regulatory Context:
•   A Record of Decision (ROD) was issued for
    the site in September 1990 and included
    remedial activities for operable unit 1  (OU1)
    for soil and sediment contaminated with
    metals, OU2 for removal of contaminated
    soil in the area of the buried drums, and
    OU3 for groundwater.
            U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
   	Technology Innovation Office
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                                             King of Prussia Technical Corporation Superfund Site
                              SITE| INFORMATION (CONT.)
   Site activities are conducted under provi-
   sions of the Comprehensive Environmental
   Response, Compensation, and Liability Act
   of 1980 (CERCLA), as amended by the
   Superfund Amendments and
   Reauthorization Act of 1986 (SARA), §121,
   and the National Contingency Plan (NCP),
   40 CFR 300.
Site Logistics/Contacts
Groundwater Remedy Selection: The
selected remedy for OU4, groundwater
remediation, was extraction of groundwater
followed by treatment for metals and VOCs to
capture the contaminated groundwater and
prevent discharge of contaminants to the Great
Egg Harbor River.  The ROD also designated
on-site groundwater treatment to remove
contaminants from the collected groundwater,
followed by a system to reinject treated
groundwater into the aquifer.
Site Lead: PRP

Oversight: EPA

PRP Contact:
Frank Opet*
PRP Coordinator
Johnson Matthey
2001 Nolte Drive
West Deptford, NJ 08066
(609) 384-7222

indicates primary contacts
Remedial Project Manager:
Jon Gorin*
U.S. EPA Region 2
290 Broadway, 19th Floor
New York, NY 10007-1866
(212) 637-4361

Treatment System Vendor:
Operations: Geraghty and Miller, Inc.
Treatment System Vendor: Andco
Environmental Processes, Inc.
                                  MATRIX DESCRIPTION
 Matrix Identification
Type of Matrix Processed Through the
Treatment System: Groundwater

Contaminant Characterization r-l.2.41
 Primary Contaminant Groups:  Metals, VOCs

 •   The contaminants of greatest concern at
    this site are metals and VOCs.  The metals
    of concern are beryllium, chromium, copper,
    and nickel.  The VOCs of concern are 1,1-
    dichloroethane (1,1-DCA),  frans-1,2-
    dichloroethylene (trans-1,2-DCE), 1,1,1-
    trichloroethane (1,1,1-TCA),
    trichloroethylene (TCE), 1,1,2,2-
    tetrachloroethane (1,1,2,2-PCA),
    tetrachloroethylene (PCE), benzene,
    toluene, and ethylbenzene.
    Cleanup standards are set for total
    chromium.  Likewise, laboratory analyses
    test for total chromium.  For these reasons,
    chromium levels tested and regulated at the
    KOP site are for total chromium.

    Figure 1 illustrates the site layout and the
    contaminant plumes as delineated using
    1993 sampling data. Figure 1 is a
    compilation of drawings provided by the
    PRP coordinator. During the 1985-1989
    remedial investigation, the metals and VOC
    plumes were determined to be commingled
    but originating from different sources.
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                                             King of Prussia Technical Corporation Superfund Site
                          MATRIX DESCRIPTION (CONT.)
     _ APPROXIMATE EXTENT OF
        METALS PLUME ABOVE ARAR3.
        APPROXIMATE EXTENT OF
        VOCs PLUME ABOVE ARARS
     © MONITORING WELL

        RECOVERY WELL

     JMJ INFILTRATION TRENCH

     9 INFILTRATION GALLERY
        Figure 1.  Approximate Areal Extent of Metals and VOCs Plumes (1993) [3]
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                                               King of Prussia Technical Corporation Superfund Site
                             I MATRIX: DESCRIPTION (CONT.)
Contaminant Characterization fCortt.)
   The metals plume originated from wastes
   that were dumped throughout the site onto
   the soil in lagoons and in the former swale.
   Contamination in the metals pliime is
   evenly distributed, with hot spots around
   wells 5-S (center of the plume) land 29-S
   (northern portion of the plume)]

   The maximum initial metals concentrations
   detected by EPA during remedjal
   investigations from 1985-1989 Jin the
   shallow, or upper, aquifer were 100 ug/L
   (beryllium),  1,040 ug/L (chromium),  12,500
   ug/L (copper), and 4,670 ug/L (nickel). The
   metals contamination is 99% contained in
   the upper aquifer. Cadmium,  rjiercury, and
   zinc were detected in the shallow aquifer,
   but at concentrations below concern.

   The upper 10 to 15 feet of the deep aquifer
   is referred to as the intermediate aquifer.
   Copper and nickel were the only two
   compounds that were detected at
   concentrations of concern in the
    intermediate aquifer. The maximum initial
    concentrations of copper and nickel
    detected during the 1985-1989 remedial
    investigation in the intermediate aquifer
    were 3,070 ug/L and 899 ug/L,, respectively.
Chromium was the only metal detected at
levels of concern in the deep aquifer. The
maximum chromium concentration detected
during the 1985-1989 remedial investigation
was 77 ug/L.

The VOC plume originated at the
northeastern end of the site in the shallow
aquifer, in the former drums location. This
area is noted in Figure 1 as the location of
the infiltration trenches. Contamination in
the VOC plume is concentrated in the
northeastern part of the plume, with the
highest contamination in well 29-S.

The maximum initial VOC concentrations
detected during the 1985-1989 remedial
investigation in the shallow aquifer were
1,1-DCA at 64 ug/L; frans-1,2- DCE  at 12
ug/L; 1,1,1-TCA at 2,200 ug/L; TCE  at 940
ug/L; 1,1,2,2-PCA at 2,900 ug/L;  PCE at
2,500 |jg/L; benzene at 8 ug/L, toluene at
190 |jg/L and ethylbenzene at 80 ug/L [1].
However, PCE was detected at levels as
high as 20,000 |jg/L during an April 1995
sampling event.

TCE was the only VOC detected at levels of
concern in the deep aquifer. The maximum
initial concentration of TCE detected during
the 1985-1989 remedial investigations in the
deep aquifer was 3 ug/L
 Matrix Characteristics Affecting Treatment Costs or Performance
 Hydrogeology [1]:             '•

 The site is underlain by unconsoliojated Coastal Plain sediments of unconsolidated sands, gravels, and
 clays. Underlying the sediment formations is relatively low permeability metamorphic bedrock.

 Two hydraulic units were identified in the Remedial Investigation/Feasibility Study (RI/FS) at the KOP
 site. Both of these aquifers are part of the regional Kirkwood-Cohansey Aquifer system. The shallow
 aquifer begins at 15 feet and extetjids to approximately 35 feet below ground surface. A 10- to 20-foot
 semiconfining layer separates the shallow and deep aquifers and is composed predominately of
 discontinuous silt and clay zones. The deep aquifer extends downward from 50 feet to  approximately
 250 feet below ground surface. Tljie upper 10 to 15 feet of the deep aquifer is referred to as the
 intermediate aquifer.            \
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                                               King of Prussia Technical Corporation Superfund Site
                             MATRIX DESCRIPTION (CONT.)
 Matrix Characteristics Affecting Treatment Costs or Performance (Cont.)

 The groundwaterflow direction at the KOP site is southwest, towards the Great Egg Harbor River.
 Lateral groundwater flow in the shallow and deep aquifers is approximately 1 and 0.4 foot per day,
 respectively. The shallow aquifer discharges to the Great Egg Harbor River, while the deep aquifer may
 only discharge a minor flow component to the river. Contamination from metals and VOCs are primarily
 in the shallow aquifer.

 There are no residential wells in the vicinity of the site. Two wells, neither of which serve as potable
 water supplies, are located within a half-mile radius of the site. The nearest residential water wells are
 located approximately one mile northeast and upgradient of the site.

 Tables land 2 present technical aquifer information and well data, respectively.

                              Table 1. Technical Aquifer Information
Unit Name
Thickness
(ft)
Conductivity
ftt/dav)
Average Linear
Velocity
fft/dav)
Shallow 20 56-100 1.0
Deep* 200 55-62 0.4
*The upper 10-15 feet of the deep aquifer are referred to as the Intermediate zone In some reports.
Flow
Direction
Southeast
Southeast
source: [1]
                          TREATMENT SYSTEM DESCRIPTION
primary Treatment Technology

Pump and treat (P&T) with an electrochemical
system and granular activated carbon treatment

System Description and Operation [3.4.81
Supplemental Treatment Technology

None
Table 2. Technical Well Data
Well Name* Unit Name
R-1S Shallow
R-2S Shallow
R-3S Shallow
R-4S Shallow
R-5S Shallow
R-6S Shallow
R-7D Deep
R-8I Deep
R-9I Deep
R-10D Deep
R-1 1 1 Deep
Depth (ft)
34
34
28
26
42
26
95
51
50
92
57
* S denotes well screened In shallow aquifer, I denotes well screened In upper 10-15 feet of the deep aquifer (Intermediate), and
D denotes well screened In lower portion of the deep aquifer.
bource: [2J
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                                               King of Prussia Technical Corporation Superfund Site
                      TREATMENT :SYSTEM DESCRIPTION (CONT.)
System Description and Operation fConU
System Description
•   The extraction well system includes 11 wells
    throughout the plume, as listed in Table 2.

•   The shallow recovery wells are designed to
    pump a total of 175 gpm from the shallow
    aquifer.  The deep and intermediate wells
    are designed to pump a total of 25 gpm
    from the deep aquifer.  These pump rates
    were determined using the computer
    models MODFLOW and MT3D.

•   Two recovery wells, R-1 and R-2, were
    placed in the shallow aquifer near the buried
    drums area at the northern portion of the
    plume. Recovery wells R-7D and R-8I were
    placed in the deep aquifer in the same area.

•   Recovery wells R-10D and R-9I were placed
    in the deep aquifer at the center of the
    plume, where the greatest metals
    contamination is located.  Recovery well  R-
    3 was placed in the shallow aquifer in the
    same area.

.   Recovery wells R-4, R-5, and R-6 were
    placed in the shallow aquifer and R-111 in
    the deep aquifer at the toe of the plume.

 •   Groundwater is pumped through the wells to
    an equalization tank to regulate flow. It is
    then fed into an electrochemical treatment
    system.

 •   The electrochemical system, developed by
    Andco Environmental  Processes, Inc.. is a
    heavy metals removal process that can be
    applied to chromium-, copper-, and nickel-
    contaminated groundwater.  A direct current
    is conducted through a cell containing
    carbon steel electrodes, which generates
    ferrous iron, reducing Cr*6 to Cr*3.  Trivalent
    chromium then complexes with hydroxyl
    groups to form chromium hydroxide, which
    is insoluble in water. The electrodes are
    consumed in generating the ferrous ions
    and require periodic replacement.  The
    reaction occurs at a pH of six to  nine.
    Copper and nickel form insoluble
    hydroxides and precipitate out at a pH of six
   to nine. The electrochemical system
   reduces the chromium and copper
   concentrations to less than 10 ug/L, and
   nickel concentrations to less than 20 ug/L.

•  After metals treatment, the water passes
   through an inclined plate clarifier for sludge
   separation.  Sludge is pumped out,
   dewatered, and disposed off-site. Clarified
   water is sent through a set of multimedia
   filters.

   Filtered water is passed through two packed
   air stripping towers to remove organics.
   GAC units were added because TCA, PCE,
   and TCE did not meet effluent
   requirements. Since the addition of GAC,
   the effluent meets requirements.

•  Treated effluent is tested for effluent
   contaminant criteria. Of the effluent, 40% is
    reinjected through five infiltration trenches
    upgradient of the plume and 60% is
    reinjected through 10 infiltration galleries
    downgradient of the plume.

•   Reinjected water works to recharge the
    aquifer as well as to desorb contaminants
    from the aquifer material into the
    groundwater.

•   Groundwater is monitored according to the
    Long Term Monitoring Plan (LTMP), which
    requires quarterly testing of five monitoring
    wells and annual monitoring of 13
    monitoring wells.

 System Operation
 •   Quantity of groundwater pumped from the
    aquifer in gallons:
 3/95-3/31/96,
 4/1/96-3/31/97
 4/1/97-12/31/97
Total Gallons
Pumped

55.1 million
55.5 million
40.9 million
Aquifer

Shallow and deep
Shallow and deep
Shallow and deep
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                                               King of Prussia Technical Corporation Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation fCont.l
    The order of treatment units was optimized
    for efficiency and minimal operational
    problems. Metals removal is followed by air
    stripping and carbon polishing for organics.

    The treatment system has been operational
    approximately 76% of the time. The major
    downtime occurred between February 10,
    1997 and April 1,1997 to repair a crack in
    one filter. Also, during this shutdown,
    multimedia filter tanks were emptied to
    allow re-engineering of the system in all
    tanks and installation of new media in the
    proper order for maximum filtration [2].

    The agreed time frame of two years and
    eight months of monitoring under the Long
    Term Monitoring Plan has ended, and a new
    proposal will be provided by the PRPs to
    EPA for sampling in the future [2]. The past
    monitoring plan will be used until a new one
    is developed [3].

    According to operations contractor,
    Geraghty and Miller, Inc., as of December
    1997, the groundwater elevations at the site
 have achieved steady-state under the
 current pumping scheme. At this point, the
 groundwater flow and contaminant transport
 at the site will be reevaluated using
 MODFLOW and MT3D to evaluate
 remediation enhancements, including
 adding or removing extraction wells [5].
 The site operator is considering pumping
 changes.

 Monitoring data indicate that contaminant
 levels in the deep aquifer are below cleanup
 criteria [2]. According to the PRP
 representative, the redeveloped monitoring
 plan and remediation enhancements may
 focus on  remediation of the shallow
 aquifer [3]. The requested change is
 awaiting EPA approval.

 The PRP contact also indicated that, after
 cleaning the well and changing a pump,
 pump rates in R-1 were increased  in 1998.
 The organics concentrations in the area of
 MW-29S decreased as a result of the higher
 pumping rates.
Operating Parameters Affecting Treatment Cost or Performance
A major operating parameter affecting cost or performance for pump and treat is the extraction rate.
Table 3 presents design values for this and other performance parameters.
fete,"!1 :-.•."".-: 	 ••--'-• 	 Parameter -..'.:-..,;;;
Design Pump Rate
Performance Standard (Effluent)















Remedial Goal (Aquifer
s - , ;- , Value ''-- ':<- '- --
175 gpm, upper aquifer
25 gpm, lower aquifer
Be
Cd
Cr
Cu
Mercury (Hg)
Ni
Zn
1,1 -DCA
frans-1 ,2-DCE
1,1,1-TCA
TCE
1,1,2,2-PCA
PCE
Benzene
Toluene
Ethylbenzene
4.0 ug/L
10 ug/L
50 ug/L
1,000 ug/L
2 ug/L
210 ug/L
5,000 ug/L
2 ug/L
10 ug/L
26 ug/L
1 ug/L
1.4 ug/L
iug/L
1 ug/L
2,000 ug/L
50 ug/L
same as Performance Standards
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                                             King of Prussia Technical Corporation Super-fund Site
                     TREATMENT! SYSTEM DESCRIPTION (CONT.)
Timeline
Table 4 presents a timeline for this remedial project.
                                     Table 4. Timeline
bSwI&afr:
9/29/90
8/94
3/93
4/95
Ongoing
^ibatr^
—
—
11/93
Ongoing
...
. ••• ??-• :•'!£-•. --' '-:^^. .f.~~~}-~~~<~i .. ; f**f -,, -~ " • •••"•• a**- sff
• C^>v-i'' ^iwty.sga.; »• -ssi, ?«$• ^ • ^ il °r> ^
ROD signed
Remedial Design completed
Soil washing performed
Groundwater extraction, treatment, and quarterly monitoring
Recalibration of groundwater models, reanalysis of extraction well placement,
consideration of remedial alternatives
Source:  [1-3]
                         TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards
The remedial goal for the site is to reduce
concentrations of contaminants at the site to
below the Maximum Contaminant Levels
(MCLs) set by the New Jersey Safe Drinking
Water Act and the Primary Drinking Water
Standards. The required cleanup levels are
listed above in Table 3 and are applied
throughout both the shallow and deep aquifers,
as measured in all monitoring wells [1].

Treatment Performance Goals
•   Effluent discharged from the treatment
    system must meet the remedial goals listed
    in Table 3 for reinjection [1].

Performance Data Assessment T2.31	
The extraction system is designed to create
an inward hydraulic gradient to contain the
plume [1].
For the purpose of this analysis, metals include
beryllium, cadmium, chromium, copper,
mercury, and zinc and total VOCs include 1,1-
DCA, trans-1,2-DCE, 1,1,1-TCA, TCE, 1,1,2,2-
PCA, PCE, benzene, toluene, and ethylbenzene.

•   Cleanup  goals for metals and VOCs appear
    to have been met in the deep aquifer.
    Cleanup  goals for metals and VOCs have
    not been met overall in the shallow aquifer;
    however, cleanup goals for VOCs have
    been met in all but two wells in the shallow
    aquifer.
      EPA
Figures 2 and 3 depict the trend of metals
and VOC concentrations, respectively, in
the shallow aquifer groundwater.

Based on groundwater monitoring data, the
plume appears to have been contained.
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                                              King of Prussia Technical Corporation Superfund Site
                    TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Assessment (Cont.)
Metals
VOCs
   Metals concentrations in the shallow aquifer
   have been reduced to levels below cleanup
   goals in some wells. Metals goals have
   been met at the southwest end of the
   plume.

   Figure 2 illustrates metals concentrations in
   individual wells with contamination above
   cleanup goals and the average metals
   concentrations in the shallow aquifer from
   September 1994 to March 1997.  The
   concentrations of metals decreased in all
   wells from September 1994 to April 1995;
   however, concentrations fluctuated in wells
   25-S and 5-S.  Well 5-S, located at the
   center of the site, has the highest
   concentrations of metals.

   Below are the remaining constituents above
   cleanup goals in the shallow aquifer:

   -   The maximum concentration of
       beryllium has been reduced by 35%,
       from 100 ug/L in April 1994 to 65 ug/L
       in December 1997, above the cleanup
       goal of 4 ug/L

   -   The maximum concentration of
       chromium  has been reduced by 87%,
       from 1,040 ug/L detected during the
       1985-1989 remedial investigation to 137
       ug/L in December 1997, above the
       cleanup goal of 50 ug/L.

       The maximum  concentration of copper
       has been reduced by 77%, from 12,500
       ug/L detected during the 1985-1989
       remedial investigation to 2,900 ug/L in
       December 1997, above the cleanup
       goal of 1,000 ug/L.

   -   The maximum concentration of nickel
       has been reduced by 62%, from 1,100
       ug/L detected during the 1985-1989
       remedial investigation to 680 ug/L in
       December 1997, above the cleanup
       goal of 210 ug/L.
    In the shallow aquifer, VOC contaminant
    levels have decreased overall.

    VOC contamination is concentrated in the
    source areas of wells 5-S and 29-S.
    Figure 3 illustrates that the VOC
    concentrations in wells 5-S and 29-S
    fluctuate, primarily because of fluctuating
    PCE and 1,1,1-TCA concentrations in the
    former drum area.

    Wells 5-S and 29-S are the only wells with
    elevated levels of frans-1 ,2-DCE  and 1,1,1-
    TCA. The remainder of the wells show low
    levels of TCE, 1,1,2,2-PCA, PCE, and TCE,
    but no detectable levels of the other
    organics of concern.

    Below are data on individual VOCs in the
    shallow aquifer:

       The concentrations of 1 ,1 -DCA in the
       shallow aquifer have  met cleanup goals.
       The maximum concentration  of 1,1-
       DCA in the shallow aquifer was reduced
       from 64 ug/L detected during the 1985-
       1989 remedial investigation to levels
       below detection limits in December
       1997 (cleanup goal is 2 ug/L).

    -   The maximum concentration  of trans-
       1 ,2-DCE in the shallow aquifer has
       increased from 12 ug/L detected during
       the 1985-1989 remedial investigation to
       160 ug/L in December 1997 (cleanup
       goal is  10 ug/L).

    -   The maximum concentration  of 1,1,1-
       TCA fluctuated from  2,200 ug/L
       detected during the 1985-1989  remedial
       investigation to 4,670 in September
        1997 to 2,420 in December 1997
        (cleanup goal is 26 ug/L).

       The maximum concentration of 1 ,1 ,2,2-
        PCA has been reduced from  2,900 ug/L
       detected during the 1985-1989 remedial
        investigation to 190 ug/L in December
        1997 (cleanup goal is 1.4 ug/L).
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                                              King of Prussia Technical Corporation Superfund Site
                    TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Assessment (Cont.)
       The maximum concentration of PCE
       has fluctuated from 2,500 ug/L detected
       during the 1985-1989 remedial
       investigation, to 20,000 ug/L in April
       1995, to 15,000 ug/L in February 1996,
       and most recently to 8,160 ug/L in
       December 1997, above the cleanup
       goal of 1 ug/L.

       The maximum concentration of TCE in
       the shallow aquifer has been reduced
       from 980 ug/L detected during the 1985-
       1989 remedial investigation to 310 ug/L
       in December 1997, above the  cleanup
       goal of 1 ug/L.

       Benzene, toluene, and ethylbenzene
       have been detected solely in well 29-S.
       In December 1997, ethylbenzene was
       detected at a concentration of 1,130
       ug/L, above the cleanup goal of 50
       ug/L.  Benzene was detected at levels
       below detection limits, below the
       cleanup goal of 1 ug/L. Toluene was
       detected at 1,130 ug/L, below the
       cleanup goal of 2,000 ug/L.
Treatment System

•   Effluent monitoring results indicate that
    during January 1997, VOC concentrations in
    the treatment effluent were slightly above
    treatment performance goals. After
    maintenance during treatment system
    shutdown, treatment performance goals
    have been met.

•   Figure 4 illustrates concentrations of
    contaminants in the influent to the treatment
    system. The metals concentration in the
    influent varied from 20 ug/L in March 1995
    to 5,591 ug/L in July 1996 to 2,532 in
    October 1997. The VOCs concentration  in
    the influent increased from March to June
    1995, from 1,236 to 2,170 ug/L, and
    primarily declined from June 1995 to
    October 1997.

•   During operation from March 1995 through
    December 1997, the treatment system
    removed 1,510 Ibs of organics and 3,910 Ibs
    of metals, for a total mass removal of 5,420
    Ibs. The rate of mass removal declined as
    the mass in the influent declined.
   8,500 rrr
   8,000
   7,500
   7,000
^ 6,500
1, 6,000
=, 5,500
c 5,000
.2 4,500 kg.
to 4,000 "*"
•g 3,500
g 3,000
= 2,500
O 2,000
   1,500
   1,000
     500
       0
      Aug-94
                     Jan-95     May-95     Oct-95
    Mar-96
Jul-96
Dec-96     Apr-97
• Average*
-*-
Well
31 -S
-*-
Well
5-S
-•-
Well
25-S -4
K— Well
29-S
                     'Average concentrations include wells 5-S, 25-S, 27-S, 29-S, and 31 -S

  Figure 2.  Metals Contaminant Concentrations in the Shallow Aquifer (September 1994 - March 1997) [2]
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                                              King of Prussia Technical Corporation Superfund Site
                   TREATMENT SYSTEM PERFORMANCE (CONT.)
    35,000
        Aug-94     Jan-95     May-95    Oct-95    Mar-96
                        Jul-96
                   Dec-96     Apr-97
                                  -Average* -*— Well 5-S -*-Well 29-S
                   'Average concentrations include wells 5-S, 25-S, 27-S, 29-S, and 31 -S

Figure 3. VOC Contaminant Concentrations in the Shallow Aquifer (September 1994 - March 1997) [2]
                       Sep-95
Apr-96
Nov-96
May-97
Dec-97
                    -Organfcs Influent Concentration, ug/L —•—Metals Influent Concentration, ug/L
    Figure 4.  Influent Concentrations to the Treatment System (March 1995 - November 1997) [2]
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                                                 King of Prussia Technical Corporation Superfund Site
                     TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Completeness
    For the contaminant concentrations shown
    in Figures 2 and 3, quarterly monitoring data
    were used from September 1994 through
    March 1997. Annual monitoring data from a
    separate subset of wells are available from
    the PRP site contact. However, because
    the annual data used in conjunction with the
    quarterly data would not have represented a
    continuous data set for analysis, these data
    were not used for Figure 2 and 3 analyses.
Performance Data Quality
                    A geometric mean of contaminant
                    concentrations was used to represent the
                    trend of contaminant concentrations across
                    the site for Figures 2 and 3.

                    Contaminant concentrations in the influent
                    shown  in Figure 4 were reported in quarterly
                    monitoring reports for March 1995 through
                    November 1997.

                    Mass removal calculations were reported in
                    quarterly monitoring reports for March 1995
                    through November 1997.
The QA/QC program used throughout the remedial action met the EPA and the State of New Jersey
requirements.  All monitoring was performed using EPA-approved methods, and the site contact did not
note any exceptions to the QA/QC protocols [2].
                                TREATMENT SYSTEM COST
Procurement Process
•   The PRPs contracted with Geraghty & Miller, Inc. to construct and operate the remedial system,
    under the oversight of EPA. Geraghty & Miller, Inc. contracted with Andco Environmental
    Processes, Inc. to provide and install the treatment system.

Cost Analysis

•   All costs for investigation, design, construction and operation of the treatment system at this site
    were borne by the PRPs.
Capital Costs T31
 Remedial Construction
 Groundwater Treatment
     Equipment
     Permits
     Construction Management
     SOP/D&M Manual
     Electrical System Construction
     Other Subs
     Plant Construction
     Cultural Resources
 Groundwater Control
     Well Construction
     Recovery System Construction
 Total Construction
$1,743,563

 $927,127

  $31,637

 $234,548

  $63,681

 $130,424

 $194,003

 $131,924

  $30,219

 $287,703

 $116,166

 $171,707
$2.031.430
Operating Costs H 995-1 9971 F31
 Labor                               $325,760
 Travel                                $14,325
 Disposal (Sludge and Water)                 $2,432
 Chemicals                             $49,226
 Lab Supplies                            $1,017
 Health & Safety Supplies                    $3,941
 Administrative Expenses                   $46,950
 Maintenance                          $159,542
 Utilities                              $181,501
 Total Operations                      $784.694

 Operations By Year
 March 1 995 - April 1 995                   $74,230
 May 1 995 - April 1 996                    $393,740
 May 1 996 - April 1 997                    $284,1 31
 May 1 997 - April 1 998                    $281 ,298*
 *June 1997 - April 1998 costs of $251,443 not included in
 unit costs
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                                                King of Prussia Technical Corporation Superfund Site
                          TREATMENT SYSTEM COST (CONT.)
Other Costs T31
 Groundwater Investigations
 Groundwater Modeling
 Western Plume Boundary
 Treatability Study
 Treatment System Design
 Overall Design Management
 Well Installation Costs
 Total Other
 $250,860

 $140,718

  $40,652

  $87,247

 $304,145

 $379,473

 $279,617

$1.482.712
Cost Data Quality
Actual capital and operations and maintenance cost data are available from the PRPs for this
application.
                        OBSERVATIONS AND LESSONS LEARNED
    Actual costs for the P&T application at the
    KOP site were approximately $2,816,000
    ($2,031,000 in capital costs and $785,000 in
    operating and maintenance costs), which
    corresponds to  $520 per pound of
    contaminants removed and $19 per
    thousand gallons of groundwater treated,
    based on cost incurred and treatment
    performed through December 31,1997.

    Cleanup goals have been met in the deep
    aquifer, but not the shallow aquifer. Two
    shallow wells, in source areas, remain
    contaminated with VOCs.  Four wells
    remain contaminated with metals.

    The concentrations of VOCs and metals in
    treatment system influent have decreased
    faster than concentrations in shallow
    monitoring wells. Concentrations of PCE
    and 1,1,1-TCA  in these wells were higher
    during the November 1997 sampling than in
    the baseline sampling,  and concentrations
    of other contaminants in the wells
    fluctuated, spiking above baseline sampling
    levels.

    There are several possible explanations for
    why treatment influent  concentrations are
    falling faster than concentrations in the
                    shallow monitoring wells.  Two conditions
                    would allow extracted water to circumvent
                    the more contaminated areas. One is the
                    tendency of contaminants in the
                    groundwater to travel through preferential
                    pathways, as observed at some Superfund
                    sites [6]. Another possible factor is
                    stagnation zones, which develop where low
                    hydraulic gradients are created in
                    overlapping zones of influence from
                    recovery wells and/or from low permeability
                    zones [7]. Stagnation zones and
                    preferential pathways can be counteracted
                    by adjusting the location and pumping rates
                    of the extraction wells. The PRPs are
                    evaluating P&T performance and will
                    consider such adjustments to optimize mass
                    removal and contaminant reduction [3,5].

                    While no dense nonaqueous phase liquid
                    (DNAPL) has been directly observed during
                    sampling, high initial concentrations of TCE
                    and PCE indicated its likely presence. If
                    DNAPL is present at this site, it will lead to
                    persistent plumes, as it dissolves
                    continuously into the aqueous phase.
                    Elimination of possible DNAPL sources, if
                    present, could improve the effectiveness of
                    P&T at this site.
      EPA
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                    	Technology Innovation Office
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                                              King of Prussia Technical Corporation Superfund Site
                                      REFERENCES
1.  Record of Decision. U.S. EPA, Region 2,
   September 1990.

2.  Quarterly Groundwater Treatment Plant
   Monitoring Reports. Johnson Matthey,
   January 16,1998, April 23,1997, and April
   21,1996.

3.  Correspondence with Mr. Frank J. Opet,
   Johnson  & Matthey, January 30,1997,
   February 14,1997, June 5,1997, July 15,
   1997, August 1,1997, January 15, 1998,
   and July  17,1998.

4.  Correspondence with Mr. Jack Reich, Andco
   Environmental Processes, Inc., February
   1998.
5.   Correspondence with Mr. Steve Feldman,
    Geraghty and Miller, Inc., January 19, 1998.

6.   Surfactant-Enhanced Remediation of a
    TCE-Contaminated Aquifer. Smith, James
    A., Sahoo, D., McLellan, H.M., and
    Imbrigiotta, T.E.  Environmental Science
    and Technology, 1997, V.31, No-12, 3565-
    3572.

7.   Design Guidelines for Conventional Pump-
    and-Treat Systems. Robert M. Cohen,
    James W. Mercer, Robert M.  Greenwald,
    and Milovan S.  Beljin. EPA Ground Water
    Issue, September 1997.

8.   Comments on draft report provided by
    Frank Opet, PRP Representative, July
    1998.
Analvsis Preoaration
This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
Emergency Response, Technology Innovation Office. Assistance was provided by Tetra Tech EM Inc.
and Eastern Research Group, Inc. under EPA Contract No. 68-W4-0004.
      EPA
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                   Technology Innovation Office
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               94

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Pump and Treat of Contaminated Groundwater at
      the LaSalle Electrical Superfund Site,
                LaSalle, Illinois
                      95

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                    Pump and Treat of Contaminated Groundwater at
                           the LaSalle Electrical Superfund Site,
                                        LaSalle, Illinois
 Site Name:
 LaSalle Electrical Superfund Site
 Location:
 LaSalle, Illinois
 Contaminants:
 PCBs and chlorinated solvents
 - Maximum concentrations
 detected in 1980-1981 were PCBs
 (760,000 ug/L), TCE (13,341
 ug/L), trans-1,2-DCE (7,152 ug/L),
 1,1,1-TCA (3,123 ug/L), and vinyl
 chloride (500 ug/L)
Period of Operation:
Status: Ongoing
Report covers: 12/92 - 5/97
Cleanup Type:
Full-scale cleanup (interim results)
 Vendor:
 Ecology & Environment, Inc.
 ThermoCor Kimmons
 Additional Contacts:
 None
Technology:
Pump and Treat
- Groundwater is extracted using 3
infiltration trenches, at an average
total extraction rate of 17 gpm
- Extracted groundwater is treated
with oil/water separation, air
stripping, and carbon adsorption,
and discharged to a POTW
Cleanup Authority:
CERCLA Remedial
- ROD Date: 3/30/88
State Point of Contact:
Rich Lange
Illinois EPA (IEPA)
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
(815)223-1126
Waste Source:
Spills from capacitor cleaning and
spreading polychlorinated biphenyl
(PCB)-laden waste oils as a dust
suppressant
 Purpose/Significance of
Application:
 Relatively high unit cost; system
consists of collection trenches
instead of extraction wells;
relatively low groundwater flow.
Type/Quantity of Media Treated:
Groundwater
- 23 million gallons treated as of May 1997
- DNAPL observed in groundwater on site
- Groundwater is found at 3-5 ft bgs
- Contaminants are primarily found hi a shallow aquifer at the site
- Hydraulic conductivity ranges from <0.01 to 0.22 ft/day
Regulatory Requirements/Cleanup Goals:
- The goal of this remedy is to restore the groundwater to primary drinking water standards; these are PCBs (0.5
  ug/L), 1,2-DCE (5 ug/L), 1,1-DCA (5 ug/L), TCE (5 ug/L), PCE (100 ug/L), 1,1,1-TCA (200 ug/L), and vinyl
  chloride (2 ug/L).
- Containment was not a specific goal of this remediation.
Results:
  Groundwater monitoring results for the deep aquifer (through March 1996) and shallow aquifer (through May
  1997) indicate that total contaminant concentrations have not been reduced below cleanup goals. At specific
  monitoring wells, contaminant concentrations fluctuate with precipitation rates.
  From 1993 to September 1997, the system removed approximately 127 pounds of contaminants from the
  groundwater; 1,1,1-TCA makes up the majority of the mass removed by the treatment system.
                                               96

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                  Pump and Treat of Contaminated Groundwater at
                          the LaSalle Electrical Superfund Site,
                                LaSalle, Illinois (continued)
Cost*
- Actual costs for pump and treat are approximately $6,138,576 ($5,314,576 in capital and $824,000 in O&M),
  which correspond to $266 per 1,000 gallons of groundwater extracted and $48,000 per pound of contaminant
  removed.                                                            	
Description:                                                                              „
LaSalle Electrical Utilities operated this site as a manufacturing facility for electrical equipment rrom 1940 to
1978. PCBs and chlorinated solvents were used in the manufacturing process during this time. As a result of
complaints, government agencies issued several orders in 1975 against the company for its manufacturing and
waste handling practices. In 1980 and  1981, Illinois EPA performed sampling at the site which confirmed the
presence of PCB and VOC contamination in soils and groundwater. The site was placed on the NPL in
December 1982 and a ROD was signed in March  1988.

The groundwater collection system is a passive design that uses three infiltration trenches instead of wells. The
three trenches form an H-pattern, and drain to a wet well, which in turn is pumped to the treatment unit. The
trenches were installed horizontally at a depth of approximately 17 to 25 ft bgs. Approximately 127 pounds of
contaminants (primarily 1,1,1-TCA) have been removed from the groundwater over 45 months, however the
system has not achieved the cleanup goals.  As of May 1997, no design modifications were being considered for
this site.	^—^=^=^=^=^=^=^^=^=
                                                97

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                                                                  LaSalle Electrical Superfund Site
                                     SITE INFORMATION
 Identifying Information:
 LaSalle Electrical Superfund Site
 LaSalle, Illinois

 CERCLIS#: SCD980711394

 ROD Date: March 30, 1988


 Background
 Treatment Application:
 Type of Action:  Remedial

 Period of operation: 12/92 - Ongoing
 (Data collected through 1997)

 Quantity of material treated during
 application: 23 million gallons of groundwater
 Historical Activity that Generated
 Contamination at the Site:  Electrical
 equipment manufacturing

 Corresponding SIC Code: 3612 (power,
 distribution, and specialty transformers)

 Waste Management Practice That
 Contributed to Contamination: Spills from
 capacitor cleaning and spreading poiychlorinated
 biphenyls (PCB)-laden waste oils as a dust
 suppressant

 Location:  LaSalle, Illinois

 Facility Operations:  [4,7]
 •   LaSalle Electrical Utilities (LEU) operated
    this 10-acre site as a manufacturing facility
    for electrical equipment from 1940 to 1978.
    PCB and chlorinated solvents were used in
    the manufacturing processes during this
    time.

 •   Site contamination resulted from operations,
    spills of dielectric fluids from capacitor
    cleaning, and PCB-laden waste oils that
    were applied as a dust suppressant to the
    ground surface.

•   As a result of complaints, government
    agencies issued several orders in 1975
    against LEU for its manufacturing and waste
    handling practices.

•   In 1980 and 1981,  Illinois EPA (IEPA)
    performed sampling at the site which
    confirmed the presence of PCB and volatile
    organic compound (VOC) contamination in
    soils and groundwater.
 •  In 1981, EPA ordered LEU to cease
    operations because of its waste
    management practices and existing health
    threats.

 •  The site was placed on the National
    Priorities List (NPL) in December 1982.

 •  Between 1982 and 1986, several emergency
    removal actions occurred at the site to
    package, stage, or cap highly contaminated
    soil.

 •  A remedial investigation (Rl) and feasibility
    study were completed between 1983 and
    1985.

    In March 1986, after review of the draft Rl
    report, the U.S. EPA elected to  split the site
    into two separate projects. The 1985 Rl had
    adequately characterized the soil
    contamination in the area.  However, it had
    failed to sufficiently determine the extent of
    groundwater contamination emanating from
    the LEU property.  A second Rl  addressing
    groundwater conditions was completed in
    1988.

    Under a separate Record of Decision
    (ROD),  (issued in September 1986), highly
    contaminated soils were excavated and
    incinerated. The incinerated soils were
    replaced and regraded across the site.

Regulatory Context:
•   A ROD was signed for groundwater
    remediation on March 30, 1988.
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                                                              LaSalle Electrical Superfund Site
                              SITE INFORMATION (CONT.)
Background fConU
»  Site activities were conducted under
   provisions of the Comprehensive
   Environmental Response, Compensation,
   and Liability Act (CERCLA) of 1980, as
   amended by the Superfund Amendments
   and Reauthorization Act (SARA) of 1986,
   §121, and the National Contingency Plan
   (NCP), 40 CFR 300.

Site Logistics/Contacts
Groundwater Remedy Selection:
The selected remedy for groundwater at this site
was extraction and treatment of groundwater via
air stripping and carbon adsorption.
Site Lead: State

Oversight: EPA
State Contact:
Rich Lange*
Illinois EPA (IEPA)
2200 Churchill Road
P.O. Box 19276
Springfield, Illinois 62794-9276
(815)223-1126

Treatment System Vendor:
Ecology & Environment, Inc.
ThermoCor Kimmons
 "Indicates primary contact
                                 MATRIX DESCRIPTION
 Matrix Identification
 Type of Matrix Processed Through the
 Treatment System: Groundwater

 Contaminant Characterization T6. 71
 Primary Contaminant Groups: PCBs and
 halogenated VOCs

 •   The primary contaminants of concern at this
    site are the PCBs:  Arochlor-1242, -1248,
    and -1254; and VOCs: tetrachloroethylene
    (PCE), trichloroethylene (TCE),
    frans-1,2-dichloroethylene (frans-1,2-DCE),
    1,1,1 -trichloroethane (1,1,1 -TCA),
    1,1-dichloroethane (1,1-DCA), and vinyl
    chloride (VC).

 •   Maximum groundwater contaminant
    concentrations detected by EPA during
    initial investigations in 1980-1981 were PCB
    (760,000 ug/L), TCE (13,341 ug/L),
    trans-1,2-DCE (7,152 ug/L), 1,1,1-TCA
    (3,123 ug/L), and VC (500 ug/L).

    The plume of groundwater contaminants
    initially detected in 1980 was estimated by
    the IEPA to cover over 700,000 square feet
    [7]-

    Figure 1 illustrates PCB concentration
    contours at the LaSalle Electrical site in
    1982.1 The plume of VOCs is not shown in
    Figure 1; however, the VOC plume is
    approximately the same size and in the
    same location.
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                                                                  LaSalle Electrical Superfund Site
                              MATRIX DESCRIPTION (CONT.)
 Contaminant Characterization (ConU
     Concentrations of RGBs in soils up to
     17,000 ppm were detected at several
     locations on site. These soils were
     excavated and incinerated in 1991 and
     1992.
 Site engineers observed a dense non-
 aqueous phase liquid (DNAPL) in the
 bottom three to five feet of a 10 foot well
 casing up to 300,000 (jg/L PCB. The
 amount of DNAPL present in the subsurface
 was unknown; however, significant
 quantities of oily liquids were removed with
 excavated soils.
 »  Uowraoto wtu
   MONO I MUPIBKJ
KX. MtOYI DETECTION UMT

COWIHJHATIOWIHajiL
CONKX* IWES OMHEO WHEN IKFEBfltD
          F/gure Y.  Initial PCB Concentration Contour Map (Best Copy Available) (1982) [6]
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                                                                 LaSalle Electrical Superfund Site
                             JMATRIX DESCRIPTION (CONT.)
Matrix Characteristics Affecting Treatment Costs or Performance f61

Hydrogeology:

Three primary units have been identified within the upper 100 feet of the soils at this site. Two of these
units function as aquifers (Units 1 and 3), and the third functions as an aquitard (Unit 2).  Upward vertical
gradients are observed across the site which limit the downward migration of contaminants into the
lower water bearing unit (Unit 3). The water table is encountered at three to five feet below ground
surface. Contaminants are primarily found, in the shallow aquifer (Unit 1) and are migrating in a
southeast direction with the natural groundwater flow.


     Unit 1    Maiden Till     Interbedded unit of sand, silt, and clay, which is an unconfined water-
                            bearing unit.

     Unit 2    Tiskilwa Till    Silty clay and clay with occasional silt and sand lenses, which acts as an
                            aquitard. This unit is discontinuous across the site.

     Unit 3    Bond          Bedrock unit composed of clay, shale, and coal seams at depth.
              Formation

     Table 1 presents the technical aquifer characteristics. This information comes from the Phase II
     Remedial Investigation performed in 1988.
Unit Name
Maiden Till
Tiskilwa Till
Bond Formation
Thickness
(ft)
15-25
10-12
>60
Conductivity
(ft/day)
0.22 (Kh)
0.000005 (Kv)
0.0005 (Kh)
Average Velocity
(ft/day)
.016
NC
NC
Flow
Direction
Southeast
NC
Southeast
 Kh - Horizontal conductivity, \^ - Vertical conductivity, NC - Not characterized
                           TREATMENT SYSTEM DESCRIPTION
 Primary Treatment Technology

 Pump and treat with air stripping and carbon
 adsorption.

 fiv^tom Descrintion and Oneration
Supplemental Treatment Technology

Vapor-phase carbon adsorption, oil/water
separation.
 System Description [5,6]
 •   The groundwater collection system is a
    passive design that uses three infiltration
    trenches instead of wells. It was designed
    to capture the on-site groundwater directly
    beneath the original plant site, and extends
    200 feet south of the original plant site. The
    one main east-west collection trench and
    the north-south collection trenches form an
    H-pattern.  The north-south collection
    trenches drain to the east-west trench,
    which'in turn flows to a wet well. Collected
    groundwater is pumped from the wet well to
    the groundwater treatment unit. The
    average extraction rate is 16-15 gpm.
    Figure 2 shows the groundwater collection
    and monitoring system at the LEU site.
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                                                       LaSalle Electrical Superfund Site
               TREATMENT SYSTEM DESCRIPTION (CONT.)
                           Figure 2. Site Diagram [2]
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                                                                  LaSa/fe Electrical Superfund Site
                      TREAtMENTl SYSTEM DESCRIPTION (CONT.)
Svstem Description and Operation (Cont.)
•   The collection system consists of trenches
    with six-inch perforated polyvinyl chloride
    (PVC) pipe installed horizontally
    approximately 17 to 25 feet deep. The
    perforated pipe was installed in a 4-foot
    deep by 4-foot wide gravel bed. The gravel
    bed is surrounded by filter fabric to retard
    infiltration of fines. The on-site trenches
    were backfilled with incinerated soil to within
    one foot of final grade. The backfilled soils
    were then capped with six inches of clay and
    six inches of topsoil to limit infiltration. Parts
    of the collection system which extended off-
    site were backfilled to within five feet of final
    grade and capped with clean fill and one foot
    of top soil.

•   The groundwater treatment unit consists of
    an oil/water separator and twin air strippers
    for the chlorinated solvents. A vapor-phase
    carbon adsorption unit is used to treat gas
    vapors from the strippers.  Two 10,000-
    pound liquid phase carbon adsorption
    systems are used to remove the  suspended
    and dissolved PCBs.  An acid injection
    system was added to  the original design to
    control pH of the effluent.

•   The air strippers are operated in  series.
    Each is two feet in diameter and  has 11  feet
    of packing material. The stripping columns
    are 23 feet tall. The design ratio  of air to
    water is 50:1.

•   Effluent from the treatment system is
    discharged to a local Publicly Owned
    Treatment Works (POTW) under an
    industrial pretreatment permit.

•   The groundwater monitoring system
    includes monitoring wells for the deep
    aquifer and manhole sampling  points in
    collection trenches for the shallow aquifer.

System Operation [5,7]
This report covers operation of the collection
and treatment systems during construction and
through September 1997.
  Quantity of groundwater pumped from
  aquifer in gallons:
    Year
    1992
    1993
    1994
    1995
    1996
1997 (9 months)
Volume Pumped (gal)
     3,015,000
     5,700,000
     2,620,000
     3,895,000
     4,800,000
     3,200,000
  The treatment unit was completed in April
  1992 and began to operate by treating the
  groundwater and precipitation that
  accumulated in open excavations during
  construction activities.

  In December 1992, part of the collection
  system was installed. The remainder of the
  collection network was installed between
  March 1993 and June 1993.  The collection
  system was installed in phases to minimize
  the number of open trenches at one time.

  Approximately eight million gallons were
  treated through the system between April
  1992 and September 1993.  The average
  extraction rate is approximately 18,000
  gallons per day based on the volume of
  water treated to date.

  The full collection system went online in
  September 1993.  The remedial system is
  operated in a batch mode. Groundwater is
  extracted for approximately 8-10 hours, then
  the aquifer is allowed to recover for 12-16
  hours. The treatment system is designed for
  an optimum capacity of 20 gpm.  It has been
  operating between 10-15 gpm to handle the
  volume of water extracted. According to the
  site contact, the treatment system has
  operated for approximately 15,530 hours and
  treated 14.6 million gallons since September
  1993.

  The extraction system is operational five
  days a week 24 hours a day. An operator is
  on-site daily 4-8 hours.
        i
  The pH of effluent is controlled to maintain
  compliance with the discharge permit.
  Caustic conditions also have caused a
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                                                                LaSalle Electrical Superfund Site
                     TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation (ConU
    mineral deposit to build up in the first
    carbon unit. Control of pH levels has
    minimized this problem.

    The oil/water separator has been used
    primarily as a settling tank for entrained
    solids. No oil component has been noted in
    the influent stream during the operation of
    the system.

    Air stripping media have not been changed;
    however, the polypropylene media has
    required acid washing to remove deposits
    every two years.
Since start-up in 1993, the site has been
operational approximately 75% of the time.
The system was shut down from July 1994
through January 1995 during a period of
negotiation with the construction contractor
over cost and scope of work for operations
and maintenance [7].

Spent carbon was changed once in 1993.
Influent concentrations to the carbon units
have generally been below detection limits
since that time and have not exceeded the
capacity of the carbon.
Operating Parameters Affecting Treatment Cost or Performance
The groundwater extraction rate is a major operating parameter affecting cost or performance for this
technology. Table 2 presents the average extraction rate between 1993 and 1997 and the performance
parameters required to restore the groundwater to primary drinking water standards.

                               Table 2: Performance Parameters
Parameter " «• :, :•'
Average Extraction Rate (1993-1997)
Performance Standard (effluent)
Remedial Goals
(aquifer)
-. '-'K3Si &i: .'ijjfijjte^ • • .,
15- 18 gprn
1,2-DCE
1,1-DCA
TCE
PCE
1,1,1-TCA
VC
PCBs
1,2-DCE
1,1-DCA
TCE
PCE
1,1,1-TCA
VC
PCBs
7 ug/L
20 ug/L
5 ug/L
100 ug/L
200 |jg/L
2Mg/L
1 ug/L
5 ug/L
5 ug/L
5Mg/L
100 ug/L
200 ug/L
2|jg/L
.5 ug/L
           Source: [4], [7]
Timeline
Table 3 shows a timeline for this remedial project.
                                   Table 3: Project Timeline
Start Date
3/88
1/89
10/91
4/92
12/92
9/93
6/94
End Date
—
10/90
4/92
8/93
6/93
—
12/94
•'••^ M^etiyjty s '','""/•>
Record of Decision signed for this site
Remedial system designed
Treatment unit constructed
Treatment system operated while full system construction completed
Collection system constructed
Operations and quarterly monitoring began
Remedial system shutdown while contractor was replaced
Source: [5]
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                                                                LaSalle Electrical Superfund Site
                         TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards f41
The goal of this remedy is to restore the
groundwater to the primary drinking water
standards as listed in Table 2. These standards
are applied throughout the aquifer as measured
in all on-site wells.
Treatment Performance Goals [41
•   The treatment system must reduce contaminant levels in the treated water to meet discharge
    requirements imposed by the local POTW. These requirements are stipulated in an industrial
    pretreatment permit which reflects the treatment standards included in the ROD and also are
    presented in Table 2.

Performance Data Assessment 15,8,91	
For this discussion and Figures 3 through 6,
total contaminants consist ofPCBs and VOCs.

•   Figures 3 and 4 present groundwater
    monitoring results for the deep and shallow
    aquifers.  Available data (through March
    1996 for the deep aquifer and through May
    1997 for the shallow aquifer) indicate that
    total contaminant concentrations have not
    been reduced below cleanup goals.

•   Figure 3 illustrates changes in average total
    contaminant concentrations in the deep
    aquifer over time. This figure is generated
    from a geometric mean of data from four
    wells in the deep aquifer.  The concentration
    of total contaminants was 6 ug/L in March
    1996 [5,8]-

•   The maximum concentration of
    contaminants detected  in the groundwater
    after 45 months of system operation were,
    PCB (BQL), TCE (530 ug/L),  1,1,1-TCA
    (1,700 ug/L), 1,1 -DCE (1,800 ug/L.), and VC
    (180 ug/L).

•   The average groundwater concentration of
    total contaminants in the deep aquifer
    peaked at 125 ug/L in April 1993 and
    dropped to less than 40 ug/L by June 1993,
    as shown in Figure 3.  The early peak
    appears to be due to high concentrations
    within one well.

•   The majority of contaminants at this site are
    found in the shallow aquifer.  Figure 4 shows
    an average of total contaminant
concentrations detected at five manhole
sampling points in the shallow aquifer.
These sampling points are located in the
collection trenches which intercept the
shallow aquifer.  MH1E located near the old
LEU buildings shows the highest peak
concentrations of total contaminants 1993-
1997 with concentrations up to 11,800 ug/L.
MH3S, located adjacent to MH1E,
consistently showed the lowest measured
total contaminant concentration with no
discernable spiking.

No contaminants have been detected in
downgradient monitoring wells since the
beginning of remedial operations. On the
basis of this information, plume containment
appears to have been achieved; however,
containment was not a specific goal of the
remedial system.

Water level measurements indicate that the
southern capture zone boundary, in the
vicinity of monitoring well G111,  is
uncertain.  A 60-inch leaking storm sewer
pipe runs through the site at this point and
creates an artificial recharge zone to the
shallow aquifer.  As a result a groundwater
mound has been created which varies in
size depending on precipitation and
recharge rates [5].

At wells G103, G107, and G112A,
contaminant concentrations increase during
wet seasons and decrease during dry
seasons. This variance is likely due to
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                                                         LaSalle Electrical Superfund Site
                TREATMENT SYSTEM PERFORMANCE (CONT.)
   140.00
   120.00
          sAl^Md««S»
     0.00
       Jul-92
Jan-93     Aug-93     Mar-94     Sep-94
                                                         Apr-95
Oct-95     May-96
Figure 3. Average Deep Groundwater Concentrations for Total Contaminants (PCBs and VOCs)
                            (Dec. 1992-Mar. 1996) [6,8]

   Jan-93
                       Jun-94
                           Oct-95
                                                                 Mar-97
  Figure 4.  Total Contaminant Concentration in Shallow Aquifer Manholes (1993-1997) [6,8]
  EPA
                                      U.S. Environmental Protection Agency
                               Office of Solid Waste and Emergency Response
                              	Technology Innovation Office
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                                                                LaSalle Electrical Superfund Site
                    TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Assessment (Cont.)
    precipitation infiltrating through residual
    contaminated soils [5]. The concentrations
    detected in the collection trenches do not
    coincide with this pattern.

    A total of 23 million gallons of groundwater
    have been treated through the remedial
    system. Taking into account the hours of
    system operation, a daily average treatment
    rate of 15-18 gpm has been achieved.

    As shown in Figure 5, the system has
    removed approximately 127 pounds of
    contaminant mass from 1993 to September
    1997.
The mass flux rate, as shown in Figure 5,
varies between 0.07 and 0.29 Ibs/day from
start up through July 1994 when the system
was temporarily shutdown. During the later
operating period from 1995 to September
1997, the mass flux rate starts at 0.02 and
increases to 0.19 Ibs/day.

Based on available data, 1,1,1-TCA is the
primary contaminant detected in the influent
samples and makes up the majority  of the
mass removed by the treatment system.
Figure 6 illustrates the relationship between
1,1,1-TCA and the total contaminants
removed from 1993 to September 1997.
Performance Data Completeness
    Contaminant mass removal was determined
    using analytical results from system influent
    measurements, along with treatment rate
    data. Wells were sampled quarterly for
    contaminant concentrations. Influent data
    were available through September 1997.

    Groundwater data are available from before
    treatment and during quarterly sampling
    events. Groundwater data from January
    1993 through May 1997 were used in this
    report. Figure  3 includes only data through
    March 1996 because different wells were
    sampled after that date.

    Figures 3 and 4 are generated by
    calculating a geometric mean of data from
    specific monitoring points. The mean is
    used to represent a trend across the  site.
Data are available for water level
measurements from before treatment and
during quarterly sampling events.

Effluent samples are collected on a weekly
basis and analyzed for PCBs and VOCs.
Effluent data are available from October
1993 through September 1997.

Monthly influent and effluent samples for
total PCB and VOC contaminants were
used for mass flux determinations
presented in Figure 5. Cumulative mass
removal was generated from these data
and monthly flow rates.

Monthly influent and effluent samples were
used for TCA data presented in Figure 6.
Performance Data Quality
The QA/QC program used throughout the remedial action met the EPA and the State of Illinois
requirements. All monitoring was performed using EPA-approved methods, and the site contact did not
note any exceptions to the QA/QC protocols.
      EPA
        U.S.  Environmental Protection Agency
 Office of Solid Waste and Emergency Response
	Technology Innovation Office
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                                                                LaSalle Electrical Superfund Site
                    TREATMENT SYSTEM PERFORMANCE (CONT.)
    0.35
    0.25
 t
 «= 0.15
    0.05
                                                        140
                                                                                     120
                                                        100
                                                                                     80
                                                       60
                                                                                         0)
      Jan-93  Aug-93   Mar-94   Sep-94  Apr-95   Oct-95   May-96   Dec-96   Jun-97   Jan-98
                                 . Mass Flux
                      . Mass Removed
               Figure 5.  Mass Flux and Cumulative Removal (Oct. 1993 - Sept. 1997)
       0.35

    8
    £
       0.05
       0.00
                                                                                   140.00
                                                                                   120.00
                                                                                   100.00
                                                                                   80.00
                                                                                   60.00
                                                                                  40.00
                                                                                   20.00
                                                                                   0.00
                                                                                         I
                                                           in
                                                           i
         Jan-93  Aug-93  Mar-94   Sep-94   Apr-95   Oct-95  May-96  Dec-96   Jun-97   Jan-98
           -Total Mass Flux
-TCA Mass Flux  — •— Total Mass Removed
-TCA Mass Removed
Figure 6. Comparison of TCA and Total Contaminant Mass Flux and Cumulative Removal
                                   (Oct. 1993 - Sept. 1997)
      EPA
                                U.S. Environmental Protection Agency
                         Office of Solid Waste and Emergency Response
                                        Technology Innovation Office
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                                                                LaSalle Electrical Superfund Site
                               TREATMENT SYSTEM COST
Procurement Process
The IEPA is the lead agency for this site; however, U.S. EPA is providing operations and maintenance
funding for the first 10 years. Ecology & Environment, Inc. has been contracted to provide site
management activities. ThermoCor Kimmins was contracted to provide treatment system construction.
Carmichael, Inc. has been contracted to provide long-term O&M.

Cost Analysis

•  The majority of costs for design, construction, and operation of the treatment system at this site were
   provided by U.S. EPA.
Capital Costs F71
Remedial Action
Engineering and Site
Management
Analytical Services
Parking Lot, Fence, etc.
Treatment System
Treatment Plant Structure
Total Remedial Construction


Cost Data Quality


$2,780,312
$1,053,496
$86,022
$1,186,423
$208,323
$5,314,576



Ooeratina Costs F71
Plant Operations and Maintenance
Analytical Services
Carbon Treatment
Total Cumulative Operating
Expenses (1992-1 997)
Other Costs F7]
Remedial Design
State Technical Assistance
Total Remedial Design1
EPA Personnel Costs
Includes the management of soils-related

$593,700
$115,700
$114,600
$824,000

$310,431
$15,487
$325,918
$95,895
activities.
Actual capital and operations and maintenance cost data are available from the IEPA for this project.
                       OBSERVATlbNS AND L.ESSONS LEARNED
    Total costs for the collection and treatment
    system were approximately $6,138,576
    ($5,314,576 in capital and $824,000 in
    operations and maintenance) which
    corresponds to $48,000 per pound of
    contaminants removed and $266 per 1,000
    gallons of groundwater.

    The collection system was installed in
    phases over a six-month period. On-site
    excavation was only to meet the remedial
    action objectives for PCBs in soil as stated
    in the ROD. The collection underdrain
    system was installed post-excavation for
    PCB thermal treatment and prior to
backfilling. This sequential installation
significantly reduced re-excavation and
resulting costs.

The treatment system performance data
indicate that approximately 127 pounds of
contaminants were removed from the
groundwater over 45 months; however, the
collection and treatment system has not
achieved the cleanup goal.

The leaking storm sewer drain has caused
an artificial recharge zone in the vicinity of
the collection system.  The storm sewer
      EPA
        U.S. Environmental Protection Agency
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                Technology Innovation Office
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                                                                LaSalle Electrical Superfund Site
                  OBSERVATIONS AND LESSONS LEARNED (CONT.)
    trench may also act as a conduit for plume
    migration off site [5].

    At specific monitoring wells, contaminant
    concentrations fluctuate with precipitation
    rates. During wet seasons contaminant
    concentrations are observed to increase,
    which is an indicator that contaminant
    materials are trapped in pore spaces or
    sorbed to unsaturated soils. When
    precipitation infiltrates, the contaminants are
    transported into the groundwater [5].

    PCBs were initially expected to be the
    primary contaminant at this site. According
    to the site contact and as shown in Figure 6,
    TCA accounts for the majority of the total
    contaminants in groundwater at the site [7].
    According to the site contact, the original
    design has been adequate in addressing the
    site cleanup efforts to date. No design
    alterations are currently being considered
    [7].

    The visual observation of an oily DNAPL
    material in a well casing confirms the
    presence of subsurface source zones.
    Additional subsurface source zones are
    likely present at this site. Persistent and
    highly variable concentrations in the
    groundwater may indicate the presence of
    additional DNAPLs, which may act as
    sources for persistent groundwater
    contamination.
                                       REFERENCES
1.  Phase II Construction Oversight. Ecology
    and Environment Engineering, April 1989.

2.  Phase II Remedial Design. Ecology and
    Environment Engineering, June 1988.

3.  Remedial Project Manager, U.S.
    Environmental Protection Agency.

4.  Record of Decision. U.S. Environmental
    Protection Agency, March 1988.

5.  Review and Assessment of Performance
    Report. LaSalle Electric Utilities Company
    Site. Groundwater Treatment Unit Inception
    Through December 1995. Ecology and
    Environment, Inc. 1996.

Analysis Preparation	
6.   Phase II Remedial Investigation.
    Groundwater Hydrogeological Report.
    Ecology and Environment, Inc. 1988.

7.   Conversations with I EPA
    Representative, May 29, 1997.

8.   Quarterly monitoring data from Ecology
    and Environment, Inc. (1996-1997).

9.   Monthly treatment unit data from LEU.
    (January 1996 - September 1997) Data
    supplied by Rich Lange, IEPA.
This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
Emergency Response, Technology Innovation Office.  Assistance was provided by Eastern Research
Group, Inc. and Tetra Tech EM Inc. under EPA Contract No. 68-W4-0004.
      EPA
            U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
    	Technology Innovation Office
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Pump and Treat of Contaminated Groundwater at
  the Mid-South Wood Products Superfund Site,
               Mena, Arkansas
                     111

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                   Pump and Treat of Contaminated Groundwater at
                     the Mid-South Wood Products Superfund Site,
                                      Mena, Arkansas
Site Name:
Mid-South Wood Products
Superfund Site
Location:
Mena, Arkansas
Contaminants:
Semivolatiles - halogenated:
pentachlorophenol (PCP); PAHs;
heavy metals (chromium); and
nonmetallic elements (arsenic)
- Maximum concentrations
detected during RI include PCP
(10,230 ug/L), fluoranthene (263
ug/L), chrysene (37 ug/L),
benzo(a)anthracene (35 ug/L), Cr
(183 ug/L), and As (18 ug/L)
Period of Operation:
Status: Ongoing
Report covers: 9/89 - 12/97
Cleanup Type:
Full-scale cleanup (interim results)
Vendor:
Bill Fletcher
B&F Engineering, Inc.
928 Airport Road
Hot Springs National Park, AR
71913
(501) 767-2366
State Point of Contact:
Mike Arjmandi
Arkansas Department of Pollution
Control & Ecology
P.O. Box 8913
8001 National Drive
Little Rock, AR 72219-8913
(501) 682-0852
Technology:
Pump and Treat
- Groundwater is extracted using
15 wells, at an average total
pumping rate of 24 gpm
- Extracted groundwater is treated
with oil/water separation, filtration,
and carbon adsorption, and
discharged to a surface water under
a NPDES permit
Cleanup Authority:
CERCLA Remedial
-ROD Date: 11/14/86
EPA Point of Contact:
Shawn Ghose, RPM
U.S. EPA Region 6
(6SF-AP)
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 665-6782
Waste Source:
Improper disposal, on-site spills
Purpose/Significance of
Application:
Groundwater contaminated with
wood treating chemicals; system
optimization performed after eight
years of operation; groundwater
contamination had been reduced to
one localized area of concern.
Type/Quantity of Media Treated:
Groundwater
- 100.6 million gallons treated as of December 1997
- DNAPL and LNAPL observed in groundwater at the site
- Extraction wells are located in 2 aquifers
- Hydraulic conductivities were not provided for this site
Regulatory Requirements/Cleanup Goals:
- The cleanup goal stated in the ROD was to treat the groundwater contamination to levels that posed no health
  or environmental risk.  Remedial goals were specified for PCP (0.20 mg/L), benzo(a)anthracene (0.01 mg/L),
  benzo(a)pyrene (0.01 mg/L), benzo(b+k)fluoranthene (0.01 mg/L), chrysene (0.01 mg/L), arsenic (0.05 mg/L),
  and chromium (0.05 mg/L).
- The performance goal for the recovery system was to provide containment of the plume on site.
                                              112

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                  Pump and Treat of Contaminated Groundwater at
                     the Mid-South Wood Products Superfund Site,
                               Mena, Arkansas (continued)
Results:
- Groundwater contamination has been reduced to one localized area of concern.  Between April 1989 and May
  1996, average concentrations of total contaminants in the groundwater were reduced 32%, from 0.14 to 0.09
  mg/L, with concentrations of contaminants reduced to below cleanup goals in 29 of 35 wells monitored in May
  1996. It is estimated that the pump and treat system will operate for a minimum of five more years to reach the
  specified goals.
- Monitoring data indicate that the plume has been contained. Because contamination was found along rock
  fractures and not in a continuous plume, plume size reduction could not be measured. During the first seven
  years of operation, 363 kg of PCP were removed by the system; data were not provided to estimate mass
  removal for other contaminants.                                                                	
Cost:
- Estimated costs for pump and treat were $1,212,600 ($465,300 in capital and $747,300 in O&M), which
  correspond to $13 per 1,000 gallons of groundwater extracted and $1,500 per pound of PCP contaminant
  removed.
Description:
The Mid-South Wood Products site was originally developed in the late 1930s to produce untreated wood posts.
In 1955, the facility added pressure treating to its process, and from 1967 to 1977, the site was operated as a PCP
and creosote wood treatment facility. In 1977, the PCP plant was abandoned and a new plant was built to treat
the lumber with a chromated copper arsenate (CCA) wood treating process. From 1978 to 1981, the Arkansas
Department of Pollution Control & Environment sampled drinking wells near the site, investigating the source of
a fish kill that occurred in November 1976. The source was ultimately determined to be an unauthorized release
of wastewater from a waste pond at the site. Further contamination of the site resulted when liquids and sludge
from the pond were sprayed on and around land farm areas at the site.  The site was placed on the NPL in 1983
and a ROD was signed in November 1986.

An interim extraction system was built in late 1984 and operated from early 1985 until 1989. The system
consisted of three pairs of extraction wells and French drains, and was designed to collect contaminated
groundwater from shallow depths where flow and contamination were expected to be the greatest. An expanded
extraction system, which began operating in the summer of 1989, consisted of nine shallow extraction wells and
six deep extraction wells (drilled into bedrock formations at depths up to 170 ft bgs). In February 1997, three
major changes were made to optimize system operations. Five recovery wells were removed from operation, five
other wells began a period of on-off operation (three months on, three months off), and the sampling frequency
for 12 monitoring wells was decreased. Groundwater contamination at the site has been reduced but has not yet
met all remedial goals. It is estimated that the pump and treat system will operate for a minimum of five more
vears to reach the snecified coals.                                                   	_^
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                                                         Mid-South Wood Products Superfund Site
                                    SITE INFORMATION
 identifying Information:
 Mid-South Wood Products Superfund Site
 Mena, Arkansas

 CERCLIS#: ARD092916188

 ROD Date: November 14,1986
Treatment Application:
Type of Action:  Remedial

Period of operation: September 1989 -
Ongoing
(Performance data collected through December
1996; pumping data collected through
December 1997)

Quantity of groundwater treated during
application: 100.6 million gallons through
December 1997
Background
Historical Activity that Generated
Contamination at the Site: Wood treatment
facility

Corresponding SIC Code: 2491 (Wood
Preserving)

Waste Management Practice That
Contributed to Contamination: Improper
disposal, on-site spills

Location: Mena, Arkansas

Facility Operations:  [2 3]
•   The Mid-South Wood Products site is
    located on 57 acres in western Arkansas.
    Several streams flow through the site,
    feeding either the Ouachita or the Little
    Rivers. Previously, there were 14 private
    drinking wells nearby, serving the 18
    properties adjacent to the site. Currently
    public water serves the site.

•   The site was originally developed in the late
    1930s to produce untreated wood posts. In
    1955, the facility added pressure treating to
    its process. From 1967 to 1977, the site was
    operated as a pentachlorophenol (PCP) and
    creosote wood treatment facility.  In 1977,
    the PCP  plant was abandoned and a new
    plant was built to treat the lumber with a
    chromated copper arsenate (CCA) wood-
    treating process.

•   The site includes the old wood treatment
    plant, an unlined waste pond, and two land
    farms. The waste pond was a collection
      EPA
   basin for the waste from the PCP and
   creosote treatment processes.

   From 1978 to 1981, the Arkansas
   Department of Pollution Control &
   Environment (ADPC&E) sampled drinking
   wells near the site, investigating the source
   of a fish kill that occurred in November
   1976. The source was ultimately
   determined to be an unauthorized release of
   wastewater from the waste pond.

   In 1978, an unsuccessful attempt was made
   to close the waste pond. Further
   contamination of the site resulted when
   liquids and sludge from the pond were
   sprayed on and around the land farm areas.
   A portion of the contaminated land farm
   soils were  placed back into the waste pond
   as fill [2].

   An Administrative Order (AO) was issued by
   ADPC&E in March 1983 that directed the
   PRPs to perform short-term remedial
   actions and conduct a full site investigation.

   The site was placed on the NPL in 1983.

   EPA conducted a Remedial Investigation/
   Feasibility  Study (RI/FS) and a
   supplemental remedial investigation (SRI)
   of the CCA plant area in 1984 and 1986,
   respectively. The results of the
   investigations showed that the area around
   the CCA treatment plant was contaminated
   by spills of the wood treatment products
           U.S. Environmental Protection Agency
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                                                        Mid-South Wood Products Superfund Site
                              SITE INFORMATION (CONT.)
Rarknrnunri /Cont.}
   and the unlined waste pond was
   contaminated by the disposal of wood
   treatment wastes.

•  Groundwater samples collected during the
   RI/FS and the SRI from wells located
   around the waste pond, land farms, and
   CCA plant showed high concentrations of
   PCP. Lower concentrations of  arsenic and
   chromium also were found in the
   groundwater.

•  As specified in the Record of Decision
   (ROD), the contaminated soils  from the
   waste pond and the old plant area were
   excavated for source control, stabilized, and
   consolidated in the waste pond. All other
   contaminated soil from the site was
   consolidated in one of the land farms. The
   waste pond and land farm were then capped
   with clay, sand, and topsoil to prevent
   further contamination of the groundwater.

Regulatory Context:
•   EPA signed  the final ROD for this site in
    September 1986.  The ROD addressed both
    soil and groundwater actions.
                                                 •   A Consent Decree was signed by the two
                                                    identified Potentially Responsible Parties
                                                    (PRPs) and entered in the Arkansas District
                                                    Court on May 16,1987.

                                                 •   Site activities are conducted under
                                                    provisions of the Comprehensive
                                                    Environmental Response, Compensation,
                                                    and Liability Act (CERCLA) of 1980, as
                                                    amended by the Superfund Amendments
                                                    and Reauthorization Act (SARA) of 1986
                                                    §121, and the National Contingency Plan
                                                    (NCP), 40 CFR 300.

                                                    National Pollutant Discharge  Elimination
                                                    System (NPDES) permits were required to
                                                    discharge treated groundwater to surface
                                                    drains.

                                                 Groundwater Remedy Selection:
                                                 Groundwater extraction and treatment via
                                                 carbon adsorption was selected as the remedy
                                                 for this site.
Site Lead: PRP

Oversight: EPA

Remedial Project Manager:
Shawn Ghose*
U.S. EPA Region VI (6SF-AP)
First Interstate Bank Tower at Fountain Place
1445 Ross Avenue 12th Floor Suite 1200
Dallas, TX 75202-2733
(214) 665-6782
                                                 State Contact:
                                                 Mike Arjmandi
                                                 Arkansas Department of Pollution Control &
                                                 Ecology
                                                 P.O. Box8913
                                                 8001 National Drive
                                                 Little Rock, AR 72219-8913
                                                 (501) 682-0852

                                                 Treatment System Consultant:
                                                 Bill Fletcher*
                                                 B&F Engineering, Inc.
                                                 928 Airport Road
                                                 Hot Springs National Park, AR 71913
                                                 (501)767-2366
 Indicates primary contacts
       EPA
                                                             U.S. Environmental Protection Agency
                                                     Office of Solid Waste and Emergency Response
                                                                    Technology Innovation Office
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                                                         Mid-South Wood Products Superfund Site
                                  MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed Through the
Treatment System: Groundwater

Contaminant Characterization l"1. 2. 61
Primary Contaminant Groups: Semivolatile
organic compounds and inorganics

•   The contaminants of concern at the site are
    PCP, chromium, arsenic, and polynuclear
    aromatic hydrocarbons (PAHs), including
    benzo(b+k)fluoranthene, chrysene, and
    benzo(a)anthracene [1].

•   The maximum concentrations detected in
    shallow groundwater during the Rl include
    PCP (10,230 ug/L), chromium (183 |jg/L),
    arsenic (18 ug/L), fluoranthene (263 M9/L),
    chrysene (37 ug/L), and benzo(a)anthracene
    (35 ug/L) [1].

•   No samples were taken of the groundwater
    in the underlying bedrock unit during the Rl,
    as additional study of the deep
    contamination was considered to be too
    costly, given the complexity of the
    hydrogeology. However, a sampling event
    in 1990 (after remedial operations began)
    revealed significant contamination in a well
    drilled to 172 feet below ground surface.
The presence of light nonaqueous phase
liquid (LNAPL) contamination by carrier oils
has been observed directly [2].  In addition,
fluoranthene and PCP were detected at
concentrations at or greater than 60% of
their aqueous solubility, suggesting the
presence of dense nonaqueous phase
liquids (DNAPLs). As noted above, while
confined to the upper portion of the bedrock,
DNAPLs were subsequently found at depths
of 172 feet during deep drilling [2].  Figure 1
illustrates site layout and the location of
monitoring wells. The monitoring wells are
located primarily around the land farm and
the old pond.

Contaminants have been found only along
fractures in rock along the fault line;
therefore no continuous contaminant plume
was defined. Thus, no plume map or
volume estimate was generated.
      EPA
         U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
	Technology Innovation Office
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                                                 Mid-South Wood Products Superfund Site
                      MATRIX DESCRIPTION (CONT.)
                                                                                e
                                                                                §
                                                                                a.
                                                                                3
                                                                                vt
                                                                             ill
             Figure 1. Site Map (November 1995, Best Copy Available) [6]
EPA
        U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
  	Technology Innovation Office
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                                                         Mid-South Wood Products Superfund Site
                             MATRIX DESCRIPTION (CONT.)
Matrix Characteristics Affecting Treatment Costs or Performance
Hydrogeology [1,2]:

One distinct hydrogeologic unit has been identified beneath this site. This unit has two separate geologic
features: a thin layer of sandy, gravelly material overlying the sandstone bedrock of the Mississipian
Age formation.  A fault zone in the bedrock runs west to east and passes under the old waste pond.  The
fault zone is characterized by highly fractured shales and influences groundwater flow patterns by
creating a highly permeable zone within the bedrock.  Groundwater flows primarily to the west-northwest,
except in the eastern two-thirds of the site, where it flows westerly to southwesterly. Groundwater flow
velocity along the fault is approximately 20 ft/yr, or 0.055 ft/day.  Higher velocities of 30 to 60 ft/yr have
been observed along the slopes of the site.
 Unitl
Overburden Aquifer
 Unit 2
Bedrock Aquifer
                                Consists of 1 to 10 feet of silt, sand, and clay with gravel.
                                The gravel consists primarily of angular rock fragments. The
                                saturated zone in soil exists 1 to 9 feet above the lower
                                bedrock formation.

                                Consists of consolidated sandstone and shale bedrock.
                                Groundwater mainly occurs in the joints, fractures, and
                                bedding planes. Depth of water within the bedrock unit is
                                generally 30 feet, with infiltration into deeper zones to depths
                                of 172 feet.

Tables 1 and 2 present technical aquifer information and well data, respectively.

                             Table 1: Technical Aquifer Information
Unit Name
Overburden Aquifer
Bedrock Aquifer
Thickness
(ft)
1 -10
>10
Conductivity
(ft/day)
NA
NA
Average
Velocity
(ft/day)
0.055
0.082
Flow Direction
West-Northwest
West-Northwest
Source: [2]
                           TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology

Pump and treat with liquid-phase carbon
treatment
                                      Supplemental Treatment Technology

                                      Oil/water separator
      EPA
                                                  U.S. Environmental Protection Agency
                                          Office of Solid Waste and Emergency Response
                                         	Technology Innovation Office
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                                                          Mid-South Wood Products Superfund Site
                      TREATMENT; SYSTEM DESCRIPTION (CONT.)
System Description and Operation
                                  Table 2: Extraction Well Data
Well Name
RW-1.RW-2, RW-3,
RW-5, RW-6, RW-7,
RW-8, RW-9, RW-15
RW-4, RW-10, RW-11,
RW-12, RW-13, RW-14
Unit Name
Overburden Aquifer*
Bedrock Aquifer
Depth (ft)
12.8-23.4
21 - 170
Yield (gal/day)
8.7-3,216
4,167-8,487
 *Overburden wells are screened within a French drain.

Source: [2]

System Description
•   In response to the 1983 AO, an interim
    extraction system was built in late 1984 and
    operated from early 1985 until 1989. The
    system consisted of three pairs of extraction
    wells and French drains.  Each well was
    screened in a drain. The system  was
    designed to collect contaminated
    groundwater from shallow depths where flow
    and contamination were expected to be the
    greatest [2]. Table 2 presents extraction
    well data.

•   The 1986 ROD specified an expansion of
    the existing system as the final groundwater
    remedy. This expanded extraction system,
    which began operating in the summer of
    1989, consisted of nine extraction wells
    (including the original three sets of drains),
    screened in eight French drains, and six
    deep extraction wells drilled into the
    bedrock formation to depths up to 170 feet
    [2].

•   The original three French drains,  installed in
    1984, are located on a NW/SE axis across
    the site along the fault zone. Three of the
    five drains installed in 1989 are located
    along the same fault line, and two were
    installed downgradient of the old pond area
    [2].

•   The French drain trenches were excavated
    to the depth of  backhoe refusal at the top of
    the bedrock, which was approximately 15
feet. The bottom of the drains is filled with
4-inch pea gravel to a depth of one foot.
The pea gravel is covered with
approximately two feet of Vz- to 11/a-inch
gravel, and the ditch is backfilled with
clay [10].

Five of the six drilled  wells are located
along the same axis as the original drains,
and are installed close to, or in between, the
three original French drains. The remaining
drilled well was installed on the southwest
corner of the land farm area [6].

Recovery wells RW-2, 4, 6, 12, and 13 were
closed February 1,1997 as recommended
in the 1995 Annual Report with approval
from EPA.  Recovery wells RW-3,5,9,10,
and 14 began the on/off period [12].

Extracted water is pumped through force
mains to an oil/water separator and then to
a storage tank. The water is then pumped
through fabric filters to remove suspended
solids and treated by carbon adsorption to
remove organics. Treated groundwater is
discharged to storm drains through two
outfalls under an NPDES permit [2].

The carbon treatment system consists of
two parallel lines, each with two 2,000-
pound canisters in series, to treat organics
[2].  •
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                                                         Mid-South Wood Products Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
Svstem Description and Operation (Cont.)
•   An additional carbon treatment system was
    added in October 1996 to treat metals-
    contaminated groundwater from RW-15,
    located near the CCA plant. Originally, the
    contaminated groundwater from RW-15 was
    used as make-up water in the CCA plant.
    As plant operations declined in 1996, so did
    the demand for make-up water. Therefore,
    the new carbon treatment system was
    added to treat this water prior to discharge.
    The new system consists of two parallel
    lines, each with two  180-pound canisters set
    in series.  The carbon system was used for
    less than one year.  Plant operations
    resumed in 1997, and the water extracted
    from RW-15 was returned to use in plant
    operations [9].

•   A network of six monitoring wells, along with
    the remaining recovery wells, is used to
    monitor changes in groundwater quality and
    water levels annually [7].

•   The remaining 12 monitoring wells went
    from annual sampling to 5-year sampling as
    recommended in the 1995 Annual Report
    with approval from EPA [6].

System Operation
•   Under the provisions of the 1983 AO, the
    interim treatment system operated from
    1985 until 1989, when it was expanded.
    The final remedy began operation in
    September 1989. This report addresses the
    final remedy [2].

•   Quantity of groundwater pumped from the
    bedrock and overburden aquifers in gallons
    is shown below [4,5,6,7].

    Year      Volume Pumped (gallons)
    1989              4,752,300
    1990             12,691,050
    1991             10,165,250
    1992             14,676,650
    1993             11,607,000
    1994             19,958,200
    1995             11,430,140
    1996             12,557,350
Approximately 40,000 pounds of carbon
were used from September 1989 until
December 1996.  The canisters have been
changed nine times since the start of the
operation. The average volume of water
treated by each canister was approximately
10 million gallons. [5,6,7]

In June 1995, a Five Year Evaluation of the
site was performed.

The oil/water separator extracts small
quantities of oil.  From September 1992 to
December 1995, two 55-gaIlon drums of oil
were extracted from the groundwater [6].

In late 1996, the site engineer reported that
free oils had been detected in piezometer
IWE, located near the two farthest
downgradient recovery wells, RW-3 and
RW-14. No concentrations of contaminants
above detection limits have been detected
in the recovery wells since 1990. The
piezometer IWE was drilled prior to
recovery well installation. Once IWE was in
place, the casing may have trapped
DNAPL, blocking the recovery wells'
subsequent zones of influence. [7,9]

In February 1997, three major changes were
made to optimize system operations. First,
five recovery wells in which no
contaminants had been found above
remedial  goals for the past four years were
removed  from operation.  Second, five
other recovery wells meeting the same
criteria for a period  of the last three years
began a period of on-off operation (three
months on, three months off). Finally, the
sampling frequency for 12 monitoring wells
was decreased to once every five years.
These wells have either a history of
contaminant levels  below detection limits or
are in close proximity to wells that will
continue to be sampled annually [9].
      EPA
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                                                        Mid-South Wood Products Superfund Site
                     TREATMENT ;SYSTEM DESCRIPTION (CONT.)
System Description and Operation fCont.)
       An additional recovery well is planned
       near the waste pond. Monitoring well
       data have shown that contaminants in
       the groundwater in this area were not
       being remediated as quickly as other
       areas of the site [7].
Monitoring wells M-17 (near CCA Plant) and
MW-19 (near Old Pond) are scheduled to be
over drilled in June 1998 and replaced with
recovery wells. IWE will be over drilled and
plugged.
Operating Parameters Affecting Treatment Cost or Performance
Table 3 presents the major operating parameters affecting cost or performance for this technology.
                                Table 3: Performance Parameters
H -/"r, -?< :£$aii£j*r -^r^' •
Average Pump Rate
Performance Standard (effluent)
(in mg/L)
Remedial Goal (aquifer)
(in mg/L)
fcr'to. • 3S8i<$? Jf;S
24gpm
NPDES effluent limitations
Arsenic
Chromium
Naphthalene
Fluoranthene
PCP
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b+k)fluoranthene
Chrysene
Arsenic
Chromium
0.050
0.050
2.30
3.98
0.20
0.01
0.01
0.01
0.01
0.05
0.05
              Source: [2]
Timeline
Table 4 presents a timeline for this remedial project.

                                   Table 4: Project Timeline
-ISfcrfDite J
1984
11/86
12/86
1989
6/95
10/96
2/97
End Date.
1989
...
7/89
ongoing
—
„.
—
•"*' /•//• *" .iT-'" ,:" Ao«^t ;"V ^ . ' *'_,"" ' 2 '•
Interim extraction system built and operated
Record of Decision signed
Remedial design and construction performed
Final extraction system operational
Five Year evaluation
RW-1 5 brought into treatment network, and two additional carbon filters to treat metals added to
treatment system
System optimization performed
Source: [2]
      EPA
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                                                        Mid-South Wood Products Superfund Site
                         TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards l"l. 51
   The cleanup goal stated in the ROD was to
   treat the groundwater contamination to
   levels that posed no health or
   environmental risk. This goal is to be
   achieved throughout the on-site aquifer.
The cleanup goal for PCP was equal to the
EPA reference dose. Goals for
benzo(a)pyrene, benzo(a)anthracene,
benzo(b+k) fluoranthene, and chrysene
were set at the respective detection limits.
Goals for arsenic and chromium were set at
the maximum contaminant level (MCL)
stipulated in 40 CFR 264.94, as listed in
Table 3.
Treatment Performance Goals Ml
•   The goal of the treatment system is to
    reduce effluent contaminant concentrations
    to meet NPDES permit requirements.

Performance Data Assessment T4. 5. 6. 71
The goal of the recovery system is to
contain the plume on site.
For the purpose of this report, total
contaminants includes arsenic, PCP, chromium,
and total PAHs.

•   Groundwater contamination has been
    reduced to one localized area of concern.
    The wells on the western portion have
    recorded contaminant levels below
    detection limits. RW-15 and other wells
    located around the CCA plant and pond
    area still show contaminant levels above the
    remedial goals.

•   Between April 1989 and May 1996, average
    concentrations of total contaminants in the
    groundwater were reduced 32%, from 0.14
    mg/L to 0.09 mg/L Over this same period,
    average arsenic concentrations increased
    20%, from  0.0030 mg/L to 0.0036 mg/L.
    Average PCP levels decreased 50%, from
    0.022 mg/L to 0.011 mg/L.  Average
    chromium concentrations decreased 83%,
    from 0.030 mg/L to 0.005 mg/L. Total PAHs
    decreased 34%, from 0.035 mg/L to 0.023
    mg/L.  Contaminant concentrations in some
    individual wells remain above remedial
    goals.

•   PCP concentrations detected during the
    May 1996 monitoring were above the
    cleanup goal of 0.10 mg/L in five wells
(RW-1, RW-7, RW-8, RW-15, and M-17).
The maximum concentration of PCP
detected in May 1996 was 6.6 mg/L (in RW-
15, near the former CCA plant). Elevated
levels of PCP also showed in the wells near
the former pond area (RW-1, RW-7, RW-8,
and M-17).  Figure 2 illustrates that the PCP
concentrations in the monitoring wells near
the pond area have declined, but remain
above the cleanup goal of 0.10 mg/L.

Concentrations of contaminants detected in
the May 1996 monitoring were below
remedial goals in all but six of the 35 wells
monitored. Arsenic concentrations were
above the remedial goal of 0.05 mg/L in
only one well (RW-15) at 0.69 mg/L.
Chromium concentrations were above the
remedial goal of 0.05 mg/L in only one well
(RW-15) at 0.13 mg/L.  Total PAHs
concentrations were above the combined
remedial goal of 0.40 mg/L in only one well
(IWB-170) at 1.18 mg/L.  The plume of
total contaminants is concentrated in the
former CCA plant area, in RW-15 and IWB-
170. Figure 3 illustrates that the
concentrations of PCP, chromium, and
arsenic in RW-15 have declined since
January 1991, but remain above the
respective remedial goals.
      EPA
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                                                         Mid-South Wood Products Superfund Site
                     TREATMENT $YSTEM PERFORMANCE (CONT.)
Performance Data Assessment (ConU
•   RW-15 remains the well with the highest
    levels of contaminants, specifically arsenic,
    chromium, and PCP. This well is located
    100 feet downgradient of the CCA plant and
    upgradient of the pond area. The
    contamination found in this well reflects its
    proximity to both the CCA plant and the
    location of the old PCP plant. Overall,
    contaminant concentrations in this well have
    decreased during remedial operations (see
    Figure 3). Reasons for the sharp spikes in
    concentrations seen in both the first quarter
    of 1990 and the third quarter of 1991 are not
    known [9]. By the secopd quarter in 1996,
    concentrations of all three of the
    contaminants remained above remedial
    goals [7].

•   The monitoring data for the wells
    downgradient of the land farm show that the
    concentrations of all contaminants remained
    below detection levels, indicating successful
    plume containment. Moreover, monitoring
    results from wells placed downgradient of
    the pond area but upgradient of the land
    farm show no evidence that contamination
    is moving between the two areas.

    Monitoring data have indicated that the area
    of contamination has decreased in size.
    The site operators have recommended that
    wells  in the western portion of the site be
    either removed from service or operated on
    an on-off basis. The remaining wells around
    the waste pond still show contaminant levels
    higher than cleanup goals. It is estimated
    that the P&T system will operate for a
    minimum of five more years to reach the
    specified goals.

Performance Data Completeness	
Because contamination was found along
rock fractures and not in a continuous
plume, plume size reduction cannot be
measured.

NPDES limits have been exceeded six
times for hazardous pollutants (arsenic or
chromium) from July 1989 through
December 1996. Only one out of the six
exceedances was from Outfall 001, the
treated groundwater. The other
exceedances were at a stormwater outfall.
Over the same period, effluent samples
failed once for Seven-Day Renewal Chronic
Toxicity to Certiodaphia and 10 times for
reproduction criteria. Exceedances were
reported to the Arkansas Department of
Pollution Control and Ecology.  No process
changes were made.

Figure 4 presents the removal of
contaminants through the treatment system
from 1990 to 1996. Over this period, a total
of 93 million gallons of groundwater were
treated, at a daily average treatment rate of
24 gpm.

During the first seven years of operation,
the carbon filter system removed a total of
363 kg of PCP.  Other contaminants were
removed as well, but sufficient data were
not available to be able to estimate their
mass. Therefore, removal of total
contaminants is likely to be higher.

PCP removal rates, reported in annual
performance reports, declined from 0.39
kg/day in 1990 to 0.03 kg/day in 1995.
   The 18 monitoring wells and the 15
   recovery wells located at the site were
   monitored on an annual basis and reported
   in the annual report.

   The data used in Figures 3 and 4 were
   taken from the summary table in the 1996
   Annual Report [7].
Data for contaminant removal through the
carbon filter system were reported in the
1994 Annual Report and Five Year
Evaluation, the 1995 Annual Report, and
the 1996 Annual Report [4,6,7].
      EPA
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                                                   Mid-South Wood Products Superfund Site
                 TREATMENT SYSTEM PERFORMANCE (CONT.)
   0.001
       Dec-88     May-90     Sep-91     Jan-93      Jun-94
                          Oct-95
                          Mar-97
                            MW-17
•RW-1
RW-7 -x-RW-8
    Figure 2. PCP Concentrations in Wells Near Pond Area (April 1989 to May 1996) [4,5,6,7]
     100
 I

 •s    0.1
 O
 o
     0.01
    0.001
       -Arsenic (MCL=0.05 mg/L) —•—Chromium (MCL=0.05 mg/L) —A—PCP (MCL=0.20 mg/L)
Figure 3.  Contaminant Concentrations in RW-15, Near CCA Plant (April 1989 to May 1996) [4,5,6,7]
                                                        U.S. Environmental Protection Agency
                                                 Office of Solid Waste and Emergency Response
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                                                       Mid-South Wood Products Superfund Site
                    TREATMENT SYSTEM PERFORMANCE (CONT.)
                                                                                  400
                                                                                J-350
                                                                                  300 &
                                                                                  250 o
                                                                                     I
                                                                                  200
                                                                                  150 g
                                                                                  100 £
                                                                                      O
       1990
                   1991
1992
                                           1993
                        1994
                                                                   1995
                                                1996
                            • Mass Flux (kg/day)
               - Cum. Mass Removed (kg)
             Figure 4. Mass Flux Rate and Cumulative POP Removal (1990 to 1994) [5]
Performance Data Quality
The QA/QC program used throughout the remedial action met the EPA and the State of Arkansas
requirements. All monitoring was performed using EPA-approved methods, and the vendor did not note
any exceptions to the QA/QC protocols.
                                                            U.S. Environmental Protection Agency
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                                                    	Technology Innovation Office
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                                                                Mid-South Wood Products Superfund Site
                                   TREATMENT SYSTEM COST
Procurement Process
B&F Engineering provided remedial design services and has provided monitoring and reporting services
during the P&T operation period.  Rollins provided construction services and Mid-South Wood Products
(one of the two PRP's) has operated the P&T system.

Cost Analysis

All costs for design and construction and operation of the treatment system at this site were borne by the
PRPs.
Capital Costs T6T
 Remedial Construction and Design
 Mobilization, Bond & Insurance               $25,560
 Health and Safety                          $7,875
 French Drain Construction                  $95,100
 Recovery Well Casings                     $45,470
 Recovery Well Pumps                     $28,900
 Rock Excavation                          $11,393
 Cable                                  $26,818
 Treatment Plant                          $141,990
 RW-15 Well and Treatment Unit              $24,700
 Miscellaneous                            $57,470
 Total Site Cost                         $465,276*
•Does not Include stabilization, consolidation, and capping
costs for remediation of contaminated soils.
Operating Costs T6T
 Carbon Regeneration                      $100,100
 Sludge, Oil, Filter, etc. Disposal                $8,400
 Miscellaneous Pipe, Filters, etc.               $10,500
 Operating Labor Cost                       $54,600
 Contract Labor Cost                         $8,400
 Electrical Power Cost                       $33,600
 Analysis, Reporting, and Monitoring           $395,800
 Annual Report                            $24,500
 Five Year Evaluation                        $14,000
 Carbon Canister Replacement                $45,000
 Pump Replacement                        $17,200
 Meter Replacement                         $2,600
 Electrical Controls Replacement               $6,600
 Filter Replacement                         $4,000
 Operator Training Cost                      $4,000
 Contingency Fund                         $18,000
 Estimated Total Operating Expenses       $747,300
 Through 1996
Note: Operating costs are based on annual cost estimates
provided by B&F Engineering.
Annual Costs [81
1990
1991
1992
1993
1994
1995
1996
Cost Data Quality

$136,350
$103,350
$88,350
$90,350
$88,750
$152,000
$88,150

Estimated capital and operating and maintenance cost data are available from the system operator for
this application.
       EPA
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                                                      Mid-South Wood Products Superfund Site
                    OBSERVATIONS AND LESSONS LEARNED
The site engineer identified one change
order for the original groundwater treatment
system construction contract, totaling
$9,966.

Estimated costs for the P&T treatment
application at Mid-South were
approximately $1,212,600, consisting of
$465,300 in capital costs and $747,300 in
cumulative operating and maintenance
costs through 1996 [8]. This corresponds to
unit costs of $13 per 1,000 gallons treated
and $3,330 per kg PCP removed ($4,510
per pound PCP removed).

The use of fabric filters to remove
suspended solids has increased the
operating life of the carbon filters. The high
rate of changeout for the fabric filters has
not added a significant level of effort to
routine operations [8].

The increase in mass flux seen in 1993 may
be attributed to an increase in precipitation
during the year.  The increased precipitation
could have accelerated groundwater flows,
which would then cause a contaminant level
increase in the recovery wells.
DNAPLs have been visually observed from
a drilled well at 172 feet of depth.  The
presence of DNAPL at the site also is
suggested by fluoromethane,
benzo(a)anthracene, and chrysene being
detected at concentrations 60%, 63%, and
30% of their aqueous solubility,
respectively. Similarly,  PCP was detected
at concentrations greater than its aqueous
solubility.  Further, a monitoring well near
the waste pond has shown persistent
elevated contaminant concentrations when
compared to the other wells at the site [2,4].

Initially, French drains were chosen to
recover groundwater because engineers
believed that the fractured nature of the
bedrock would result in  low yields from a
system composed only of drilled extraction
wells. Actual experience at this site has
shown that the extraction rates from the
French drains are much lower than those
from the drilled extraction wells, and that
pumping from the drilled wells has
significantly changed groundwater flow
patterns at the site [6].
    EPA
          U.S. Environmental Protection Agency
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                 Technology Innovation Office
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                                                        Mid-South Wood Products Superfund Site
                                      REFERENCES
1.  Superfund Record of Decision. Mid-South
    Wood Products, Mena, Arkansas,
    November 1986.

2.  Case Studies and Updates. U.S. EPA,
    "Case Study 20, Mid-South Wood
    Products," March 25,1992.

3.  Superfund Site Status Summaries. U.S.
    EPA, "Mid-South Wood Products,"
    http://www.epa.gov/earth1r6/6sf/midsouth,
    April 30,1997.

4.  Superfund Remediation 1994 Annual Report
    & Five Year Evaluation. Mid-South
    Superfund Site, B&F Engineering, Inc., June
    1995.

5.  Superfund Remediation 1989-1990 Annual
    Report. Mid-South Superfund Site, B&F
    Engineering, Inc., May 1991.
Analysis Preparation
6.  1995 Annual Report. B&F Engineering, Inc.,
    October 1996.

7.  1996 Annual Report. B&F Engineering, Inc.,
    February 1997.

8.  Cost estimates provided by
    Linda McCormick, B&F Engineering, Inc.,
    June 1997.

9.  Telephone conversation with
    Linda McCormick, B&F Engineering, Inc.,
    October 6, 1997.

10.  Personal Communication with
    Linda McCormick, B&F Engineering, Inc.,
    October 16, 1997.

11.  Comments on Draft Report, provided by
    Linda McCormick, B&F Engineering, Inc.,
    June 1998.

12.  Operations and Maintenance Manual. B&F
    Engineering, Inc., January 1997.
This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
Emergency Response, Technology Innovation Office. Assistance was provided by Eastern Research
Group, Inc. and Tetra Tech EM Inc. under EPA Contract No. 68-W4-0004.
      EPA
           U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
                   Technology Innovation Office
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Pump and Treat of Contaminated Groundwater at
  the Odessa Chromium I Superfund Site, OU 2
               Odessa, Texas
                    129

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                   Pump and Treat of Contaminated Groundwater at
                      the Odessa Chromium I Superfund Site, OU 2
                                         Odessa, Texas
 Site Name:
 Odessa Chromium I Superfund
 Site, Operable Unit 2 (OU 2)
 Location:
 Odessa, Texas
 Contaminants:
 Heavy Metals (Chromium)
 - Maximum concentration of Cr
 detected during 1985 sampling
 event was 72 mg/L
Period of Operation:
Status: Ongoing
Report covers:  11/93 - 1/98
Cleanup Type:
Full-scale cleanup (interim results)
 Vendor:
 Design and Management: IT
 Corporation (ITC)
 Construction and Oversight:
 WATEC
 State Point of Contact:
 Lei Medford
 Texas Natural Resources
 Conservation Commission
 P.O. Box 13087
 Austin, TX 78711
 (512)239-2440
Technology:
Pump and Treat
- Groundwater is extracted using 6
wells at an average total pumping
rate of 60 gpm
- Extracted groundwater is treated
for Cr removal with chemical
treatment (ferrous ion, produced on
site), pH adjustment, flocculation,
precipitation, and multimedia
filtration
- Treated groundwater is reinjected
through 6 injection wells
Cleanup Authority:
CERCLA Remedial
-RODDate: 9/8/86
EPA Point of Contact:
Ernest Franke, RPM
U.S. EPA Region 6
First Interstate Bank Tower at
Fountain Place
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214)655-8521
 Waste Source:
 Improper disposal practices
Purpose/Significance of
Application:
Includes on-site treatment for
chromium; relatively low
groundwater flow; contamination
in one aquifer
Type/Quantity of Media Treated:
Groundwater
- 125 million gallons treated as of January 1998
- Groundwater is found at 30-45 ft bgs
- Extraction wells are located in 1 aquifer, which is influenced by
production wells in the area
- Hydraulic conductivity ranges from 1.7 to 5.1 ft/day
Regulatory Requirements/Cleanup Goals:
- Remediate groundwater so that chromium levels are less than the maximum contaminant level (MCL) or
  primary drinking water standard.
- Prior to 1990, the drinking water standard for chromium was 0.05 mg/L; in 1990, EPA revised the drinking
  water standard to 0.10 mg/L.
- Treated effluent that is reinjected into the aquifer must have a chromium level of less than 0.05 mg/L.
- The remedial system was required to create an inward gradient toward the site to contain the plume.
Results:
- Groundwater monitoring results indicate that chromium concentrations have been reduced compared to initial
  levels, but not to levels below the cleanup goal of 0.10 mg/L.
  Average chromium concentrations were reduced by 48% from January 1992 to January 1997.
  From December 1993 to 1996, 1,143 pounds of chromium have been removed from the groundwater.
  Treated effluent has met the required performance standard throughout treatment.
  Plume containment has been achieved since 1995; this was achieved after two monitoring wells were
  converted to recovery wells, and two other recovery wells were taken offline.
                                              130

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                  Pump and Treat of Contaminated Groundwater at
                     the Odessa Chromium I Superfund Site, OU 2
                                 Odessa, Texas (continued)
Cost:
- Actual costs for the P&T application were approximately $2,742,000 ($1,954,000 in capital and $728,000 in
  O&M), which correspond to $30 per 1,000 gallons of groundwater extracted and $2,400 per pound of
  contaminant removed.
- The ROD specified that the ferrous iron used in the treatment system be produced electrochemically, which
  limited the number of vendors to two and potentially increased the cost of the treatment system.
- The costs for design, construction, and operation of the P&T system were split 90:10 by EPA and TNRCC,
  respectively.
Description:
Metal plating and chrome plating facilities operated at this site from 1954 to 1977, producing chromium- and
other metals-containing wastewater. In 1977, the TNRCC investigated citizen complaints of poor drinking water
quality in private wells and discovered elevated levels of chromium in the groundwater. The chromium
contamination was attributed to the discharge of chromium-containing wastewater into unlined dirt ponds,
directly to the soils, and into a septic tank drain field; contaminants also are suspected to have migrated to the
aquifer through an abandoned open well bore on the site.  The Odessa I  site was added to the NPL in September
1984, and a ROD for OU 2 was signed in September  1986. OU 1, not addressed by this case study, concerned
providing for an alternate water supply to replace water previously supplied by contaminated wells.

The extraction system used at this site consisted of six extraction wells constructed in the Trinity Sand Aquifer to
a depth of 138 ft bgs, each with a design yield of 14,400 gpd.  Extracted groundwater was treated with ferrous
iron (produced on site in an electrochemical cell), pH adjustment and aeration, clarification, and multi-media
filtration. While chromium concentrations have been reduced to below  the MCL in three wells, as of December
1996, groundwater cleanup goals have not been achieved throughout the site.

There were several startup problems that delayed full-scale operation at this site, including clogging of injection
wells and filters by iron and calcium. These problems were solved through system modification and no longer
interfere with operations.
                                                131

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                                                              Odessa Chromium I Superfund Site
                                   SITE INFORMATION
Identifying Information;
Odessa Chromium I Superfund Site
Operable Unit 2 (OU 2)
Odessa, Texas

CERCLIS#: TXD980867279

ROD Date for OU2: September 8,1986
Background M. 2. 31
Treatment Application:
Type of Action:  Remedial

Period of operation:  11/93 - Ongoing
(Monitoring and mass removal data collected
through December 1996)
(Data on volume treated collected through
January 1998)

Quantity of material treated during
application: 125 million through January 1998
Historical Activity that Generated
Contamination at the Site:  Metals plating

Corresponding SIC Code: 3471, Plating of
Metals

Waste Management Practice That
Contributed to Contamination: Improper
disposal practices

Location: Odessa, Texas

Facility Operations:
•   In 1977, the Texas Natural Resources
    Conservation Commission (TNRCC)
    investigated citizen complaints of poor
    drinking water quality in private wells and
    discovered elevated levels of chromium in
    the groundwater. The 0.4-acre facility at
    4318 Brazos Avenue was identified by EPA
    as the source of chromium contamination.

*   Metals plating and chrome plating facilities
    operated at the site from 1954 to 1977,
    producing chromium and other metals-
    containing wastewater.  Operations at the
    site ceased in 1977.

•   High levels of chromium were detected in
    the soil and groundwater. The chromium
    contamination was caused by discharge of
    chromium-containing wastewater into
    unlined dirt ponds, directly to the soils, and
    into a septic tank drain field. Contaminants
    are also suspected to have migrated into the
    aquifer through an abandoned open well
    bore on the site.
    In 1984, the building, foundation, and soils
    contaminated with chromium were
    excavated and disposed. Shallow soils,
    down to approximately two feet, were
    removed. The remaining soils at the site
    were found to contain other heavy metals at
    detectable levels, but at levels that posed
    no apparent risk to human health and the
    environment.

•   From 1977 until 1985, the TNRCC
    conducted drinking water well surveys to
    determine the extent of the chromium
    contamination.

•   The Odessa I site was added to the National
    Priority List (NPL) in September 1984.

•   The Remedial Investigation and Feasibility
    Study (RI/FS) was completed in 1986.

Regulatory Context:
•   For the Odessa I site, EPA issued two
    Records of Decision (ROD): Operable Unit
    1 (OU1) to address the need for an
    alternative drinking water supply and
    Operable Unit 2 (OU2) to address
    groundwater cleanup.

•   In 1986, through  the ROD for OU1, an
    alternate drinking water source was made
    available to replace water previously
    supplied by the contaminated wells.

•   On March 18, 1988, the ROD for OU2 was
    approved for groundwater remediation.
    Further soil removal was not required by the
    ROD.
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                                                             Odessa Chromium I Superfund Site
                              SITE INFORMATION (CONT.)
Backaround fCont.}
•  Site activities are conducted under
   provisions of the Comprehensive
   Environmental Response, Compensation,
   and Liability Act of 1980 (CERCLA), as
   amended by the Superfund Amendments
   and Reauthorization Act of 1986 (SARA),
   § 121, and the National Contingency Plan
   (NCP), 40 CFR 300.

Site Loaistics/Contacts            	
Groundwater Remedy Selection: Extraction
of the groundwater and treatment of chromium
through ferrous ion reduction, followed by
reinjection of treated water to the aquifer, was
determined to be the most appropriate remedy
for groundwater based on treatability studies.
Site Lead: State

Oversight:  EPA

Remedial Project Manager:
Ernest Franke
U.S. EPA Region 6
First Interstate Bank Tower
at Fountain Place
1445 Ross Avenue
12th Floor, Suite 1200
Dallas, TX 75202-2733
(214) 655-8521

indicates primary contact
State Contact:
Lei Medford*
Texas Natural Resources Conservation
Commission
P.O. Box 13087
Austin, Texas 78711
(512) 239-2440

Treatment System Vendor:
Design and  Management: IT Corporation (ITC)
Construction and Operation: WATEC
                                 MATRIX DESCRIPTION
Matriy Identification
Type of Matrix Processed Through the
Treatment System: Groundwater

Contaminant Characterization M .2.4.91
Primary Contaminant Group: Chromium

•   The contaminant of concern is chromium.
    The groundwater is contaminated with the
    hexavalent chromium species. However,
    cleanup standards are set for total
    chromium. Likewise, laboratory analyses
    test for total chromium.  For these reasons,
    chromium levels tested and regulated at the
    Odessa I site are for total chromium. No
    organic contaminants were detected in the
    soil or groundwater.
    During a 1985 sampling event, chromium
    was detected in the groundwater at levels
    up to 72 mg/L.  During sampling events in
    1993, prior to pump and treat application,
    chromium was detected at levels up to 4.3
    mg/L.

    The chromium plume directly beneath the
    former on-site building was heavily
    concentrated in the Trinity Sands, which is
    the major aquifer in the region. The
    remnants of the Ogallala Aquifer found at
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                                                               Odessa Chromium I Superfund Site
                             MATRIX DESCRIPTION (CONT.)
Contaminant Characterization (Cont.^
   the site contain a few feet of saturated
   thickness at the most. The northern plume
   migration concurs with the north-
   northeasterly groundwater flow direction
   observed during the RI/FS.

   The initial volume of the chromium plume
   was estimated in the 1986 RI/FS to be 15
   million gallons between 44th and 48th
   streets. The areal extent of the initial plume
   was estimated to be approximately 283,000
   square feet, based on a chromium contour
   of 0.05  mg/L.
The ROD required the chromium levels in
the groundwater to meet the maximum
contaminant level (MCL) for chromium.
EPA changed the MCL from 0.05 to 0.10
mg/L in 1990.

Figure 1 illustrates the boundaries for the
chromium plume for 1994, 1995 and 1996.
From 1994 and 1996, the surface area of
the chromium plume has decreased from
440,000 ft2 to 247,000 ft2, a reduction in
plume size of 44%. The areal plumes are
based on a total chromium concentration
contour of 0.1 mg/L.
Matrix Characteristics Affecting Treatment Costs or Performance
Hydrogeology:  [4,9]

Two distinct hydrogeologic units have been identified beneath this site. Soil and sandy caliche overlie
the water-bearing formations. The first water-bearing unit is encountered at approximately 30 to 45 feet
below ground surface.


     Unit 1    Ogallala      This unit is formed of fluvial plastics consisting of fan deposits of fine to
              Formation    coarse grained sands, silt, clay, and occasional strings of gravel. There
              (Perched     are only erosional remnants of this formation present in the site area,
              Zone)        with a saturated thickness of less than 10 feet in the lower most portion.
                           The erosional remnants of the Ogallala are hydraulically connected to
                           the underlying Trinity Sand Aquifer, and water from the Ogallala flows
                           into the Trinity.  The Ogallalla does not exist as a continuous aquifer and
                           thus flow direction could not be measured.

     Unit 2    Trinity Sand   This unit consists of sands and ferragiorous calcite cemented
              Aquifer       sandstones. Settled lenses of gravel, clay, and siltstone occur at irregular
                           intervals. This unit is the primary groundwater water supply for municipal
                           and private residences in the area. It is underlain by the Chinle
                           Formation, which acts as an effective aquitard. Groundwater in this unit
                           in the area of the site was observed to flow north to northeast, which
                           concurs with the spread of the plume from the source.  However,
                           changes in water levels have altered groundwater flow direction.

The water level in the Trinity Sand Aquifer has risen over 25 feet from 1986 to 1993. The rise in the
water table is attributed to the decrease of public and private wells using the aquifer and to increased
precipitation during this period.
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                                                       Odessa Chromium I Superfund Site
                      MATRIX DESCRIPTION (CONT.)
                a
                               J33SUS  OMC»
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                                                                          I
                                                                     O  U  (J
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                                                                       t
            F/gure 7. Chromium Concentration Contour Map, 1994 -1996 [9]
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                                                               Odessa Chromium I Superfund Site
                              MATRIX DESCRIPTION (CONT.)
Tables 1 and 2 include technical aquifer information and technical well data, respectively.  Extraction
wells are discussed in the following section.

     	Table 1. Technical Aquifer Information	
         Unit Name

           Unit!
          (Ogallala)

           Unit 2
        (Trinity Sand)
Thickness
   (ft)
Conductivity
  (ft/day)
 Average Flow
Velocity (ft/day)
 Flow Direction
  0-10
   70
    1.6
  1.7-5.1
     0.02
  0.03 - 0.00
     Not
 Characterized1

North-Northeast2
       'Water flows from the Ogallala to the Trinity, but the direction of flow has not been
       characterized.
       2Flow observed during the 1986 remedial investigation was towards the north-northeast.
       However, the water table rose from 1986 to 1993 by 25 feet. Flow observed during a 1993
       investigation was towards the southeast. Groundwater investigations since 1993 have shown
       groundwater flow direction to be northerly.	
      Source: [4]
                           TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology

Pump and treat with electrochemical
precipitation of chromium using ferrous ion

System Description and Operation	
                          Supplemental Treatment Technology
                          None
                                  Table 2. Extraction Well Data
Well Name
RW-1/102
RW-2
RW-3
RW-4
RW-5/106
RW-6
Unit Name
Trinity Sand
Trinity Sand
Trinity Sand
Trinity Sand
Trinity Sand
Trinity Sand
Depth (ft)
138
138
138
138
138
138
Design Yield
(gal/day)
14,400
14,400
14,400
14,400
14,400
14,400
     Source: [4]

System Description [4, 5]
•   The extraction system consists of six
    recovery wells, located in the Trinity Aquifer
    (Unit 2). No recovery wells were placed in
    the Ogallalla Formation, directly beneath
    the site because only erosional remnants of
    the Ogallalla remain in the vicinity of the
    Odessa I site. In addition, the groundwater
    in this zone flows directly into the Trinity
    Aquifer. A computer model was used to
                              determine well placement and design
                              extraction rates in the Trinity Aquifer. The
                              modelling determined capture zone for the
                              plume that exceeded 0.1 mg/L chromium.

                              ITC used Randomwalk to model solute
                              transport (an in-house model by Reed and
                              Associates) and Geoflow to model
                              groundwater flow (an in-house model by
                              ITC).
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                                                                Odessa Chromium I Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation (ConU
    The metals treatment system is designed to
    treat the collected groundwater at a rate of
    60 gpm. Influent tanks regulate flow
    through the treatment system.

    Water from the extraction wells is sent to a
    dual-chamber reaction tank.  Ferrous ion is
    fed into the first chamber and mixed with
    the contaminated well water. Ferrous ion is
    produced on site in an electrochemical cell.
    The ion reduces the hexavalent chromium
    to trivalent chromium, to facilitate
    subsequent hydroxide precipitation. In the
    second chamber of the reaction tank, pH is
    adjusted to the range of 8.5 to 8.8 to
    achieve minimum solubility for chromium
    hydroxide.  Also in the second chamber,
    ferrous ion is oxidized by aeration to
    insoluble ferric ion and converted to ferric
    hydroxide.  Both the ferric and the
    chromium hydroxide are mixed with a poly-
    electrolyte in the second chamber.

    The treated water is clarified through a
    flocculation and precipitation tank, where
    insoluble hydroxides are precipitated out.
    From here, the treated water is polished
    through a multimedia filter for reinjection. A
    backwash unit stores a portion of the treated
    water, which is used to flush the filter at
    least once every 24 hours. The sludge from
    the clarifier is disposed off site.

    Chromium  concentrations in the influent and
    the effluent from the treatment system are
    monitored continuously. If the level of
    chromium exceeds 0.05 mg/L in the
    effluent, it is pumped back through the
    treatment system. Treated water with
    chromium concentrations less than 0.05
    mg/L is injected through a network of six
    injection wells.

    A network of 14 monitoring wells placed in
    the Trinity Aquifer is used to monitor plume
    containment quarterly.  The six recovery
    wells are monitored on a monthly basis for
    water quality parameters as well.
System Operation [4,5,6,7]
•   Quantity of groundwater pumped from the
    aquifer by year is:
      Year         Volume Pumped (gal)

      1992                361,000*

      1993              5,339,885*

      1994              28,400,155

      1995              30,692,836

      1996              30,598,566

*The volume pumped during 1992 was during a 30-
day unsuccessful trial run. The extraction system
operated only for the months of November and
December in 1993.

•   Initial startup began in July 1992. The
    injection wells and the filter began to clog
    with iron and calcium in the first 30 days of
    system operation. The extraction and
    treatment systems were shut down for the
    following alterations.

    -  The reactive tank was altered from a
       single-chamber to a two-chamber tank,
       separated by a baffle. The second
       chamber allowed for further
       precipitation of iron, the cause of
       clogging.

    -  A backwash unit was added after the
       multi-media polishing filter to unclog the
       filter of iron and other precipitates. The
       pH of the water after the clarifier was
       reduced to less than 7.5.

    -  Original injection wells continued to be
       used, but infiltration rates had slowed
       because of clogging.  Three additional
       injection wells were constructed to
       increase the injection rate.

    —  After modifications were made from
       May 1993 to August 1993, the system
       resumed operation in November 1993.

    —  Backwash water is stored in the
       mqdified backwash unit and is added
       slowly to the influent tank. The slow
       addition avoids  upsetting the pH
       balance in the influent tank.
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                                                              Odessa Chromium I Superfund Site
                     TREATMENT SYSTEM DESCRIPTION (CONT.)
        Descrintion and Ooeration (Cont.)
    Based on sampling events from 1993 to
    1995, the higher chromium concentrations
    appeared to be migrating to the northwest.
    Recovery wells RW-1 and RW-5 were shut
    down and monitoring wells MW-102 and
    MW-106 were converted to recovery wells
    to continue pumping from areas in the
    plume with high chromium concentrations.
One injection well was found to continually
plug because of a local formation of silty
fines.  It was taken off line in May 1995.
The rate of injection of treated water
remained the same.

The site has been operational 95% of the
time since 1993. Downtime is primarily due
to shutdowns for local brown outs and
system maintenance.
Onpratinn Parameters Affectina Treatment Cost or Performance
The major operating parameter affecting cost or performance for this technology is extraction rate.
Table 3 presents the values measured for this and other performance parameters.

                               Table 3. Performance Parameters
telfSflsajPlrameter . ' .;:.. 	 _!„;,
Average Pump Rate
Performance Standard (effluent)
Remedial Goal (aquifer)
' •"'"'"' ' : Valued- -
86,500 gpd*
0.05 mg/L total chromium
0.10 mg/L total chromium
              Source: [2, 6]
              *The average system extraction rate from January 1998 until December 1996 was estimated for
              this report to be 86,500 gpd or approximately 14,400 gpd per well, based on the actual 125 million
              gallons pumped and 95% operating rate.
Table 4 presents a timeline for this remedial action.
                                      Table 4.  Timeline
Start Date
January 1992
July 1992
May 1993
November 1993
April 1995
Mav 1995
End Date
July 1992
August 1992
August 1993
...
—
—
< Ac«vl#7 -'**"'
Remediation system constructed
System started; injection wells clogged with iron and calcium
Alterations made to remedial system
~/// *



Continuous operation of remediation system begun. Monthly monitoring of groundwater
begun.
Shitt in plume detected. Monitoring wells MW-102 and MW-106 converted to recovery wells
RW-1 02 and RW-1 06. RW-1 and RW-5 shut down
Iniection Well IJ-2 taken off line because of oiuaaina
Source: [2, 4, 6, 7]
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                                                              Odessa Chromium I Superfund Site
                         TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards T21
•   The cleanup goals as established by
    TNRCC and EPA are to remediate
    groundwater so that chromium levels are
    less than the maximum contaminant level
    (MCL), or the Primary Drinking Water
    Standard, of 0.10 mg/L. This goal is applied
    throughout the aquifer, as measured in all
    on-site monitoring wells.

Treatment Performance Goals T41	
Additional Information on Goals

•  The original drinking water standard for
   chromium set by EPA was 0.05 mg/L. In
   1990, EPA revised the standard to the
   Primary Drinking Water Standard of 0.10
   mg/L.
•   Effluent injected into the aquifer from the
    treatment system must have levels of
    chromium below 0.05 mg/L.

Performance Data Assessment T1. 3. 4. 5. 6. 71
   As a secondary goal, the remedial system is
   required to create an inward gradient toward
   the site to contain the plume.
   Three wells have met the cleanup goal for
   chromium of 0.10 mg/L: RW-1, RW-3, and
   RW-5. The maximum concentration of
   chromium detected in the groundwater in
   January 1997 was 2.9 mg/L. Groundwater
   monitoring results indicate that chromium
   concentrations have been reduced
   compared to initial levels, but not to levels
   below the treatment goal.

   Figure 2 illustrates the changes in average
   chromium concentrations in the
   groundwater from January 1992 to January
   1997 [6]. Average chromium levels were
   reduced by 48% during that time, from 0.98
   mg/L in March 1992 to 0.54 mg/L in January
   1997.

   The individual wells provided wide
   variations in month to month chromium
   concentrations for the first two years.  The
   variation became less pronounced in 1996
   with a noticeable downward trend [9].

   Concentrations of chromium in the
   groundwater have fluctuated in different
   wells.  Figure 3 illustrates that chromium
   levels in RW-1 and RW-5 increased from
   1992 to 1995.  Figure 4 illustrates well-
   specific chromium levels that decreased
   from 1991 to 1997, then fluctuated during
   1994.  Figure 5 illustrates well-specific
   chromium levels that decreased from 1986
   until 1997 [4,6].
   The September 1994 sampling event
   revealed spikes in concentrations of
   chromium in many wells [7].  The site
   contact has indicated that while no QA/QC
   problems were identified, the validity of the
   September 1994 sampling event is
   questionable [6].

   Other spikes in concentrations of chromium
   may be a result of incomplete source
   removal. According to the site contact,
   source control measures were applied only
   to shallow soils. Because the ROD did not
   specify complete removal of soil
   contamination, additional soil removal was
   not performed.

   Figure 6 presents the removal of chromium
   through the treatment system from
   December 1993 to 1996 [1,5].  During this
   time, a total of 1,143 pounds of chromium
   were removed from the groundwater [1].
   Chromium mass removal was determined
   based on the chromium concentrations in
   the sludge. Data on the amount of
   chromium removed by the treatment system
   during the 30-day period in 1992 were not
   available.

   Figure 6 illustrates that mass flux decreased
   after the first year  of system operation, from
   1.2 pounds per day to less than 0.8 pounds
   per day [1 ].
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                                                             Odessa Chromium I Superfund Site
                    TREATMENT SYSTEM PERFORMANCE (CONT.)
PArfnrmanrp Data Assessment
•   Effluent chromium levels have met the
    required performance standard of 0.05 mg/L
    throughout treatment [6].

•   Based on sampling events, plume
    containment has been achieved since 1995
    [3,6]. The site operators determined there
    was a failure in plume containment during
    1993 and 1995, based on a rise in
    chromium concentrations in some
    monitoring wells during this period [4]. Two
    monitoring wells within the area of concern
    were converted to recovery wells, and two
    recovery wells from a less contaminated
    area were taken off line.

Pprfnrmanrp Data Comnleteness
    Data on mass flux and mass removed are
    reported on a monthly basis and are
    available for this site from the TNRCC.
    Annual data were used for the analyses in
    Figure 6.

    For the chromium concentration analyses in
    Figures 2 through 5, annual monitoring data
    were used for 1993 and 1995 through 1997.
    Quarterly data were used for 1994. These
    data were supplied in monthly reports and in
    the Project Status Draft Report prepared by
    ITC in 1995.  Monitoring data are available
    on a quarterly basis for this site from the
    TNRCC.

  orfrtriYmnr*A Data Onalitv
A geometric mean was used for average
chromium concentrations detected in the
groundwater, as presented in Figure 4, to
represent the overall trend of chromium
contamination in the groundwater at the site.

When concentrations below detection limits
were encountered, half of the detection limit
was used for evaluation purposes.
The QA/QC program used throughout the remedial action met EPA and TNRCC requirements.  All
monitoring was performed using EPA Method 218.1 and EPA-approved methods for pH, total suspended
solids, and other water quality parameters. Except for the September 1994 data (discussed above) the
vendor did not note any exceptions to the QA/QC protocols [6].
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                                                            Odessa Chromium I Superfund Site
                   TREATMENT SYSTEM PERFORMANCE (CONT.)
      1.4000
      o.oooo
         Jan
-92
            Jan-93
                           Jan-94
Jan-95
Jan-96
Jan-97
     Figure 2. Average Chromium Concentrations in the Groundwater (1992 - January 1997) [4,6]

      * Two monitoring wells converted to extraction wells; two other extraction wells shut down.
o
    0
    Jan-92
                  Jan-93
                                            Jan-94
                             Jan-95
                                     -RW-1
                                          -RW-5
         Figure 3.  Chromium Concentrations in Wells RW-1 and RW-5 (1992 - 1997) [4,6]
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                                                          Odessa Chromium I Superfund Site
                 TREATMENT SYSTEM PERFORMANCE (CONT.)
 Jan-91
               Jan-92
                            Jan-93
Jan-94
                                                      Jan-95
                          Jan-96
                   -RW-2
                                  -RW-4
                                                -RW-6
                                                              -RW-102/MW-102*
                                                                                Jan-97
  "RW-102 was MW-102 until 4/95
Figure 4. Chromium Concentrations in Wells RW-2, RW-4, RW-6, and RW-102 (1991 - 1997) [4,6]
                                    vmwr%^  /     , *
 Jan-86  Jan-87  Jan-88  Jan-89  Jan-90   Jan-91   Jan-92  Jan-93  Jan-94   Jan-95  Jan-96  Jan-97
                                 -RW-3
     •RW-106/MW-106*
   *RW-106 was MW-106 until 4/95
      Figure 5.  Chromium Concentrations in Wells RW-3 and RW-106 (1986 - 1997) [4,6]
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                                                          Odessa Chromium I Superfund Site
                   TREATMENT SYSTEM PERFORMANCE (CONT.)
                                                                           1200
                                                                                I
                              - Mass Flux
                                                 -Mass Removed
         Figure 6.  Mass Flux Rate and Cumulative Chromium Removal (1993 - 1996) [6]
                             TREATMENT SYSTEM COST
Procurement Process
TNRCC is the lead authority on this site. WATEC was awarded the construction and operations contract
for the site.  ITC was awarded the oversight contract for the site.
Cost Analvsis
   The costs for design, construction, and operation of the P&T system at this site were split 90:10 by
   EPA and TNRCC, respectively.
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                                                               Odessa Chromium I Superfund Site
                           TREATMENT SYSTEM COST (CONT.)
Capital Costs 161
  Remedial Construction
  Mobilization Work
  Monitoring Wells -
  Sampling/Testing Analysis
  Groundwater Collection &
  Control
  Installation of Treatment Plant
  Site Restoration
  Site Security
  Construction Management
  Total Remedial Construction
Cost Data Quality
  $334,723
   $52,761


  $287,947


  $944,800

   $13,542

   $3,298

  $316,533

$1,953,604
                 Operating Costs T61
 Operation and Maintenance           $774,418
 Monitoring Costs                    $13,841
 Total Cumulative Operating         $788,259
 Expenses (1993-1996)
 1993 Operating Costs (11/93 -          $25,772
 12/93)
 1994 Operating Costs (1/94 -12/94)    $202,817
 1995 Operating Costs (1/95 -12/95)    $228,705
 1996 Operating Costs (1/96 -12/96)    $330,965

Other Costs f 6"|
 Remedial Design
 Original Bid Design                  $132,180
 Final Amount (redesign in 1993)       $230,438
 (total for design)
Actual capital and operation and maintenance cost data are available from TNRCC for this application.
                        OBSERVATIONS AND LESSONS LEARNED
    Actual costs for the pump and treat
    application at Odessa I were approximately
    $2,742,000 ($1,954,000 in capital costs and
    $788,000 in operation and maintenance
    costs), which corresponds to $30 per 1,000
    gallons of groundwater treated and $2,400
    per pound of  chromium removed. The $30
    per 1,000 gallons is based on volume
    treated through December 1996, because
    cost data through 1998 were not available at
    the time of this report.

    The ROD specified that the  ferrous ion used
    to reduce the chromium would be
    electrochemically produced, which limited
    the number of the on-site system vendors to
    two and potentially increased the cost of the
    treatment unit.

    The costs listed above include the system
    modifications performed in 1993 and in
    1995.  There  have been no further changes
    to the cost for the remedial system at the
    site [3].

    Operating costs have increased from 1993
    to 1996. The operations contract has a
    fixed annual cost for  disposal of up to 500
    Ibs of chromium.  Any amount of chromium
      EPA
                     beyond 500 Ibs is paid on a cost plus fixed
                     fee basis, resulting in additional annual
                     disposal costs each year since 1993.

                     While chromium levels have been reduced
                     below the MCL in three wells, the
                     groundwater cleanup goals have not been
                     achieved as of December 1996. Extraction
                     and treatment will continue until goals are
                     achieved [3,4,6].

                     Overall, average chromium concentrations
                     decreased, but concentrations of chromium
                     have fluctuated in some wells [4]. These
                     variations in chromium  levels are most
                     likely a result of the increased  groundwater
                     level  and further desorption of chromium
                     from  aquifer materials [3,7]. According to
                     the site contact, because complete removal
                     of all  contaminated soils was not specified
                     in the ROD, source control measures (i.e.,
                     soil removal) were applied to only shallow
                     soils [4]. Deeper aquifer material may still
                     contain high levels of chromium that can act
                     as a source for continuing contamination
                     [3,7]. The site contact also noted that
                     complete source removal would have
                     eliminated the source for a persistent plume
                     [3].

                            U.S.  Environmental Protection Agency
                     Office of Solid Waste and Emergency Response
                                     Technology Innovation Office
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                                                             Odessa Chromium I Superfund Site
                  OBSERVATIONS AND LESSONS LEARNED (CONT.)
   The plume has been contained since 1995,
   after containment failure from 1993 to 1995
   [1].  The shift in groundwater flow observed
   in 1993 may have caused the containment
   failure [6]. By adjusting the extraction
   system, plume containment was achieved.
   This illustrates the importance of flexibility
   in system operation.

   There were several startup problems,
   including clogging of injection wells and
   filter by iron and calcium, that delayed full-
   scale operations [4]. These problems were
   solved through system modification, and no
   longer interfere with operations.  The site
   contractor has suggested that one potential
   approach to identifying the problems earlier
   would be to increase the length of pilot
   operations. At this site, pilot operations
   were conducted in hourly increments, and
   the results were used to simulate full-cycle
   operations. Had the pilot operations been
   conducted for a full 24-hour cycle, it is likely
   that the iron and calcium fouling problems
   that led to clogging would have been
   identified [4].
   Full-scale operations were delayed by iron
   encrustation in the injection wells and in the
   filter. Setting effluent standards for iron in
   the future could prevent such delays.

   ITC also has concluded that the continuous
   chromium monitors on the influent were not
   useful because they could not detect
   chromium levels above 1.0 mg/L. They did
   not operate until wells were well on the way
   to being clean. Monthly tracking was found
   to be helpful for monitoring site cleanup, but
   continuous data were not useful [4].

   During system operation, system operators
   determined that backwash from the filter
   system should be equalized and added
   slowly to the influent tank to avoid large
   changes in the influent chemistry [4].
   During early system operations, backwash
   water was introduced directly into the
   influent tank.  The differences between the
   pH levels in the backwash and the influent
   reduced the effectiveness of the reaction
   tank.  The backwash storage unit allows
   gradual  addition of backwash to the influent.
   This has alleviated the earlier problems in
   the reaction tank [4].
                                      REFERENCES
1.   Record of Decision. USEPA, Odessa
    Chromium #1, OU2, March 18,1988.

2.   Record of Decision. USEPA, Odessa
    Chromium I, OU1, Septembers, 1986.

3.   Correspondence with Mr. Lei Medford,
    TNRCC.

4.   Project Status Draft Report. ITC, January
    1995.

5.   Odessa Chromium I & IIS Superfund Sites
    Treatment System. WATEC. No date
    listed.
6.  Odessa Chromium I Monthly Reports. ITC.
   December 1993/January 1994, January
   1995, January 1996, January 1997.

7.  Lessons Learned. ITC, January 1997.

8.  Groundwater Regions of the United States.
   Heath, Ralph. U.S. Geological Survey
   Water Supply Paper 2242. 1984.

9.  TNRCC comment on draft report, dated
   3/11/98.
This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
Emergency Response, Technology Innovation Office. Assistance was provided by Eastern Research
Group, Inc. and Tetra Tech EM Inc. under EPA Contract No. 68-W4-0004.
      EPA
            U.S.  Environmental Protection Agency
     Office of Solid Waste and Emergency Response
                    Technology Innovation Office
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              146

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Pump and Treat of Contaminated Groundwater at
 the Odessa Chromium US Supeiiimd Site, OU 2
               Odessa, Texas
                    147

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                  Pump and Treat of Contaminated Groundwater at
                    the Odessa Chromium IIS Superfund Site, OU 2
                                        Odessa, Texas
Site Name:
Odessa Chromium US Superfund
Site, Operable Unit 2 (OU 2)
Location:
Odessa, Texas
Contaminants:
Heavy Metals (Chromium)
- Maximum concentration of Cr
detected during 1986 sampling
event was 50 mg/L (perched zone
aquifer)
Period of Operation:
Status: Ongoing
Report covers:  11/93 -12/97
Cleanup Type:
Full-scale cleanup (interim results)
Vendor:
Design and Management: IT
Corporation (ITC)
Construction and Oversight:
WATEC
State Point of Contact:
Lei Medford
Texas Natural Resources
Conservation Commission
P.O. Box 13087
Austin, TX 78711
(512) 239-2440
Technology:
Pump and Treat
- Groundwater is extracted using
10 wells at an average total
pumping rate of 58.5 gpm
- Extracted groundwater is treated
for Cr removal with chemical
treatment (ferrous ion, produced on
site), pH adjustment, flocculation,
precipitation, and multimedia and
cartridge filtration
- Treated groundwater is reinjected
through 9 injection wells
Cleanup Authority:
CERCLA Remedial
-ROD Date: 3/18/88
EPA Point of Contact:
Ernest Franke, RPM
U.S. EPA Region 6
First Interstate Bank Tower at
Fountain Place
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214) 655-8521
Waste Source:
Unlined wastewater-holding ponds
and waste drum burial
Purpose/Significance of
Application:
Includes on-site treatment for
chromium; relatively low
groundwater flow; contamination
in two aquifers.
Type/Quantity of Media Treated:
Groundwater
- 121 million gallons treated as of December 1997
- Groundwater is found at 30-45 ft bgs
- Extraction wells are located in 2 aquifers, which are influenced by
production wells in the area
- Hydraulic conductivity ranges from 1.6 to 5.1 ft/day
Regulatory Requirements/Cleanup Goals:
- Remediate groundwater so that chromium levels are less than the maximum contaminant level (MCL) or
  primary drinking water standard.
- Prior to 1990, the drinking water standard for chromium was 0.05 mg/L; in 1990, EPA revised the drinking
  water standard to 0.10 mg/L.
- Treated effluent that is injected into the aquifer must have a chromium level of less than 0.10 mg/L.
- The remedial system was required to create an inward gradient toward the site to contain the plume.
                                              148

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                   Pump and Treat of Contaminated Groundwater at
                    the Odessa Chromium HS Superfund Site, OU 2
                                 Odessa, Texas (continued)
Results:
- Groundwater sampling results show that chromium levels have been reduced to less than 0.10 mg/L in the
  Trinity Aquifer but not in the Ogallala Aquifer. Results from January 1997 show that concentrations have
  been reduced in the Ogallala Aquifer (since startup), but not to levels below 0.10 mg/L.
- The P&T system removed 131 pounds of chromium from the groundwater from 1993 to December 1996.
- Effluent chromium levels have met the required performance standard of 0.10 mg/L throughout system
  operation.
- The plume has been contained in both aquifers.
Cost:
- Actual costs for the P&T system were approximately $2,487,700 ($1,927,500 in capital and $560,200 in
  O&M), which correspond to $26 per 1,000 gallons of groundwater extracted and $19,000 per pound of
  contaminant removed.
- The ROD specified that the ferrous iron used in the treatment system be produced electrochemically, which
  limited the number of vendors to two and potentially increased the cost of the treatment system.
- The costs for design, construction, and operation of the P&T system were split 90:10 by EPA and TNRCC,
  respectively.
Description:
Basin Radiator & Supply operated a radiator repair facility at this site from 1960 to the early 1970s. Wastewater
containing chromium was discharged to unlined ponds, and waste radiator sludge containing chromium corrosion
inhibitors was buried on the site. In 1977, the TNRCC discovered elevated levels of chromium in the
groundwater during investigations conducted in response to citizen complaints of contaminated well water. This
site later became known as the Odessa n South (S) site. The Odessa IIS site was placed on the NPL in June
1986, and a ROD was signed for the site in March 1988.

The extraction system used at this site consisted of six extraction wells constructed in the Trinity Sand Aquifer
and four extraction wells in the Ogallala Formation.  Extracted groundwater was treated with ferrous iron
(produced on site in an electrochemical cell), pH adjustment and aeration, clarification,  and multi-media and
cartridge filtration. While chromium concentrations have been reduced to below the MCL in the Trinity Aquifer,
groundwater cleanup goals have not been achieved in the Ogallala Formation.

There were several startup problems that delayed full-scale operation at this site, including clogging of injection
wells and encrustation of the multimedia filter by iron and calcium. These problems were solved through system
modification and no longer interfere with operations.	
                                               149

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                                                           Odessa Chromium IIS Superfund Site
                                   SITE INFORMATION
Identlfying-Information:

Odessa Chromium IIS Superfund Site
Operable Unit 2 (OU 2)
Odessa, Texas

CERCLIS#: TXD980697114

ROD Date: March 18,1988
Backaround
Treatment Application:
Type of Action: Remedial

Period of Operation: 11/93 - Ongoing
(Performance data collected through December
1996)
(Data on volume treated collected through
December 1997)

Quantity of Material Treated During
Application: 121 million gallons
Historical Activity that Generated
Contamination at the Site:  Radiator repair

Corresponding SIC Code: 7538

Waste Management Practice That
Contributed to Contamination:  Unlined
wastewater-holding ponds and waste drum
burial

Location: Odessa, Ector County, Texas

Facility Operations:  [1, 2, 3]
•   The site is located in a mixed residential,
    commercial, industrial area.  The Basin
    Radiator & Supply formerly located in the
    5300 block of Andrews Highway operated
    from  1960 to the early 1970s. Wastewater
    containing chromium was discharged to
    unlined ponds, and waste radiator sludge
    containing chromium corrosion inhibitors
    was buried on the site. Also located in the
    5300 block of Andrews Highway was
    Wooley Tool and Manufacturing which had
    a chromium plating operation.

•   In 1977, the Texas Natural Resource
    Conservation Commission (TNRCC)
    discovered elevated levels of chromium in
    the groundwater during investigations in
    response to citizen complaints of
    contaminated well water.

•   The TNRCC concluded that the two facilities
    were the source of chromium in the
    groundwater: Wooley Tool and
    Manufacturing and Basin Radiator & Supply.
    The former became known as the Odessa II
    North site and the latter as the Odessa II
    South(S) site. The Odessa IIS site is the
    subject of this report.

    In 1978, the TNRCC removed drums, on-
    site buildings, and contaminated soils from
    the site.

•   In 1986, the Remedial Investigation/
    Feasibility Study (RI/FS) was completed.
    On June 10,1986, Odessa IIS was placed
    on the National Priorities List (NPL).

Regulatory Context:
    For the Odessa IIS site, the EPA issued two
    Records of Decision (ROD).  In 1986, the
    ROD for Operable Unit 1  (OU1) was signed
    to provide an alternative drinking water
    supply.

•   On March 18,1988, the ROD for OU2 was
    approved for groundwater remediation at
    Odessa IIS. Source control was not
    required by the ROD.

•   Site activities are conducted under
    provisions of the Comprehensive
    Environmental Response, Compensation,
    and Liability Act of 1980 (CERCLA), as
    amended by the Superfund Amendments
    and Reauthorization Act of 1986 (SARA)
    §121, and the National Contingency Plan
    (NCP), 40 CFR 300.
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                                                           Odessa Chromium IIS Superfund Site
                              SITE INFORMATION (CONT.)
Background (Cont.l
Groundwater Remedy Selection:
Groundwater extraction followed by treatment to
remove chromium contamination and injection
of the treated water back to the aquifer was
determined by the FS to be the most
appropriate methodology for site remediation.
The results of a pilot study confirmed the basic
approach.

Site Logistics/Contacts	
Site Lead: State

Oversight:  EPA

Remedial Project Manager:
Ernest Franke
U.S. EPA Region 6
First Interstate Bank Tower at Fountain Place
1445 Ross Avenue
12th Floor, Suite 1200
Dallas, TX 75202-2733
(214) 655-8521

Indicates primary site contact
State Contact:
Lei Medford*
Texas Natural Resources Conservation
Commission (TNRCC)
P.O. Box13087
Austin, Texas 78711
(512) 239-2440

Treatment System Vendor:
Design and  Management: IT Corporation (ITC)
Construction and Operation: WATEC
                                 MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed Through the
Treatment System: Groundwater

Contaminant Characterization M. 31
Primary Contaminant Groups:  Chromium

•  The contaminant of concern is chromium.
   Hexavalent chromium is the species of
   concern in the groundwater because under
   the aquifer conditions it is the only species
   that is soluble and can affect the drinking
   water. The ROD stipulates a clean-up
   standard based on total chromium since the
   Maximum Contaminant Limit (MCL) was set
   for total chromium, instead of an individual
   species.
   Two hydraulically connected chromium
   plumes have been identified and are
   referred to as the Perched Zone plume and
   the Trinity Aquifer plume.

   The maximum concentration of chromium in
   the groundwater in the Trinity Aquifer,
   detected during a 1985 sampling event, was
   2.8 mg/L. The maximum chromium
   concentration in the Perched Zone
   groundwater, detected in 1986, was greater
   than 50 mg/L.
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                                                             Odessa Chromium IIS Superfund Site
                             MATRIX DESCRIPTION (CONT.)
Contaminant Characterization M. 31 (Cont.)
    The initial volume of the chromium plume in
    the Perched Zone was estimated in the
    1986 RI/FS at 980,000 gallons. The areal
    extent of the initial plume was estimated to
    be approximately 105,000 square feet.

    The initial volume of the chromium plume in
    the Trinity Aquifer was estimated in the
    1986 RI/FS at 79,000,000 gallons. The
    areal extent of the  initial plume was
    estimated to be approximately 585,000
    square feet.

    The ROD required the site to be cleaned to
    meet the MCL for chromium.  In 1990, EPA
    changed the MCL from  0.05 mg/L to 0.10
    mg/L in 1990 by EPA. The plume size
    estimates were originally calculated based
    on the 0.05 mg/L contour.

    Figures 1 and 2 delineate the 0.1 mg/L
    chromium contours in the Perched Zone
    and Trinity Aquifer, respectively, as
    observed during a  September 1994 (nine
    months after beginning treatment) sampling
    event.
In the Project Status Draft Report, the
plume volumes in the Perched Zone and
Trinity Aquifer were calculated based on the
revised 0.1 mg/L clean-up goal and data
that were nine years more current than the
original Rl data. A significant change in the
aquifer water level and the chromium
concentration had occurred between 1985
and 1994 because of lower water withdrawal
rates in the area.

The Perched Zone plume was found to be
61,270 square feet in area and 690,000
gallons in volume, compared to the 1986
plume estimate of 105,000 square feet in
area and 980,000 gallons in volume. The
Trinity Aquifer plume was found to be
210,385 square feet in area and 44,000,000
gallons in volume, compared to the 1986
estimate of 585,000 square feet and
79,000,000 gallons.  The plume reductions
are in part because of lowered levels of
chromium but also because of the less
stringent standard.
Matrix Characteristics Affecting Treatment Costs or Performance

Hydrogeology: [1,3]

Two distinct hydrogeologic units have been identified beneath this site.  Soil and sandy caliche overlie
the water-bearing formations. The first water-bearing unit is encountered at approximately 30 to 45 feet
below ground surface.

   Unit 1     Ogallala        This unit is formed of fluvial plastics consisting of fan deposits of fine to
             Formation      coarse grained sands, silt, clay, and occasional strings of gravel. A few
             (Perched       miles to the south, the Ogallala has been removed by erosion.  It is
             Zone)          present in some parts of the site with a saturated thickness of
                            approximately 5 to 15 feet, and is referred to as the Perched Zone. It is
                            hydraulically connected and discharges to the underlying Trinity Sand
                            Formation under natural conditions. The Ogallalla does not exist as a
                            continuous aquifer and thus flow direction  could not be measured.
   Unit 2     Trinity Sand    This unit consists of sands and ferragiorous calcite cemented
             Aquifer        sandstones.  Settled lenses of gravel, clay, and siltstone occur at
                            irregular intervals. This unit is the primary groundwater supply for
                            municipal and private residences in the area. It is underlain by the
                            Chinle Formation, which acts as an aquitard. Groundwater flow in this
                            unit has been observed to flow north to northeast;  however, changes in
                            water levels have altered groundwater flow direction.
      EPA
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 Office of Solid Waste and Emergency Response
  	Technology Innovation Office
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                                                                  Odessa Chromium IIS Superfund Site
                              MATRIX DESCRIPTION (CONT.)
                                                                                   MW-232  •»:
                                                               WUMHCTCN AMMUE
                                                                IWOTW MTHUt
                                                                      OOMITHV tuotue
                        ANDREWS   HIGHWAY
                                                                                    U.S.  HWY   385
                                                                       NO
                                                                  PUW-201
                                                                          MW—2O1A
__    r~l   OtROHEO ZONE RECOVERY WELL
PRW—18 I A I   WITH CONCENTRATION OF TOTAL
    "-•> i__l   CHROMIUM C"<«/L). CNOVCMBER i»e«)
    2O7 -
    MO
 PU-2S
PERCHED ZONE MOMTOmNG WELL
WITH CONCENTRATION OT TOTAL
CHROMIUM <*T.Q/L). (OCTOBER !»»'

PERCHED ZONE INJECTION WCU.
n 1 _«_ LINE OF EQUAL CHROMIUM CONCENTRATION
        IN PERCHED ZONE (mg/L)

 MO      CHROMIUM NOT DETECTED AT REPORTING LIMIT

 W      NOT TAKEN

 SOURCE  tWATEC MONTHLY REPORTS
        OCTOBER/NOVEMBER  199«
^»~1«it  1   TRINrTY RECOVERY WELL

MW—2O5 «.    TRINrrv MONITORING WELL

  UT2' »  I   TRimrv MJCCTION WELL
         Figure 1.  Perched Aquifer Chromium Contour Map (1994, Best Copy Available) [3]
    EPA
                      U.S.  Environmental Protection Agency
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            	Technology Innovation Office
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                                                            Odessa Chromium IIS Superfund Site
                         MATRIX DESCRIPTION (CONT.)
         . MW-233
          HO
                                    '  /) ****

                                    MMlMHlHQ -^         o
                                      /rt*-1*       . fc>
                                     /    •>•*'       ^
           TRINfTY RECOVERY WELL WITH
           CONCENTRATION OF TOTAL
           CHROUWM (mo/L). (NOVEMBER 1994)

 MW-2O3.+.   TRINITY MONITORING WELL. WITH
   CM.?     CONCENTRATION OF TOTAL
           CKROUHJM (mg/L). (OCTOBER t99*>

 U<-21 j> ~~|  TMN«TY iNJCCTtON WELL


PKW-1O <*l  PERCHED ZONE RECOVERY WELL


PUW—2O7 -I-   I^RCHCO ZONE UONTTOKtNC WELL


 PU-2S fa]  PERCHED ZONE INJECTION WELL
                                            CHROMIUM NOT DETECTED AT REPORTING LIMIT
      Figure 2.  Trinity Aquifer Chromium Contour Map (1994, Best Copy Available) [3]
EPA
                                                                 U.S.  Environmental Protection Agency
                                                        Office of Solid Waste and Emergency Response
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                                                            Odessa Chromium IIS Stipe/fund Site
                             MATRIX DESCRIPTION (CONT.)
Matrix Characteristics Affecting Treatment Costs or Performance fCont.>

The water level in the Trinity Aquifer has risen over 25 feet from 1986 to 1993. The rise in the water
table is attributed to the decrease of public and private wells in the aquifer and to increased precipitation
during this period.

Tables 1 and 2 present technical aquifer information and extraction well data, respectively.

                             Table 1. Technical Aquifer Information
Unit Name
Thickness
(ft)
Conductivity
(ft/day)
Unit! 5-15 1.6
Unit 2 70 1.7-5.1
1Flow observed during the 1986 remedial investigation was towards the north
feet and could have resulted in a change in groundwater flow direction.
Average Flow
Velocity (ft/day)
Flow Direction
0.0190 Not Characterized
0.0262 - 0.0782 North-Northeast1
-northeast. However, the water table rose from 1 986 to 1 993 by 25
Source: [1,3]
                          TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology

Pump and treat (P&T) with electrochemical
precipitation of chromium using ferrous ion

System Description and Operation	
Supplemental Treatment Technology

Solids removed by flocculation and filtration
                                 Table 2. Extraction Well Data
Well Name
PRW18
PRW19
PRW20
PRW28
RW12
RW13
RW14
RW15
RW16
RW17
Unit Name
Ogallala Formation
Ogallala Formation
Ogallala Formation
Ogallala Formation
Trinity Aquifer
Trinity Aquifer
Trinity Aquifer
Trinity Aquifer
Trinity Aquifer
Trinity Aquifer
Depth (ft)
70
70
70
70
165
165
165
165
165
165
Design Yield
(gal/day)
4,070
4,070
4,070
4,070
21,600
21,600
21,600
21,600
21,600
21 ,600
Source:  [1,3,4]
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                                                              Odessa Chromium IIS Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
        Deselection and Ooeration (Cont.)
System Description [3, 5, 8]
•   The extraction system consists of six
    recovery wells in the Trinity Aquifer and four
    recovery wells in the Ogallala Formation.
    ITC used Random Walk to model solute
    transport (an in-house model by Reed &
    Associates) and Geoflow to model
    groundwater flow (an in-house model by IT).
    Model results were used to determine well
    placement based on projected pumping
    rates.

•   The metals treatment system is designed to
    treat the collected groundwater at a rate of
    60 to 90 gpm. An influent tank regulates
    flow through the treatment system.

•   Water from the extraction wells is sent to a
    dual chamber reaction tank (initially single
    chamber),  into which ferrous ion is fed and
    mixed with the contaminated well water.
    Ferrous ion is produced on site in an
    electrochemical cell. The ion reduces the
    hexavalent chromium to trivalent chromium
    to facilitate subsequent hydroxide
    precipitation. In the second chamber of the
    reaction tank, pH is adjusted in the range of
    8.5 to 8.8 to achieve minimum solubility for
    chromium  hydroxide.  Also, in the second
    chamber, excess ferrous ion is oxidized by
    aeration to insoluble ferric ion and
    converted  to ferric hydroxide. The ferric
    and chromium hydroxide precipitate is
    mixed with a polyelectrolyte in the second
    chamber to aid settling.

•   The treated water is clarified through a
    flocculation and precipitation tank. From
    here, the treated water is polished through a
    multimedia and cartridge filter for
    reinjection. The multimedia filters are
    backwashed with treated water based on
    pressure drop and the cartridge filters are
    replaced when a specified pressure
    differential is exceeded. The sludge from
    the clarifier and the cartridge filters are
    disposed off site as nonhazardous waste.

•   Chromium concentrations in the influent to
    and the effluent from the system are
    monitored  continuously. If the level of
    chromium  exceeds 0.05 mg/L in the
      EPA
    effluent, the effluent is recycled through the
    treatment system.  Treated water with
    chromium concentrations less than 0.05
    mg/L is injected through a network of six
    injection wells in the Trinity Aquifer and
    three injection wells in the Ogallala
    Formation.

•   The recovery wells are monitored on a
    monthly basis for water quality parameters.
    A network of wells is used to monitor plume
    containment on a semiannual  basis:  10
    monitoring wells and the recovery wells in
    the Trinity Aquifer, and two monitoring wells
    and the recovery wells in  the Ogallala
    Formation.

System Operation [3, 4, 5, 8]
•   Quantity of groundwater pumped from
    aquifer by year:
        Year        Volume Pumped (gal)

     11/93-12/93         4,269,133
        1994            29,660,519
        1995            29,118,867
        1996            31,257,749
        1997            26,320,000

    Initial startup began in July 1992; however,
    the multimedia polishing filter and injection
    wells began to clog with iron and calcium in
    the first 30 days and treated water could not
    be reinjected. The extraction  and treatment
    systems were shut down and the following
    alterations were  made:

    —  The reaction tank was altered from a
       single-chamber to a two-chamber tank,
       separated by a baffle. The second
       chamber allowed for precipitation of the
       excess iron, the main clogging problem.
       A tank was added to receive backwash
       from the multimedia filters. The
       backwash tank acted as an equalization
       tank to prevent shock change to the
       system influent tank when the filters
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                                                             Odessa Chromium IIS Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
Svstem Descriotion and Ooeration (Cent.)
       were backwashed. The pH of the
       treated water was set to between 7.0
       and 7.5 pH beyond the clarif ier to
       prevent precipitation of calcium
       carbonate.

    --  Two additional injection wells were
       constructed to allow for higher
       reinjection rates.

    —  Backwash water is stored in the
       modified backwash unit and is slowly
       added to the influent tank. The slow
       addition avoids upsetting the pH
       balance in the influent.

    —  Modifications were completed in August
       1993, and the extraction and treatment
       systems became operational in
       November 1993.

    In September 1996, a low-flow test was
    performed in case future extraction would
    be from the Ogallala Formation only,
    because the Ogallala Formation was being
    remediated more slowly than the Trinity
    Aquifer. The treatment system was tested
    for ability  to operate at 20 gpm, and was
    successful at low flow rates.

    In March 1997, an additional recovery well
    was installed in the Ogallala Formation to
    expedite cleanup of the suspected source
    area. The additional well expanded the
    extraction network to a total of four recovery
    wells in the Ogallala Formation.
Ooeratina Parameters Affectina Treatment Cost or Performance
Since November 1993, the site has been
operational 95% of the time. Downtime is
primarily due to shutdowns for local brown-
outs and routine system maintenance.

On December 12,1997 the Odessa IIS
plant was shut down for major modification.
All of the Trinity Aquifer wells had met the
clean-up criterion set by the ROD as did all
but two of the Ogallala Formation wells.
Since the remaining two perched zone wells
produced less than two gpm total flow, it
became inefficient to operate a 60 gpm
plant for such a small flow. Modifications
were made to collect the water from the two
remaining Ogallala Formation wells in the
influent and effluent tanks at the plant.
These tanks are periodically discharged to a
tank truck for transport to an off-site
treatment plant.

The equipment that was not needed in the
modified plant was either disposed off site
or disconnected and stored on site for future
use. All of the Trinity Aquifer recovery wells
with the exception of RW14 were plugged,
as were Ogallala Formation wells PRW18
and PRW19. RW14 supplies injection water
to two Ogallala Formation injection wells to
aid in pushing contaminated water toward
the Ogallala Formation recovery wells.
The operating parameter affecting cost or performance for this technology is the extraction rate.  Table 3
presents the average pump rate and other performance parameters.

                                Table 3.  Performance Parameters
-**'•< feararheter - '" .<
Average Pump Rate
Performance Standard (effluent)
Remedial Goal (aquifer)
- Value
84,200 gpd*
0.05 mg/L total chromium
0.10 mg/L total chromium
           The average system extraction rate from November 1993 until December 1996 was approximately
           84,200 gpd, based on a total volume of 94 million gallons extracted and a 95% operation rate.
           Source: [3,4]
      EPA
        U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
                Technology Innovation Office
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                                                           Odessa Chromium IIS Superfund Site
                     TREATMENT SYSTEM DESCRIPTION (CONT.)
Timeline-
Table 4 presents a timeline for this application.
                                      Table 4.  Timeline
Start Date
January 1992
July 1992
August 1992
May 1993
November 1993
September 1996
March 1997
December 1997
End Date
July 1992
August 1992
May 1993
August 1993
...
—
—
—
Activity
Remediation system constructed
Trial run conducted and injection wells clogged with iron and calcium
Redesign and pilot studies performed
Alterations made to remedial system
Continuous operation of remediation system begun. Monthly
monitoring of groundwater began
Treatment system tested for effectiveness during low flow
Recovery Well PRW-28 constructed in Perched Zone
Plant shut down and modified for collection of Perched Zone water onlv.
Source: [1-4]
                         TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards Ml
The cleanup goals as established by the EPA
and TNRCC are to lower the chromium levels in
the groundwater to less than the maximum
contaminant level (MCL), or Primary Drinking
Water Standard, of 0.10 mg/L This goal is
applied throughout the aquifer, as measured in
all on-site monitoring wells.

Treatment Performance Goals F31	
Additional Information on Goals

The original drinking water standard for
chromium set by EPA was 0.05 mg/L In 1990,
EPA revised the standard to the primary
drinking water standard of 0.10 mg/L.
    Effluent injected into the aquifer from the
    treatment system must have levels of
    chromium below 0.10 mg/L.
Performance Data Assessment T3.4. 61
   As a secondary goal, the remedial system is
   designed to create an inward hydraulic
   gradient toward the site to contain the
   plumes.
   Based on monthly sampling events, cleanup
   goals have been achieved in the Trinity
   Aquifer but not in the Ogallala Formation
   [1,5]. Groundwater monitoring results from
   the January 1997 sampling event indicate
   that chromium concentrations in the
   Ogallala Formation have been reduced, but
   not to levels below treatment goals.
   However, in the Trinity Aquifer, chromium
   levels detected in the 1997 sampling event
   were all found to be below the MCL [6].
   Based on sampling results, the site
   operators have concluded that the plume
   has been contained in both aquifers [4,6].

   Figure 3 illustrates the decline in average
   chromium concentrations in the
   groundwater over time for the Trinity
   Aquifer. The average chromium levels in
   the groundwater have decreased in this unit.
      EPA
           U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
   	Technology Innovation Office
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                                                            Odessa Chromium IIS Superfund Site
                    TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Assessment (Cont.)
   Figure 3 also shows a spiking of the
   average chromium concentrations in the
   Ogallala Formation in 1995.  ITC has
   attributed this spike to desorption of
   chromium from the previously unsaturated
   zone that was affected by increased
   precipitation from  1986 to 1996[5]. Since
   then, concentrations have again dropped.

   The average concentration of chromium
   detected in the groundwater in the Ogallala
   Formation in January 1997 was 0.18 mg/L,
   while the maximum concentration found
   during the same sampling event was 0.88
   mg/L, a level exceeding the MCL [4].
                             Effluent chromium levels have met the
                             required performance standard of 0.10
                             mg/L; thus, reinjection of effluent has been
                             possible throughout system operation [4].

                             From 1993 to December 1996, the  P&T
                             system removed a total of 131 pounds of
                             chromium from the groundwater, as shown
                             in Figure 4.  Figure 4 illustrates the decline
                             in contaminant removal rate for the P&T
                             system during the first three years of full-
                             scale system operation (1993-1996).  The
                             chromium removal rate decreased from
                             0.18 pounds per day in December 1993 to
                             0.05 pounds per day in 1996 [4].
       1.20
    c
    to
    0)
    _
    0)
    i
    a
         Mar-92
Mar-93
Mar-94
                                                      Mar-95
Mar-96
                                                                                     Mar-97
                                    -Trinity Aquifer
                                 - Perched Aquifer
          Figure 3. Average Chromium Concentrations from March 1992 - January 1997[3,4]
      EPA
                                     U.S. Environmental Protection Agency
                              Office of Solid Waste and Emergency Response
                              	Technology Innovation Office
                                            159
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                                                           Odessa Chromium IIS Superfund Site
                    TREATMENT SYSTEM PERFORMANCE (CONT.)
                                                                                140
    e!
    S
      0.04
      0.02
      0.00
        Dec-93
Dec-94
                                                     Dec-95
                                                                            Dec-96
                                  • Mass Flux
                       -Mass Removed
          Figure 4.  Mass Flux Hate and Cumulative Chromium Removal (1993 - 1996) [3,4]
Performance Data Completeness
    Data on mass flux and mass removed are
    reported on a monthly basis, and are
    available from the TNRCC.  Annual
    monitoring data were used for Figure 3.

    Annual data on chromium mass removed
    were provided by the TNRCC and were
    used for Figure 4 analyses.
Performance DataCJualitv
                     A geometric mean was used for average
                     chromium concentrations detected in the
                     groundwater in Figure 4 to show the overall
                     trend of chromium levels in the groundwater
                     on an annual basis.

                     When concentrations below detection limits
                     were encountered, half of the detection limit
                     was used for evaluation purposes.
The QA/QC program used throughout the remedial action met the EPA and the TNRCC requirements.
All monitoring was performed using EPA Method 218.1 and EPA-approved methods for pH, total
suspended solids, and other water quality parameters. The vendor did not note any exceptions to the
QA/QC protocols [4].
      EPA
                            U.S.  Environmental Protection Agency
                     Office of Solid Waste and Emergency Response
                                    Technology Innovation Office
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                                                              Odessa Chromium IIS Superfund Site
                               TREATMENT SYSTEM COST
Procurement Process
The TNRCC is the lead authority on this site. WATEC was awarded the construction and operations
contract for the site. ITC was awarded the oversight contract for the site.
Cost Analvsis
    The costs for design, construction, and operation of the treatment system at this site were split 90:10
    by the EPA and the TNRCC, respectively.
Capital Costs F61
Remedial Construction

Mobilization Work                   $334,723

Monitoring Wells -                    $43,500
Sampling/Testing Analysis

Groundwater Collection & Control       $330,944

Installation of Treatment Plant         $884,962

Site Restoration                      $13,542

Site Security                          $3,298

Construction Management            $316,533

Total Remedial Construction        $1,927,502
Operating Costs F61
Operation and Maintenance 1993-      $524,766
1996

Monitoring: Sampling and Analysis      $35,466
1993-1996

Total 1993-1996 Operating Costs     $560,232

1993 Operating Costs (11/93-12/93)       $ 13,060
1994 Operating Costs (1/94-12/94)       $146,260
1995 Operating Costs (1 /95-12/95)       $232,416
1996 Operating Costs (1/96-12/96)       $168,506

Other Costs F61	
                                                    Engineering Design

                                                    Oversight

                                                    EPA Oversight
                                  $417,452

                                   $48,154

                                  $113,978
Cost Data Qualitv
    The costs listed above include the system
    modifications performed in 1993 and in
    1995. There were no other changes to the
    cost of the remedial system for this site
    greater than 10% of the total cost [6].
    Actual capital and operations and
    maintenance cost data are available from
    the TNRCC for this application.
                        OBSERVATIONS AND LESSONS LEARNED
    Actual costs for the P&T application at
    Odessa IIS were approximately $2,487,700
    ($1,927,500 in capital costs and $560,200 in
    operations and maintenance costs), which
    corresponds to $26 per 1,000 gallons of
    groundwater treated and $19,000 per pound
    of chromium removed.

    The ROD specified that the ferrous ion used
    to reduce the chromium would be
    electrochemically produced. This
    requirement limited the on-site system to
    two vendors and potentially increased the
    cost of the treatment unit.

    Average concentrations of chromium in the
    Ogallala Formation spiked between 1993
    and 1 995. The increase may be a result of
    aquifer recharge through chromium-
    containing soil. ITC has determined the
    chromium in the Ogallala Formation is the
    source for chromium in the Trinity Aquifer.
    Because the Ogallala Formation is
    hydraulically connected to the Trinity
    Aquifer, water within the Ogallala Formation
      EPA
            U.S. Environmental Protection Agency
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                    Technology Innovation Office
                                              161
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                                                           Odessa Chromium IIS Superfund Site
                OBSERVATIONS AND LESSONS LEARNED (CONT.)
is expected to continue to move downward
over time, adding additional contaminated
water to the Trinity Aquifer [3].  Continued
extraction from the Ogallala Formation will
help prevent downward migration of the
plume to the Trinity Aquifer.

Chromium levels in the Trinity Aquifer have
been reduced to below the MCL.  Extraction
and monitoring of groundwater in the Trinity
Aquifer will continue to ensure that
concentrations remain stable. If levels of
chromium remain below the MCL, extraction
from this unit will be discontinued and
increased pumping from the Ogallala
Formation will begin [6].

There were several startup problems,
including clogging of injection wells and
encrustation of the multimedia polishing
filter by iron and calcium carbonate that
delayed full-scale operations. These
problems were accommodated through
system modification, and no longer interfere
with operations.  ITC has suggested that
one potential approach to identifying
problems earlier would be to  increase the
length of pilot operations.  At this site, pilot
tests were conducted in hourly increments,
and the results were used to simulate full-
cycle operations.  Had the pilot operations
been conducted for a full 24-hour cycle, it is
likely that the iron fouling problems that led
to clogging could have been identified [2].
 Full-scale operations were delayed by iron
 and calcium encrustation in injection wells
 and the filter.  Future effluent standards set
 for iron could prevent such delays.

 ITC found monthly monitoring of chromium
 levels in influent wells helpful.  However,
 this was not the case for continuous
 monitoring.  The continuous chromium
 monitors installed at this site could not
 detect levels above 1.0 mg/L [2].

 During system operation, ITC determined
 that backwash from the filter system  should
 be equalized and added slowly to the
 influent tank to avoid large changes in the
 influent chemistry. During early system
 operations, backwash water was introduced
 directly into the influent tank. The
 differences between the pH levels in the
 backwash and the influent reduced the
 effectiveness of the reaction tank. The
 backwash storage unit allowed  gradual
 addition  of backwash to the influent.
 Addition of an equalization tank alleviated
 the earlier problems in the reaction tank [2].
  EPA
        U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
	Technology Innovation Office
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                                                           Odessa Chromium IIS Superfund Site
                                      REFERENCES
1.   Record of Decision.  USEPA, Odessa
    Chromium IIS, March 18, 1988.

2.   Lessons Learned.  IT Corporation, January
    1997.

3.   Project Status Draft Report. ITC, January
    1995.

4.   Odessa Chromium IIS Monthly Reports.
    ITC, December 1993/January 1994,
    January 1995, January 1996, January 1997.

5.   Odessa Chromium I  & IIS Superfund Sites
    Treatment System. Waste Abatement
    Technology, Inc. No date listed.

Analysis Preparation	
6.  Correspondence with Mr. Lei Medford,
   TNRCC. February 12, March 5, March 11,
   March 14, June 4, July 29, and December 5,
   1997.

7.  Groundwater Regions of the United States.
   Heath, Ralph.  U.S. Geological Survey
   Supply Paper 2242. 1984.

8.  TNRCC comment on draft report, dated
   May8,1998.
This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
Emergency Response, Technology Innovation Office. Assistance was provided by Eastern Research
Group, Inc. and Tetra Tech EM Inc. under EPA Contract No. 68-W4-0004.
      EPA
            U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
                   Technology Innovation Office
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This Page Intentionally Left Blank
              164

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    Groundwater Containment at
Site FT-01, Pope AFB, North Carolina
               165

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                               Groundwater Containment at
                          Site FT-01, Pope AFB, North Carolina
Site Name:
Site FT-01, Pope AFB
Location:
North Carolina
Contaminants:
Total Petroleum Hydrocarbon
(TPH), free product (JP-4 fuel):
- TPH concentrations in soil
reported as high as 44,000 ppm
- 24,000 gallons of free product in
groundwater
Period of Operation:
11/93 - ongoing (as of 4/98);
projected completion in 2001
Data reported through November
1996
Cleanup Type:
Full-scale cleanup
Vendor/Consultant:
Parsons Engineering Science
Additional Contacts:
U.S. Air Force Air Combat
Command
Technology:
Free product recovery system
consisting of four recovery wells
and one trench. JP-4 is recovered
using a pneumatic skimmer pump
and stored in a product recovery
tank.
Cleanup Authority:
Installation Restoration Program
Regulatory Point of Contact:
Information not provided
Waste Source: Fuel Spill
Purpose/Significance of
Application: Recovery of free
product from groundwater
Type/Quantity of Media Treated:
Groundwater and free product - the areal extent of the plume was
estimated at 1.5 acres. Groundwater is encountered between 2 and 5 feet
below ground surface. The total amount of free product removed as of
November 1996 was 5,163 gallons of JP-4.
Regulatory Requirements/Cleanup Goals:
The operational objective of the free product recovery was to remove liquid-phase contamination as quickly and
cost-effectively as possible to prevent continued contamination of surrounding soil and groundwater.
Results:
Data on system performance were available for the first three years of operation (through November 1996). The
total amount of JP-4 product recovered during this time was 5,163 gallons. Monthly removal rates ranged from
1 to 650 gallons.
Cost:
The capital cost for the system was $289,000. The total cumulative O&M costs from November 1993 through
November 1996 was $66,600. According to the report, accurate month-to-month O&M data were not available;
however, the average monthly O&M costs were reported as $1,800. After three years of operation, the average
O&M costs per unit of contaminant removed was $12.90/gallon of JP-4.
                                               166

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                               Groundwater Containment at
                   Site FT-01, Pope AFB, North Carolina (continued)
Description:
Site FT-01 is located at the Pope AFB in North Carolina.  Soil and groundwater at the site were contaminated
with JP-4 fuel. TPH concentrations as high as 44,000 ppm were detected in soil at the site. The areal extent of
groundwater contamination was estimated to be 1.5 acres with an estimated 24,000 gallons of free product
floating on the groundwater. In September 1993, 3,175 tons of contaminated soil were removed from the site.
In November 1993, a free product recovery system were installed at the site to recover JP-4 fuel.

The free product recovery system included four recovery wells and one trench. A pneumatic skimmer pump was
used to recover the JP-4, which was then stored in a product recovery tank. The system was operational at the
time of this report (April 1998) and is expected to operate through 2001.  Data on cost and performance are
available for the first three years of operation (through November 1996).  During this time, 5,163 gallons of JP-
4 fuel was recovered, with the monthly removal rates ranging from 1 to 650 gallons. The report includes a
graph of JP-4 recovered versus time. As of November 1996, the curve had not flattened, indicating that the
operational objectives of the system were still being met.

The total capital cost for this system was $289,000. The total O&M costs  through November 1996 were
$66,600.  Although accurate monthly O&M costs were not available, the average monthly O&M cost was
$1,800.  The average O&M cost per unit of JP-4 fuel recovered was $12.90 per gallon.
                                               167

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Groundwater Containment  at
Site FT-01,  Pope AFB
 Site Background
This section focuses on the groundwater
containment system located at FT-01,
Pope AFB. A site map for FT-01 is included as
Figure 37.

Contaminants in Soil

•  TPH concentrations detected up to
   44,000 ppm.

•  In September 1993, 3,175 tons of
   contaminated soil were removed from the
   site.

Contaminants in Groundwater

•  The areal extent of JP-4 fuel contamination
   was estimated at 1.5 acres.

•  As much as 24,000 gallons of free product
   are floating on top of the groundwater.

Lithology

•  Fine- to medium-grained sands to 25 feet
   bgs; hard silty clay from a depth of 26 feet
   bgs to 70 feet bgs.
•  Groundwater is encountered between 2 and
   5 feet bgs.

Groundwater Containment System Details

•  Free floating product recovery system.

•  The system consists of four recovery wells
   (RW-1, RW-2, RW-3, and MW-2) and one
   trench.

•  JP-4 is recovered by a pneumatic skimmer
   pump and stored in a product recovery tank.


Operation Period

•  The system began operation in November
   1993 and may operate until 2001.


Total Capital Costs

•  $289,000 for initial capital investment.


Total O&M Costs

•  Total cumulative O&M costs from November
   1993 through November 1996 were $66,600.
 Cost and Performance of Groundwater Containment at Site FT-01
Groundwater Containment with Free Product
Source Removal Operational Objectives

The objective of free product source removal is
typically to remove liquid-phase contamination
as quickly and cost-effectively as possible to
prevent continued contamination of surrounding
soil and groundwater. The emphasis for free
product removal is that the mass of
contaminants is cost effectively removed.

Cost for Operation

Figure 38 illustrates curves of the O&M costs for
the groundwater containment system at
Site FT-01. Accurate month to month data were
not available. The monthly O&M costs average
$1,800. Total O&M costs after three years of
operation were $66,600.


Contaminant Removal

Figure 39 illustrates curves of the removal rates
of JP-4 product at the groundwater containment
system at Site FT-01. Monthly removal rates of
JP-4 product ranged from 1 to 650 gallons. Total
contaminant removal after three years of
operation was 5,163 gallons of JP-4 product. In
November 1996, the curve representing the
cumulative removal rate had not flattened,
indicating that the removal rate was still
adequate for this system's performance and it
was meeting its operational objectives.
                                        168

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                                                           Aircraft
                                                           Mockup
                                                           Burning
                                                           Area
                                                      fe "'!fp|;, Jj'^"^;p3'f*^
                                                        0«*?*^A^^^W, .*•&'/' M'?"^«®'#Vs'?^; <9!"^- 5
         Direction of
      Groundwater Flow
Source: Metcalf& Eddy, 1990
                                           169

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  $70.000



  $50,000



  $50,000
e? $40,000 •
I
Q
0 $30,000
                                                   Figure 38
                                 Monthly and Cumulative O&M Costs vs. Time
                                               JP-4 Free Product
                                             SiteFT-01, PopeAFB
-O&M costs per month ($/month)
-Cumulative O&M costs ($)
        Nov-  Dec-  Mar- Apr-  Jun-  Aug-  Oct-  Dec-  Feb-  Apr- Jun-  Aug-  Oct-  Dec-  Feb-  Apr-  Jun-  Aug-  Oct-
         93    93    94   94   94    94   94   94    95    95   95    95    95   95   96    96    96   96   96
                                                         Months
                                                                                                      RawftOI .ids; O&M costs
       6,000-1
       5,000-
                                                        Figure 39
                                  Monthly & Cumulative JP-4 Product Recovery vs. Time
                                                  SiteFT-01,  PopeAFB
                     -Volume of contaminants removed per month (Gallons/month)
                     -Cumulative Volume of contaminants removed (Gallons)
                        Mar-94
                                      Sep-94
                             Apr-95         Oct-95
                                    Months
                                                                                 May-96
                                                                                               Dec-96
                                                                                                             Jun-97
                                                                                                         Rawft01.xls; Volume
                                                         170

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 Correlation of Costs and Contaminant
 Removal

 Figures 40 and 41 illustrate the relationship
 between the O&M costs and the removal rates
 for the groundwater containment system at
 SiteFT-01.

 Figure 40 illustrates the cumulative O&M cost
 over the cumulative contaminant removal. As of
 November 1996, this curve had not steepened.
 In November 1996, this groundwater
 containment system was operating efficiently for
 this system's performance and was meeting its
 operational objectives.
Figure 41 illustrates curves of the monthly and
cumulative cost per unit of contaminant removal
over the operation time of the technology. The
monthly curve illustrates the cost per gallon of
JP-4 product removal in each month. The
cumulative curve illustrates that the average
cost per unit of contaminant removal was
$12.90/gallon of JP-4 product after three years
of operation time.
  $70,000
  $60,000
  $50,000 -
0 $40,000 -
1
•| $30,000 -
o
  $20,000
  $10,000 -
      $0
                                            Figure 40
                         Cumulative O&M Costs vs. Cumulative JP-4 Recovered
                                       SiteFT-01, PopeAFB
                                                                    -Cumulative O&M costs ($)
                     1,000
                                   2,000           3,000           4,000

                                   Cumulative JP-4 Product Recovered (Gallons)
                          5,000
6,000
                                                                                  RawftOI .xls; $ vs. vol
                                              171

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   $10.000 j
    $1,000:
I
I
o
     $100
      $10:
       $1
                                                     Figure 41
                       Monthly and Cumulative Costs per Gallon of JP-4 Recovery vs. Time
                                               Site FT-01, Pope AFB
-Monthly O&M costs per volume of contaminant recovered ($/gallon)
-Cumulative O&M costs per cumulative volume of contaminant recovered ($/gallon)
         Nov-93  Feb-94  May-94   Aug-94   Nov-94  Feb-95  May-95   Aug-95   Nov-95   Feb-96   May-96  Aug-96   Nov-96
                                                          Months
                                                                                             Rawft01.xls; monthly$pergalovert
                                                        172

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            APPENDIX A



Detailed Cost and Performance Data Table
                173

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  JP-4 Free-Product Recovery Pumping
Fire Protection Training Area No. 4 (FT-01)
             PopeAFB
Date of
contamination
Nov-93
Dec-93
Jan-94
Feb-94
Mar-94
	 Apr-94 	
Mav-94
Jun-94
Jul-94
Aug-94
	 Seo-94
	 Od-94 	
Nov-94
Dec-94
Jan-95
Feb-95
Mar-95

Mav-95
Jun-95
Jul-95


Oct-95
Nov-95

Jan-96



Mav-96 	
Jun-96
Jul-96
	 Aug-96 	

Oct-96
Nov-96
Volume of
contaminants
removed per month
151
240

202
433

417
145
136
134
	 389
150
140
175
95
24
36
63
131
46
36
105
60
650
23
58
121
29
41
15
69
40
66
18
1

	 79 	
Cumulative Volume
of contaminants
151
391
443
645
1.078
1.299
1.716
1.861
1.997
2.131
2.520
2.670
2.810
2.985
3.080
3.104
3.140
3,203
3.334
3,380
3.416
3.521
3.581
-.231

'.312
'.433
4j462
' .503
'J518
' .587
4.627
4.693
4.711
4.712
5.084
I 5.163 	
O&M costs per month
(S/month)
$1,800.00
51,800.00
$1,800.00
$1.800.00
$1.800.00
$1,800.00
$1.800.00
$1,800.00
$1.800.00
$1,800.00
$1,800.00
$1.800.00
$1.800.00
$1.800.00
$1,800.00
$1.800.00
$1.800.00
$1.800.00
$1.800.00
$1,800.00
$1.800.00
$1.800.00
$1.800.00
$1.800.00
$1,800.00
$1.800.00
$1.800.00
$1.800.00
$1.800.00
$1.800.00
$1.800.00
$1,800.00
$1.800.00
$1,800.00
$1.800.00
$1.800.00
$1.800.00
Cumulative O&M
costs (S)
$1.800.00
$3.600.00
$5.400.00
$7.200.00
$9.000.00
$10.800.00
$12.600.00
$14.400.00
$16.200.00
$18.000.00
$19.800.00
$21.600.00
$23.400.00
$25.200.00
$27.000.00
$28.800.00
$30.600.00
$32.400.00
$34.200.00
$36.000.00
$37.800.00
$39.600.00
$41 ,400.00
$43,200.00
$45,000.00
$46,800.00
$48.600.00
$50.400.00
$52.200.00
$54.000.00
$55.800.00
$57.600.00
$59.400.00
$61 .200.00
$63.000.00
$64.800.00
$66.600.00
Monthly O&M costs
per volume of
contaminant
recovered (S/gallon)
$11.92
$7.50
$34.62
$8.91
$4.16
$8.14
$4.32
$12.41
$13.24
$13.43
$4.63
$12.00
$12.86
$10.29
$18.95
$75.00
$50.00
$28.57
$13.74
$39.13
$50.00
$17.14
$30.00
$2.77
$78.26
$31.03
$14.88
$62.07
$43.90
$120.00
$26.09
$45.00
$27.27
$100.00
$1.800.00
$4.84
$22.78
Cumulative O&M
costs per
cumulative volume
of contaminant
recovered (S/ga!lon)
$11,92
$9.21
$12.19
$11.16
$8.35
$8.31
$7.34
$7.74
$8.11
$8.45
$7.86
$8.09
$8.33
$8.44
$8.77
$9.28
$9.75
$10.' 2
$10.26
$10.65
$11.07
$11.25
$11.56
$10.21
$10.58
$10.85
$10.96
$11.30
$11.59
$11.95
$12.16
$12.45
$12.66
$12.99
$13.37
$12.75
$12.90
                             174

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   Groimdwater Containment at
Site SS-07, Pope AFB, North Carolina
               175

-------
                               Groundwater Containment at
                           Site SS-07, Pope AFB, North Carolina
 Site Name:
 Site SS-07, Blue Ramp Spill Site,
 Pope AFB
 Location:
 North Carolina
Contaminants:
Volatile Organic Compounds
(VOCs), free product (JP-4 fuel)
- VOCs in soil detected as high as
l,000ppm
- 75,000 gallons of JP-4 fuel
estimated to be floating on
groundwater
Period of Operation:
11/93 - ongoing (as of 4/98)
Data reported through November
1996
Cleanup Type:
Full-scale cleanup
Vendor/Consultant:
Parsons Engineering Science
Additional Contacts:
U.S. Air Force Air Combat
Command
Technology:
Free product recovery system
consisting of a dual pump recovery
system with one free product cut-
off trench. JP-4 was recovered
using pneumatic skimmer pumps
and stored in a product recovery
tank. The system operates at an
average flow rate  of 1 gallon per
minute (gpm).
Cleanup Authority:
Installation Restoration Program
Regulatory Point of Contact:
Information not provided
Waste Source: Fuel Spill
Purpose/Significance of
Application: Recovery of free
product using active pumping
Type/Quantity of Media Treated:
Groundwater - Groundwater is encountered between 22.5 and 27 feet
below ground surface.
Regulatory Requirements/Cleanup Goals:
The operational objective of the free product recovery was to remove liquid-phase contamination as quickly and
cost-effectively as possible to prevent continued contamination of surrounding soil and groundwater.
Results:
Data on system performance were available for the first three years of operation (through November 1996). The
total amount of JP-4 product recovered during this time was 3,516 gallons. Monthly removal rates ranged from
one to 340 gallons.
Cost:
The capital cost for the system was $394,000. The total cumulative O&M costs from November 1993 through
November 1996 was $96,200. According to the report, accurate month-to-month O&M data were not available;
however, the average monthly O&M costs were reported as $2,600. After three years of operation, the average
O&M costs per unit of contaminant removed was $27.36/gallon of JP-4.
                                              176

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                               Groundwater Containment at
                   Site SS-07, Pope AFB, North Carolina (continued)
Description:
Site SS-07, the Blue Ramp Spill Site, is located at the Pope AFB in North Carolina. Soil and groundwater at
the site were contaminated with JP-4 fuel and VOCs. VOC concentrations as high as 1,000 ppm were detected
in the vadose zone at the site, and the areal extent of the soil vapor plume was .estimated to be 25 acres.
Dissolved VOCs were detected in the groundwater and an estimated 75,000 gallons of free product was floating
on the groundwater. In November 1993, a free product recovery system were installed at the site to recover JP-4
fuel.

The groundwater free product recovery system was a dual pump recovery system with one free product cut-off
trench. JP-4 is recovered with pneumatic pumps and stored in a product recovery tank.  The trench was
extended in 1993 and again in 1995. The system was operational at the time of this report (April 1998) and is
expected to operate for 40 years. Data on cost and performance are available for the first three years of
operation (through November 1996). During this time, 3,516 gallons of JP-4 fuel was recovered, with the
monthly removal rates ranging from 1 to 340 gallons. The report includes a graph of JP-4 recovered versus
time. After April 1995, the curve began to flatten, indicating that the removal rate for the system is slowing.
According to the report, it is recommended that the system be evaluated to determine how to increase product
removal.

The total capital cost for this system was $394,000. The total O&M costs through November 1996 were
$96,200. Although accurate monthly O&M costs were not available, the average monthly O&M cost was
$2.600. The average O&M cost per unit of JP-4 fuel recovered was $27.36 per gallon.	
                                                177

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Groundwater  Containment at
Site SS-07, Pope AFB
 Site Background
This section focuses on the groundwater
containment system located at the Blue Ramp
Spill Site, SS-07, Pope AFB. A site map for
SS-07 is included as Figure 42.


Contaminants in Soil

•  Soil vapor investigations indicate
   concentrations of greater than 1,000 ppm of
   VOCs exist in the vadose zone.

•  The soil vapor plume is estimated at
   25 acres in areal extent.

Contaminants in Groundwater

•  As much as 75,000 gallons of JP-4 free
   product are floating on top of the
   groundwater.

•  Dissolved VOCs have also been detected
   within the groundwater.

Lithology

•  Subsurface soils are silty to clayey fine-
   grained sands.

•  Clay lenses ranging from 1 to 5 feet in
   thickness.

•  Groundwater is encountered between 22.5
   and 27 feet bgs.
Groundwater Containment System Details

•  Dual pump recovery system with one free
   product cut-off trench (Radian Corporation,
   1996).

•  In 1993 and 1995, the free product cut-off
   trench was extended.

•  The system operates at an average
   groundwater flow rate of 1 gpm.

•  JP-4 is recovered by pneumatic skimmer
   pumps and is stored in a product recovery
   tank.
Operation Period

•  The system began operation in November
   1993 and may operate approximately
   40 years.


Total Capital Costs

«  $394,000 for initial capital investment.

Total O&M Costs

•  Total cumulative O&M costs from
   November 1993 through November 1996
   were $96,200.
 Cost and Performance of Groundwater Containment at Site SS-07
Groundwater Containment with Free Product
Source Removal Operational Objectives

The objective of free product source removal is
typically to remove liquid-phase contamination
as quickly and cost-effectively as possible to
prevent continued contamination of surrounding
soil and groundwater. The emphasis for free
product removal is that the mass of
contaminants is cost effectively removed.
Cost for Operation

Figure 43 illustrates curves of the O&M costs for
the groundwater containment system at
Site SS-07. Accurate month to month data were
not available. The monthly O&M costs average
$2,600. Total O&M costs after three years of
operation were $96,200.
                                       178

-------
       Building
         742
                    Grass
Portion of Cut-off
Trench Installed
 in 1995
                  Parking Lot
                                                                     Portion of Cut-off Trench Installed
                                                                      in 1991 (Assumed Location)
                                                                                                         N
                                                                                         i	1  550-Gallon Aboveground Tank
                                                                                     Portion of Cut-off Trench Installed
                                                                                     in 1993 (Assumed Location)
                                                                           Equipment/Pump Building
Source: OHM (June 1995)
                                                                                                   Not to Scale
                            Figure 42. Free Product Recovery System at Site SS-07, Pope AFB
                                                              179

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                                              Figure 43
                                Monthly and Cumulative O&M Costs vs. Time
                                       JP-4 Free Product Recovery
                                         SiteSS-07, PopeAFB
    $120.000 ,
    5100,000 .
     $80,000 .
     $60,000 -
     $40,000.
     $20,000 .
-O&M costs per month ($/month)

-Cumulative O&M costs ($)
        SO?
          Nov- Dec- Mar-  Apr- Jun-  Aug- Oct-  Dec- Feb- Apr-  Jun- Aug-  Oct-  Dec- Feb-  Apr- Jun-  Aug- Oct-
          93   93   94   94   94   94   94   94   95   95   95   95   95   95   96   96   96  96   96
                                                  Months
                                                                                 Raws07.xls; O&M costs
Contaminant Removal

Figure 44 illustrates curves of the removal rates
of JP-4 product at the groundwater containment
system at Site SS-07. Monthly removal rates of
JP-4 product ranged from 1 to 340 gallons. Total
contaminant removal after three years of
operation was 3,516 gallons of JP-4 product.
After April 1995 the curve representing the
cumulative removal rate had begun to flatten,
indicating that the removal rate for this system is
slowing. It is recommended that the system be
evaluated for increasing product removal.


Correlation of Costs and Contaminant
Removal

Figures 45 and 46 illustrate the relationship
between  the O&M costs and the removal rates
for the groundwater containment system at
Site SS-07.

Figure 45 illustrates the cumulative O&M cost
relative to the cumulative contaminant removal.
                      In November 1996, this curve was no longer
                      vertical. In November 1996, this groundwater
                      containment system was operating adequately
                      for this system's performance and meeting its
                      operational objectives of cost-effectively
                      removing contaminants.

                      Figure 46 illustrates curves of the monthly as
                      well as the cumulative cost per unit of
                      contaminant removal over the operation time of
                      the technology. The first curve illustrates the cost
                      per gallon of JP-4 product removal in each
                      month. The cumulative curve illustrates that the
                      average cost per unit of contaminant removal
                      was $27.36/gallon of JP-4 product after three
                      years of operation time.
                                              180

-------
  4,000 ,


  3,500 -


  3,000 -
                                                    Figure 44
                              Monthly & Cumulative JP-4 Product Recovery vs. Time
                                              SiteSS-07, PopeAFB
-Volume of contaminants removed per month (Gallons/month)

- Cumulative Volume of contaminants removed (Gallons)
      Nov-  Dec-  Mar-  Apr-  Jun-  Aug-  Oct-  Dec-  Feb-  Apr-  Jun-  Aug-  Oct-  Dec- Feb-  Apr-  Jun- Aug-  Oct-
       93    93   94    94   94    94    94   94    95   95    95    95   95    95   96    96    96   96    96
                                                       Months
                                                                                                  Rawss07.xls; Volume
   $120,000 -,
   $100,000 -
!
u
    $80,000
    $60,000 -
    $40,000 -
    $20,000 -
                                                   Figure 45
                           Cumulative O&M Costs vs. JP-4 Product Volume Recovered
                                             SiteSS-07,  PopeAFB
                                         -Cumulative O&M costs ($)
                      500        1,000        1,500        2,000       2,500
                                            Cumulative JP-4 Recovered (Gallons)
                                                                 3,000
3,500
                                                                                         4,000
                                                                                              Rawss07.xls; O&M vs. vol
                                                      181

-------
   $10,000 ,
    $1,000 .
I
•g    5100
      $10-
       $1
                                                    Figure 46
                      Monthly and Cumulative Costs per Gallon of JP-4 Recovered vs. Time
                                             SiteSS-07, PopeAFB
- Monthly O&M costs/monthly Volume ($/Gal)

-Cumulative O&M costs/Cumulative Volume (S/Gal)
          Nov-  Jan-  Mar-  May-  Jul-  Sep-  Nov-  Jan-  Mar-  May-  Jul-  Sep- Nov-  Jan-  Mar-  May-  Jul-  Sep-  Nov-
           93   94    94   94    94   94    94    95   95    95   95    95   95    96    96    96    96   96    96
                                                          Months
                                                                                           Rawss07.xls; monSpergalovert
                                                      182

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            APPENDIX A




Detailed Cost and Performance Data Tables
                183

-------
JP-4 Free Product Recovary Pumping
    Blua Ramp Spill Site (SS-07)
           Pope AFB
Date of
contamination
removal
Nov-93
Dec-93
Jan-94
Feb-94
Mar-94
Apr-94
May-94
Jun-94
Jul-94
Aug-94
Sep-94
Oct-94
Nov-94
Dec-94
Jan-95
Feb-95
Mar-95
Apr-95
May-95
Jun-95
Jul-95
Aug-95
Sep-95
Oct-95
Nov-95
Dec-95
Jan-96
Feb-96
Mar-96
Apr-96
May-96
Jun-96
Jul-96
Aug-96
Sep-96
Oct-96
Nov-96
Volume of
contaminants
removed per month
(Gallons/month)
160
340
128
334
192
126
234
78
79
46
226
175
150
220
130
160
135
50
65
35
20
17
7
7
1
2
16
7
3
6
200
6
0
79
12
29
41
Cumulative Volume
of contaminants
removed (Gallons)
160
500
628
962
1,154
1,280
1,514
1,592
1,671
1,717
1,943
2,118
2,268
2,488
2,618
2,778
2,913
2,963
3,028
3,063
3,083
3,100
3,107
3,114
3,115
3,117
3,133
3,140
3,143
3,149
3,349
3,355
3,355
3,434
3,446
3,475
3,516
O&M costs per
month ($/month)
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
$2,600
Cumulative O&M
costs ($)
$2,600
$5,200
$7,800
$10,400
$13,000
$15,600
$18,200
$20,800
$23,400
$26,000
$28,600
$31,200
$33,800
$36,400
$39,000
$41,600
$44,200
$46,800
$49,400
$52,000
$54,600
$57,200
$59,800
$62,400
$65,000
$67,600
$70,200
$72,800
$75,400
$78,000
$80,600
$83,200
$85,800
$88,400
$91,000
$93,600
$96,200
Monthly O&M
costs/monthly
Volume ($/Gal)
$16.25
$7.65
$20.31
$7.78
$13.54
$20.63
$11.11
$33.33
$32.91
$56.52
$11.50
$14.86
$17.33
$11.82
$20.00
$16.25
$19.26
$52.00
$40.00
$74.29
$130.00
$152.94
$371.43
$371.43
$2,600.00
$1,300.00
$162.50
$371.43
$866.67
$433.33
$13.00
$433.33
$2,600.00
$32.91
$216.67
$89.66
$63.41
Cumulative O&M
costs/Cumulative
Volume ($/Gal)
$16.25
$10.40
$12.42
$10.81
$11.27
$12.19
$12.02
$13.07
$14.00
$15.14
$14.72
$14.73
$14.90
$14.63
$14.90
$14.97
$15.17
$15.79
$16.31
$16.98
$17.71
$18.45
$19.25
$20.04
$20.87
$21.69
$22.41
$23.18
$23.99
$24.77
$24.07
$24.80
$25.57
$25.74
$26.41
$26.94
$27.36
                         184

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Pump and Treat and Containment of Contaminated Groundwater at
            the Sylvester/Gilson Road Superfund Site
                   Nashua, New Hampshire
                            185

-------
        Pump and Treat and Containment of Contaminated Groundwater at
                        the Sylvester/Gilson Road Superfund Site
                                  Nashua, New Hampshire
Site Name:
Sylvester/Gilson Road Superfund
Site
Location:
Nashua, New Hampshire
Contaminants:
Chlorinated solvents; volatiles -
nonhalogenated; and heavy metals
(selenium)
- Maximum concentrations detected
in 1980 included methylene chloride
(122,500 ug/L), chloroform (81,000
ug/L), tetrahydrofuran (1,000,000
ug/L), methyl ethyl ketone (80,000
ug/L), and toluene (140,000 ug/L)
Period of Operation:
Status: Ongoing
Report covers: 1982 through
December 1995
Cleanup Type:
Full-scale cleanup (interim results)
Vendor:
Construction:
Weston
O&M:
Joe Fritsch
Metcalf & Eddy
57 Gilson Road
Nashua, NH 03062
State Point of Contact:
Tom Andrews
NHDES
6 Hazen Drive
Concord, MA 03301
(603)271-2910
Technology:
Pump and Treat; Vertical Barrier
Wall; Cap; and Soil Vapor
Extraction
- Groundwater was extracted using
14 wells, located on site, at an
average total pumping rate of 265
gpm
- Extracted groundwater was treated
with addition of chemicals (lime
slurry), flocculation, clarification,
mixed-media pressure filtration, air
stripping (at elevated temperature
(175 °F), and biological treatment
(biological treatment was used for
only 50 of the 265 gpm extracted)
- Treated groundwater was
reinjected on- and off-site through
recharge trenches
- A slurry wall, 4 ft wide, 4,000 ft
long, and as much as 100 ft deep,
encloses the 20-acre site
- A 40-mil HOPE synthetic cap
covers the area inside the slurry wall
- The SVE system included 66 wells
and a boiler/incinerator for
destruction of VOCs
Cleanup Authority:
CERCLA Remedial
- ROD Dates: 7/29/82 and 9/22/83
EPA Point of Contact:
Darryl Luce, RPM
U.S. EPA Region 1
JFK Federal Building
1 Congress Street
Boston, MA  02203
(617) 573-5767
Waste Source:
Waste disposal, drum burial, waste
storage
Purpose/Significance of
Application:
ACLs have been met for all
contaminants, with one exception.
The exception has an ACL which is
less than the state standard and
below the analytical detection limit
for that constituent.
Type/Quantity of Media Treated:
Groundwater
- 1,200 million gallons treated as of December 1995
- LNAPL (toluene) observed in several monitoring wells on site
- Depth to groundwater was not provided for this site
- Extraction wells are located in 3 hydrogeologic units which are influenced
by a nearby surface water
- Hydraulic conductivity in the upper unit ranges from 30 to 50 ft/day
                                                186

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        Pump and Treat and Containment of Contaminated Groundwater at
                         the Sylvester/Gilson Road Superfund Site
                            Nashua, New Hampshire (continued)
Regulatory Requirements/Cleanup Goals:
- The remedial goal for this site were set as alternate concentration limits (ACLs) within the containment structure.
  ACLs were set at 10% of the maximum concentration detected, and consisted of the following: vinyl chloride (95
  ug/L), benzene (340 ug/L), chloroform (1,505 ug/L), 1,1,2-TCA (1.7 ug/L), MEK (8,000 ug/L), chlorobenzene
  (110 ug/L), methylene chloride (12,250 ug/L), toluene (2,900 ug/L), 1,1-DCA (1.5 ug/L), trans-l,2-DCA (1,800
  ug/L), 1,1,1-TCA (200 ug/L), methyl methacrylate (350 ug/L), selenium (2.6 ug/L), and phenols (400 ug/L).
- Risk-based concentration levels were set for groundwater outside of the containment structure.
- A performance goal for the remedial system was to prevent the contaminant plume from further migration.
Results:
- As of December 1995, the remedial action appears to have attained ACLs for all contaminants except 1,1-DCA.
  The levels of 1,1 -DCA are less than the state standard of 81 ug/L and below the analytical detection limit; EPA is
  reportedly considering adjusting the ACL set for this contaminant. From 1986 through 1995, the system removed
  427,000 pounds of contaminants from the groundwater.
- A net inward flow into the containment structure has been maintained, thus reducing downward migration of
  contaminants.
Cost:
- Actual costs for the remedial application at this site were $27,600,000 ($9,100,000 in capital and $18,500,000 in
  O&M), which correspond to $23 per 1,000 gallons of groundwater extracted and $64 per pound of contaminant
  removed.
- The high O&M costs for this site were attributed to the 300 gpm treatment system and the number of staff
  required to operate it.  For many years, the site was staffed with 15 full-time personnel who operated the site 24
  hours/day.
Description:
The Sylvester/Gilson Road site is a 2-acre site. Approximately six acres of the site was used as a sand borrow pit
for an undetermined number of years.  Illegal dumping was first discovered in 1970.  Although the total amount of
hazardous waste disposed at the site had not been determined, documents show that approximately 900,000 gallons
of hazardous waste were discarded at the site during a 10-month period in 1979.  It was estimated that the site was
used for hazardous waste disposal for five years.  In 1981, initial remedial investigations by the state showed high
concentrations of heavy metals and organic compounds in the groundwater under the site. A ROD for this site was
signed in July 1982 and a supplemental ROD in September 1983. In July 1990, EPA issued a BSD for this
application.

The remedial application at this site consisted of a pump-and-treat system, vertical barrier wall, cap, and soil vapor
extraction system.  Groundwater was extracted using 14 wells, located on site, and treated with addition of
chemicals, flocculation, clarification, mixed-media pressure filtration, air stripping, and biological treatment. A
slurry wall encloses the 20-acre site, and a HOPE synthetic cap covers the area inside the slurry wall. To address an
area with LNAPL (toluene) that was identified part-way through the application, a SVE system was installed mat
included 66 extraction wells. As of December 1995, the remedial action appears to have attained ACLs for all
contaminants except 1,1-DCA.
                                                187

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                                                          Sylvester/Gilson Road Superfund Site
                                   SITE INFORMATION
Identifvlna Information:
Treatment Application:
Sylvester/Gilson Road Superfund Site
Nashua, New Hampshire

CERCLIS#: NHD099363541

ROD Dates: July 29,1982 and September 22,
1983.

ESDDate:  July 10,1990

R $* r* limni i n rl
Type of Action:  Remedial

Period of operation: 1982 through 1995
(Performance Data Collected Through
December 1995)

Quantity of groundwater treated during
application:  1.2 billion gallons [1]
Historical Activity that Generated
Contamination at the Site: Illegal waste
disposal

Corresponding SIC Code:  NA

Waste Management Practice That
Contributed to Contamination: Waste
disposal, drum burial, waste storage

Location: Nashua, New Hampshire

Facility Operations:
•   The Sylvester/Gilson Road Superfund Site
    is a 20-acre site. Approximately six acres of
    the site was used as a sand borrow pit for
    an undetermined number of years. Illegal
    dumping was first discovered in 1970. A
    court injunction was issued in 1976, which
    required removal of all materials from the
    site. The operator of the site failed to
    comply with the injunction. In  1978, New
    Hampshire state personnel observed drums
    being stored at the site. A second court
    order was issued in  1979  prohibiting further
    disposal of hazardous wastes on the site.

•   Although the total amount of hazardous
    waste disposed of at the site had not been
    determined, documents show that
    approximately 900,000 gallons of hazardous
    waste were discarded at the site during a
    10-month period in 1979 [5].  It was
    estimated that the site was used for
    hazardous waste disposal for five years [2,
    10].

•   During 1980, the state removed  1,314
    drums of waste from the site and disposed
    of them off site.
    In 1981, initial remedial investigations by
    the State of New Hampshire showed high
    concentrations of heavy metals and organic
    compounds in the groundwater under the
    site. The contamination formed a plume in
    the groundwater, which was moving from
    the site toward Lyle Reed Brook. As the
    plume discharged to Lyle Reed Brook,
    hazardous compounds volatilized into the
    air at levels above acceptable public health
    limits [5].

    In December 1981, the EPA initiated an
    emergency containment action at the site
    that entailed installing a groundwater
    recirculation system.  Four extraction wells
    were installed and pumped for containment
    only; no treatment was provided at this time.
    Contaminated groundwater was extracted
    and discharged to recharge trenches
    upgradient of the disposal area.

    A feasibility study was completed in May
    1982 and a Record of Decision (ROD) was
    issued in July 1982. The ROD required a
    slurry wall to be installed around the 20-acre
    site and a synthetic cap to be placed over
    the area.  The slurry wall and cap were
    designed to isolate the source area and
    provide containment of the groundwater
    plume. The containment system was
    installed by December 1982. The 1982
    ROD also required groundwater extraction
    and treatment, but did not specify a
    treatment method for groundwater.
    However, pilot studies were underway to
    determine the appropriate treatment
    method. A groundwater recirculation
    system operated from 1981 until 1986.
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                                                         Sylvester/Gilson Road Superfund Site
                              SITE! INFORMATION (CONT.)
Background (Cont.)
•   A Supplemental ROD (SROD) concerning
    groundwater extraction and treatment was
    issued in September 1983. The SROD
    established cleanup goals within the slurry
    wall containment area. The groundwater
    treatment plant began operation in April
    1986 to remove metals and organic
    compounds.

•   In July 1990, EPA issued an Explanation of
    Significant Differences (ESD), which
    concluded that certain adjustments to the
    treatment remedy described in the SROD
    were necessary.  These changes included
    an extension of operation by five years,
    additional extraction wells, and measures to
    control a toluene contamination source.
    The source control measures included a soil
    vapor extraction (SVE) system and an
    additional source-area groundwater well.

Regulatory Context:
•   The ROD was signed on July 29,1982, and
    the SROD was signed on September 22,
    1983. An ESD was signed on July 10,
    1990.

Site Logistics/Contacts	
•   The State of New Hampshire and the U.S.
    EPA have entered into a cooperative
    agreement for remediating this site.

•   Site activities are conducted under
    provisions of the Comprehensive
    Environmental Response, Compensation,
    and Liability Act of 1980 (CERCLA),  as
    amended by the Superfund Amendments
    and Reauthorization Act of 1986 (SARA)
    §121, and the National Contingency Plan
    (NCP), 40 CFR 300.

Groundwater Remedy Selection: In the
original ROD, the selected remedy included
construction of a slurry wall and cap with
treatment of groundwater within the slurry wall.
The treatment method was not included in the
original ROD language. The SROD specified
groundwater extraction, treatment via chemical
and biological processes, and discharge to the
on-site aquifer.
Site Lead: State

Oversight: EPA

Remedial Project Manager:
Darryl Luce
U.S. EPA Region I
John F. Kennedy Fed Bldg.
1 Congress Street
Boston, MA 02203
(617) 573-5767

* Indicates Primary Contact
State Contact:
Tom Andrews*
New Hampshire Department of Environmental
Services (NHDES)
6 Hazen Drive
Concord, NH 03301
603-271-2910

Contractors:
Weston (construction oversight)

Metcalf & Eddy (O&M)
Contact: Joe Fritsch
57 Gilson Road
Nashua, NH 03062
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                                                          Sylvester/Gilson Road Superfund Site
                                  MATRIX DESCRIPTION
Matrix IdentifJeaiiQJL
Type of Matrix Processed Through the
Treatment System: Groundwater

Contaminant Characterization n.2.5.61
Primary Contaminant Groups: Heavy metals
and volatile organic compounds (VOCs)

•  The reported initial maximum
   concentrations of organic contaminants
   found in the groundwater included:
   tetrahydrofuran (THF) at 1,000,000 ug/L,
   methylene chloride at 122,500 pg/U methyl
   ethyl ketone (MEK) at 80,000 ug/L, toluene
   at 140,000 pg/L, and chloroform at 81,000
   ug/L Selenium was the primary heavy
   metal compound detected in the
   groundwater.

•   Because toluene and 1,1 -DCA
   concentrations in the groundwater remained
    high after several years of treatment,
   toluene was thought to be floating on the
   water table as a non-aqueous phase liquid
    (NAPL) at the southern end of the site.  In
    1988, the toluene concentration in this area
    was 140,000 pg/L, approximately  26 percent
    of the aqueous solubility of toluene. 1,1-
    DCA concentrations also remained
    persistently high. Based on similar
    concentration contours for toluene and 1,1-
    DCA and the low water solubility for both
    contaminants, 1,1-DCA appeared to be in
    solution with the toluene NAPL.
Figure 1 illustrates the total VOC
concentration contours of the plume as
detected during a December 1980 sampling
event. The outermost concentration contour
marks the 1,000 ug/L levels; the innermost
contour marks the 1,000,000 ug/L levels.

The size of the plume in Figure 1  was
estimated to  be 669,000 square feet at the
1,000 ug/L contour. The plume volume was
estimated at  59.9 million gallons based the
areal extent,  40 feet of plume thickness,
and a porosity of 30%.
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                                                          Sylvester/Gilson Road Superfund Site
                         .MATRJX DESCRIPTION (CONT.)
                                                                            .EM-IZ
             RECHADOE WELL


             CENTER LINE OF RECHftHGE TBENCH
          A  SURFACE WATER SAMPLING LOCATION


          4-  MONITOR WELL


          0  MULTILEVEL WELL


             APPROXIMATE TOTAL VOt CONCENTRATION CONTOUR
        -I.OOO  IN ug/L. I INTERPRETATION ADAPTED FROM
             DECEMBER I9BI GZA PLAN)
      Figure 1. Contaminant Contours (based on results of 1980 Sampling Event) [9]
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                                                            Sylvester/Gilson Road Superfund Site
                              MATRIX DESCRIPTION (CONT.)
Matrix Characteristics Affecting Treatment Costs or Performance

Hydrogeology [4,6]:

The site is underlain by fractured bedrock mantled with 20 to 100 feet of unconsolidated sediments.
These sediments consist of a thin low-permeability glacial till covered by a high-permeability sand and
gravel outwash deposit.
       Unit 1      Stratified Drift
       Unit 2      Glacial Till
       Unit 3      Bedrock
High permeability sand and gravel deposit.  Groundwater
encountered is under water table conditions.

A discontinuous silt, sand, and gravel till layer with low
permeability.  This unit may act as a confining layer in some
places.

A biotite schist of the Merrimack Group and igneous rocks. It
is differentially weathered and fractured. The top of the
bedrock surface is irregular, with variation in relief of more
than 70 feet.
The site is located in the Lyle Reed Brook watershed.  Lyle Reed Brook flows from the east to within 50
feet of the northern property boundary. Two major aquifers within this watershed underlie the site. One
is a sand and gravel stratified drift aquifer, and the other is a fractured bedrock aquifer. A discontinuous
till layer separates the two aquifers.  In general, the till has a lower hydraulic conductivity than the
overlying stratified drift, and may act as a confining layer in some places.

Groundwater in the stratified drift is under water table conditions, while groundwater within the fractured
bedrock is under semiconfined conditions. Groundwater flows northwest through both aquifers and is
encountered 10 to 20 feet below ground surface. The high-concentration area of the plume extended in
a northwestern direction in an elliptical shape from the area of historical liquid waste disposal near the
current location of Trench 3. Contamination has been detected in both aquifers.

Tables 1 and 2 present technical aquifer information and well data, respectively.
                               Table 1. Technical Aquifer Information
Unit Name
Stratified Drift
Glacial Till
Bedrock
NA - not available
Thickness
(ft)
20-80
0-20
>100

Conductivity
(ft/day)
30-50
5 (vertical)
6,500 fta/day
(transmissivity)

Average Velocity
(ft/day)
0.15-0.25
NA
NA

Flow
Direction
Northwest
NA
Northwest

Source:  [6]
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                                                           Sylvester/Gilson Road Superfund Site
                           TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology

Pump and treat (P&T) with precipitation and
high temperature air stripping.
System Description and Operation F11
Supplemental Treatment Technology

Biological treatment for polishing effluent from
the groundwater treatment system prior to
discharge to off-site recharge trenches.
                                 Table 2. Extraction Well Data
Well Name
A
B
C
D
E
F
G
H
1
J
K
Ka
L
La
Note: The average extraction
Unit Name
Stratified Drift
Stratified Drift
Stratified Drift
Stratified Drift
Stratified Drift
Stratified Drift
Stratified Drift
Stratified Drift
Stratified Drift
Stratified Drift
Stratified Drift
Bedrock
Stratified Drift
Bedrock
rate for the extraction system
Depth (ft)
51
56
50
52
50
46
35
46
55
56
34
68
50
85
is 265 gpm.
Yield
(gal/min)
45
45
53
90
61
49
48
90
23
22
17
25
40
25

Source: [1]

System Description [1,4]
•   A 40-mil high-density polyethylene (HOPE)
    synthetic cap and containment wall were
    constructed to minimize infiltration and limit
    contaminant migration. The containment
    wall was constructed of bentonite slurry with
    a design hydraulic conductivity of
    10~7 cm/sec. The slurry wall is
    approximately four feet wide, 4,000 feet in
    perimeter length, and 100 feet deep in some
    places. The bottom of the slurry wall is
    keyed into fractured bedrock.
    Approximately 20 acres is enclosed by the
    wall and covered by the cap.
    The remedial system includes 14
    groundwater extraction wells (listed in
    Table 2) and seven recharge trenches.
    Groundwater is extracted, treated, then
    recharged through the trenches. The
    remedial system has been designed to
    isolate contaminated groundwater, recover
    and treat groundwater from within the slurry
    wall, and induce uniform flushing of the
    upper saturated zone.

    Four extraction wells (B, C, D, E) were
    installed in 1981 and 1982 as part of an
    emergency groundwater interception and
    recirculation system to halt the migration of
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                                                          Sylvester/Gilson Road Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
SvsteflLDescription and Operation (ConU
    contaminated groundwater.  Wells A, F, and
    G were installed in 1986 as part of the
    construction of the site groundwater
    remedial system.  Wells H, I, J, K, Ka, L,
    and La were installed in 1991 as part of the
    modification to the groundwater remedial
    system. Wells A, B, C, D, E, I, and J are
    located in the downgradient portion of the
    site. Wells F, G, and H are located in the
    area of original dumping and contamination.
    Wells K, Ka,  L, and La are located in areas
    that EPA and NHDES determined to be
    areas of persistent contamination. All
    extraction wells are located inside the slurry
    wail.

    Pumping rates for each well were initially
    set by the design engineer. Wells A, B, C,
    D, E, I, and J were pumped at a rate to
    minimize leakage of groundwater from the
    containment area. Wells F,  G, and H were
    pumped at a  rate to maximize recovery of
    contaminated groundwater.  Well L was
    pumped at a  rate to depress the water table
    in the vicinity of the SVE system and
    recover contaminated groundwater.  Well  K
    was pumped to reduce a persistent "hot
    spot".  Bedrock wells Ka and La were
    pumped at very low rates and only as long
    as bedrock contamination was present.

    The treatment system consisted of physical,
    chemical, biological, and thermal unit
    processes (Figure 2). Approximately 265
    gpm of groundwater passed through a pH
    adjustment tank where pH was adjusted to
    approximately pH 11 using a lime slurry.
    Water then flowed to a flocculation tank
    where polymer was added and mixed using
    a variable speed mixer. After f locculation,
    groundwater passed through an inclined
    plate settler where metals in the form of
    suspended solids were removed.  The
    groundwater was then neutralized to pH 7.
    Neutralized groundwater was pumped
    through four (series) mixed-media pressure
    filters to remove small particulate matter.
    Following filtration, the groundwater
    temperature was raised to 175° F. Heated
    groundwater then passed through a stripping
    column for removal of VOCs.  Stripped
    vapors were introduced into a
    boiler/incinerator where No. 2 fuel oil was
burned to create sufficient heat to destroy
organic vapors.

Stripped groundwater was pumped through
a heat exchanger to transfer heat from
treated groundwater to incoming
groundwater.  Stripped groundwater was
then divided into two streams: one stream
(215 gpm) was discharged to on-site
recharge trenches while the other stream
(50 gpm) flowed to biological treatment.
Biological treatment consisted of extended
aeration with an activated sludge and
removed the remaining volatile organic
compounds before discharge to off-site
recharge trenches.

The biological treatment effluent was
discharged off site to remove water from the
containment area, thereby inducing water to
flow into the containment area through the
fractured bedrock below and reducing
leakage downward from the site.

The stripping column used at this site was a
4-foot diameter, 40-foot tall stainless steel
stripper with demister at the top and
stripped water sump at the bottom. The
effective stripping depth was about 20 feet.
The packing used was Type 3Y Flexipack
elements stacked to approximately 16 feet.

Well L and the SVE system were installed to
recover and remove toluene from the
source area identified by a toluene NAPL
floating on the groundwater surface.  The
SVE system, which operated for
approximately three years, consisted of six
headers with eleven extraction/injection
wells on each header.  A variable speed
pump extracted soil gas, and pumped the
vapors into the boiler/incinerator for
destruction of VOCs.

The groundwater monitoring system
consisted of 73 monitoring wells.  All wells
were sampled quarterly. Because there
were many contaminants in the
groundwater, three indicator compounds
were selected to monitor water quality:
toluene, THF, and 1,1-DCA.
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                                                      Sylvester/Gilson Road Superfund Site
                  TREATMENT SYSTEM PESCRIPTION (CONT.)
                    UIME
 300 GPM FROM
 RECOVERY WELLS
    SECURE
                            SETTLING
  LUDGE LANDFILL
              SLUDGE
             DEWATERING
 SLUDGE
THICKENING
                                     IRON SLUDGE
                                      _l
                                        BIOLOGICAL
                                        SLUDGE
K
      INCINERATOR
VAPORS
J
PUMPS



STRIPPING
COLUMN



PREHEATER

4-

               , 5O GPM TO EXTERIOR
                                   PUMPS
               'RECHARGE TRENCH
               , 250 GPM TO INTERIOR
                                             SETTLING
                                                      BIOLOGICAL
                                                      TREATMENT
               rRECHARGE  TRENCHES
Figure 2.  Process Flow Diagram of the Sylvester Groundwater Extraction and Treatment System [4]
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                                                           Sylvester/Gilson Road Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation fCont.)
System Operation [1,4]
•   Quantity of groundwater pumped from
    aquifer by year:
   Year

    1986

    1987

    1988

    1989

    1990

    1991

    1992

    1993

    1994

    1995
Total Volume
  Pumped
  (gallons)

  80,666.000

  138,029,000

  130,086,000

  112,587,000

  125,437,000

  107,285,000

  125,040,000

  125,476,000

  124,395,000

  126,889,000
Unit Name

   1,3

   1,3

   1,3

   1,3

   1,3

   1,3

   1,3

   1,3

   1,3

   1,3
    The remedial system operated from mid-
    1986 through 1995, with the following
    exceptions. Incinerator repair in 1989
    reduced operation for approximately one
    month. The treatment facility was off line
    for a portion of 1991 and 1992 to make
    modifications. According to the site contact,
    the system has operated an average of 88%
    of the time between 1986 and 1995.  The
    treatment facility was designed to operate
    24 hours per day, 365 days per year.

    The groundwater treatment facility started
    up in April 1986, and full-scale operation
    commenced in June 1986. TheSROD
    estimated that cleanup levels inside the 20-
    acre containment area would be met within
    two years of treatment system initiation.
    After two years, the SROD required EPA
    and NHDES to evaluate the site to
    determine the degree to which treatment
    goals had been met.  In  March 1988, the
    evaluation was performed and EPA and the
    NHDES concluded that several "hot spots,"
    or areas of elevated groundwater
    contamination, persisted. An ESD was
    issued in July 1990, which  included
adjustments to the remedy as a result of the
1988 evaluation.

As required by the ESD, the groundwater
treatment plant operated for an additional
four years, six additional recovery wells
were installed in areas of greatest residual
contamination, and the location of an
apparent toluene contamination source was
investigated.

The total pump rate to the treatment facility
did not increase substantially after the
addition of six new extraction wells in 1991.
The groundwater treatment facility was
designed with a capacity of approximately
330 gpm, which could not be increased
without decreasing contaminant removal
efficiency. When new extraction  wells were
placed on line, the pumping rate from less
contaminated existing wells was decreased.

The original remedial design sought to
optimize capture and treatment of
contaminated groundwater while  reducing
leakage of groundwater from the  site. Later
optimization included increasing pumping
rates at extraction wells with demonstrated
greater groundwater contamination and
using a MODFLOW model to maximize
mass removal.

The air stripper media and heat exchangers
were acid washed quarterly to prevent
clogging from iron fouling.

High temperature air stripping was selected
over conventional cold stripping because of
the solubility of the organic compounds
present and the desire to remove 90% of
the VOCs on each pass through the stripper.
While the removal efficiency was above
expectations, the higher concentration of
VOCs and greater total mass of pollutants
resulted in a longer-than-expected treatment
period to reduce groundwater
concentrations to cleanup goals.
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                                                         Sylvester/Gilson Road Superfund Site
                     TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation (Cont.)
    In 1994 to 1995, a Remedial Action
    Evaluation Study was conducted to
    determine whether the remedy was
    protective of human health and the
    environment. The study concluded that the
    remedy used at the Sylvester/Gilson Road
    site was effective and that cleanup goals
    had been met. Groundwater extraction and
              treatment ceased on December 31,1995 and
              access to the site was limited. On January 1,
              1996, a three-year standby period was begun at
              the site.  During this period, groundwater
              treatment equipment at the site will be
              maintained and kept in a ready state in the
              event that treatment must resume.
Operating Parameters Affectina Treatment Cost or Performance
Table 3 presents parameters affecting performance for this technology.
                               Table 3.  Performance Parameters
                fneter
                         Value
        Average Pump Rate
                       265 gpm
   Performance Standard (Effluent)
1.  Same as remedial goals for effluent discharged to
   recharge trenches.

2.  MCLs for effluent discharged outside the slurry wall.
      Remedial Goal (within the
       containment structure)
       Vinyl Chloride
         Benzene
        Chloroform
    1,1,2-Trichloroethane
    Methyl Ethyl Ketone
       Chlorobenzene
    Methylene Chloride
         Toluene
     1,1-Dichloroethane
  Trans-1,2-Dichloroethane
    1,1,1-Trichloroethane
    Methyl Methacrylate
         Selenium
         Phenols
  95 ug/L
 340 ug/L
1,505 ug/L
  1.7 ug/L
8,000 ug/L
 110 ug/L
12,250 ug/L
2,900 ug/L
  1.5 ug/L
1,800 ug/L
 200 ug/L
 350 ug/L
  2.6 ug/L
 400 ug/L
Source: [5]
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                                                         Sylvester/Gilson Road Superfund Site
                     TREATMENT SYSTEM DESCRIPTION (CONT.)
Timeline
Table 4 presents a timeline for this remedial project.

                                  Table4. Project Timeline
!' Start Data 	
7/29/82
9/22/83
10/83
7/82
4/84
6/86
7/90
9/91
3/92
...
1/96
End Date
—
—
3/84
12/82
4/86
—
—
3/92
	
12/95
—
. Activity '•".. ./%>? '•?' - '- >
/* '
Original ROD issued
SHOD issued
Treatment facility designed
Slurry wall installed and synthetic cap placed over 20-acre area
Groundwater treatment facility constructed
Full-scale operations of groundwater treatment facility begin
ESD extending the operation of the treatment system, adding six new wells, and initiating toluene
source removal actions issued
Six additional extraction wells installed to enhance plume recovery
Soil vapor extraction system added to remove toluene NAPL on groundwater surface
Remedial goals achieved and groundwater extraction and treatment system shut down
Three vear standby period beaun
Source: [2, 3, 7]
                         TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards T81
The remedial goal for this site was to clean up
groundwater to meet the recommended
Alternate Concentration Levels (ACLs) within
the containment structure.  ACLs were set for
14 groundwater contaminants, as shown in
Table 3, at 10% of the maximum concentration
detected. These limits were established to be
protective of the bentonite slurry containment
wall and the surrounding groundwater outside
the containment system.

Treatment Performance Goals F81	
Additional Information on Goals [8]

    Risk-based concentration levels were set for
    groundwater outside of the containment
    structure.  Treated water discharged to
    infiltration trenches outside the slurry wall
    must meet maximum contaminant levels.

•   Volatization from Lyle Reed Creek must be
    reduced to acceptable exposure levels.
    One performance goal of the remedial
    system was to prevent the contaminant
    plume from further migrating. The slurry
    wall was designed to eliminate horizontal
    flow of contaminants; the
    extraction/infiltration system was designed
    to hydraulically minimize downward leakage
    of contaminants to the bedrock aquifer
    below.
    Another goal of the treatment system was to
    reduce contaminant concentrations by 90%
    with each pass through the treatment train.
    It was envisioned that treating two pore
    volumes would reduce groundwater
    concentrations by 99%.
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                                                         Sylvester/Gilson Hoad Superfund Site
                    TREATMENT! SYSTEM PERFORMANCE (CONT.)
Performance Data Assessment M. 4. 5. 71
For the purpose of this analysis, total
contaminants includes all those contaminants
listed in Table 3.

•   According to the site contact, as of
    December 1995, the remedial action
    appears to have attained ACLs for all
    contaminants except 1,1-DCA. The levels
    of 1,1-DCA are below the New Hampshire
    groundwater quality standards of 81 ug/L
    and below the detection limit of analytical
    equipment feasible at this time.  EPA is
    reportedly considering adjusting the ACL set
    for this contaminant.

•   A slurry wall and cap were installed to
    contain the contaminant plume and
    minimize groundwater flow into and through
    the site, which would have carried
    contaminants further downgradient.
    Eliminating infiltration reduced the
    downward migration of groundwater into the
    bedrock.  The extraction system further
    reduced downward migration by extracting
    more groundwater than was injected thus
    maintaining a net inward flow into the
    containment structure.

    Figure 3 presents the removal of
    contaminants through the treatment system
    from 1986 through 1995. The treatment
    system was shut down in December 1995.
Performance Data Completeness
The mass flux data show that the mass of
contaminant removed per day increased
from 1986 to 1988 and reached a maximum
of 512 pounds per day on average. The
mass removed per day decreased in 1989
to 72 pounds and continued to decrease to
less than 10 pounds per day in 1995.  The
total  mass removed curve demonstrates
that the mass of contaminants removed
between 1986 and 1988 was 368,000
pounds,  and between 1988 and 1995 was
only 59,000 pounds.

From 1986 through 1995, the P&T system
removed approximately 427,000 pounds of
contaminant mass from 1.2 billion gallons of
groundwater treated.

Most contaminant concentrations decreased
after the treatment remedy was installed.
However, two contaminants, toluene and
1,1-DCA, showed persistently high
concentrations until a source control
measure (SVE) aimed at removing a
toluene NAPL was implemented.

Figure 4 illustrates changes in total VOC
concentrations in the groundwater since the
remedial system was shut down. The total
VOC measurement is the cumulative
concentrations of contaminants detected in
all monitoring wells. These data show that
total concentrations are not rebounding.
   For the purpose of the analyses shown in
   Figure 3, annual flow rates, influent
   concentrations, mass removed data, and
   percent operational data were provided by
   the site contact.

   Quarterly data are available; however, an
   annual average was used in this report to
   present the data.

   The total VOCs data were taken from  a
   common set of monitoring wells to
   demonstrate how contaminant
   concentrations are changing over the entire
   site.
Contaminant mass removal was determined
using analytical results from influent
samples, along with flow rate data. Annual
averages were used to calculate total mass
removed and daily mass flux.

Mass flux data was calculated with the
following equation:

mass flux = (QxC)/ %operational,
where:

mass flux = pounds per day
Q = total yearly flow in gallons per year
C( = average annual influent concentration
in pounds per gallon
% operational = days of operation per year
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                                                        Sylvester/Gilson Road Superfund Site
                    TREATMENT SYSTEM PERFORMANCE (CONT.)
Performance Data Qualitv
The QA/QC program used throughout the remedial action met the EPA and the State of New Hampshire
requirements. All monitoring was performed using EPA-approved methods, and the vendor did not note
any exceptions to the QA/QC protocols.
     1000
     100
  £
  I
                                                               450,000

                                                              • • 400,000

                                                               350,000

                                                               300,000 1"
                                                               250,000

                                                               200,000

                                                               150,000

                                                               100,000'

                                                               50,000
        1986
1987
1988     1989    1990    1991
                                                     1992
                                             1993    1994
1995
                        • Mass Flux (Ib/day)
                               -Total Mass Removed (Ibs)
   Figure 3. Mass Flux Rate and Cumulative Contaminant Removal (June 1986 - December 1995) [1]
  8
  o
           Sep-94   Apr-95    Oct-95   May-96    Dec-96   Jun-97    Jan-98    Jul-98

   Figure 4.  Total VOC vs. Time (1995 -1997) Data Represents the Sum of All VOCs Detected [1]
      EPA
                                           U.S. Environmental Protection Agency
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                                                            Sylvester/Gilson Road Superfund Site
                                TREATMENT SYSTEM COST
Procurement Process F11
The NHDES is the lead for this site. Weston was the Remedial Action Contractor.
Cost Analysis Ml
•   All costs through 1995 for design, construction and operation of the treatment system at this site
    were shared by the U.S. EPA (90%) and the State of New Hampshire (10%). As of 1996, all costs
    for the site have been borne by the State of New Hampshire.
Capital Costs Ml
 Remedial Construction
 Slurry Wall & Cap
 Groundwater Extraction and
 Treatment Facility
     Change Order #1
     Change Order #2
     Change Order #3
 Groundwater Treatment
 Facility Modifications
     Change Order #1

     Change Order #2
     Change Order #3
 Groundwater Treatment
 Facility Landfill Closure
   Total Site Construction
 $2,200,000
 $5,375,000

    $14,844
   $118,863
   $124,947
 $1,385,000

   Period of
Performance
   Extension
   $39,179
   $31,329
  $109,465

$9,069,465
                   Operating Costs m
        Operating and
         Year
         1986
         1987
         1988
         1989
         1990
         1991
         1992
         1993
         1994
         1995
         1996
         1997
     Total Annual
     Operating
     Expenses

Other Costs rn
Maintenance Cost
          Cost
        $1,142,411
        $1,615,500
        $1,590,169
        $1,574,255
        $1,908,630
        $1,896,018
        $1,981,405
        $1,961,017
        $1,940,022
        $2,116,624
          $375,385
  $366,170 (estimated)
       $18,467,606
                                                    Remedial Design Cost
                                                    Slurry Wall & Cap                   $180,741
                                                    Groundwater Treatment Facility       $291,200
                                                    Groundwater Treatment Facility       $183,800
                                                    Modifications
                                                    Remedial Action Evaluation and
                                                    Closure Studies
                                                    Remedial Action Investigation         $350,000
                                                    (1988)
                                                    Remedial Action Evaluation and       $810,000
                                                    Closure Study (1994)
Cost Data Quality
Actual cost data were provided by the NHDES site contact.
      EPA
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                                                       Sylvester/Gilson Road Superfund Site
                    OBSERVATIONS AND LESSONS LEARNED
The total construction and operating and
maintenance (O&M) costs for the
Sylvester/Gilson Road site were
approximately $27.6 million (9.1 million in
capital costs and $18.5 million in O&M
costs) which corresponds to $64 per pound
of contaminant removed and $23 per 1,000
gallons treated.

Modifications were made to the system in
1991 to reflect changes required by the ESD
and the site evaluation performed in 1988.
These modifications resulted in a 15%
increase in capital expenditures.  The
modifications included six new extraction
wells and the installation of an SVE system
for toluene source removal.  (Listed as
Groundwater Treatment Facility
Modifications under Capital Costs.)

O&M  costs varied between approximately
$1 and $2 million per year. The system was
initially planned to operate for two years. As
a result of higher than expected
concentrations and overall mass of
contaminants, the remedial system was
required to operate for almost ten years.

The high O&M costs at this site are
attributed to the 300 gpm treatment system
and number of staff required to operate it.
For many years, the site was staffed with 15
full-time personnel who operated the site 24
hours per day.
The slurry wall and cap contained the plume
at the Sylvester/Gilson Road site.
According to the site contact, this remedial
action reduced the concentration of
contaminants in Lyle Reed Brook while most
groundwater contamination was being
isolated and treated within the containment
structure.

Mass flux data from the Sylvester/Gilson
Road site generally shows the typical
asymptotic decline for mass removed using
a P&T system. The mass flux slightly
increased in 1992 to 23 Ibs/day from 19
Ibs/day in 1991. This increase was due to
the addition of seven extraction wells
installed in 1991.

Based on persistent high toluene
concentrations, additional investigations
were performed and identified a toluene
NAPL floating on the groundwater surface.
As a result, a source removal action was
initiated to remove the toluene NAPL after
almost six years of P&T operation. After a
SVE system was installed and removed the
source area, groundwater concentrations
were eventually reduced below cleanup
goals.
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                                                          Sylvester/Gilson Road Superfund Site
                                       REFERENCES
1.   Data provided by site contact, Tom
    Andrews. August, 1997.

2.   U.S. Environmental Protection Agency,
    Record of Decision. July 1982.

3.   U.S. Environmental Protection Agency,
    Explanation of Significant Differences. July
    1990.

4.   U.S. Environmental Protection Agency,
    Evaluation of Groundwater Extraction
    Remedies Phase II. February 1992.

5.   U.S. Environmental Protection Agency, Five
    Year Review. Svlvester/Gilson Road
    Superfund Site. September 1994.
6.  U.S. Environmental Protection Agency,
    Innovative Operational Treatment
    Technologies for Application to Superfund
    Sites. April 1990.

7.  New Hampshire Department of
    Environmental Services, Annual Report
    (1996-1997) The Gilson Road Superfund
    Site. June 1997.

8.  U.S. Environmental Protection Agency,
    Supplemental Record of Decision.
    September 1983.

9.  Plume map from:  Remedial Program
    Evaluation Gilson Road Site. Nashua. NH.
    Weston, July 1989.

10.  Correspondence with John Fritsch, Metcalf
    & Eddy, July 9, 1998.
Analysis Preparation
This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
Emergency Response, Technology Innovation Office. Assistance was provided by Eastern Research
Group, Inc. and Tetra Tech EM, Inc. under EPA Contract No. 68-W4-0004.
      EPA
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    Office of Solid Waste and Emergency Response
                   Technology Innovation Office
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               204

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Pump and Treat of Contaminated Groundwater at
       the United Chrome Superfund Site
              Corvallis, Oregon
                    205

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                  Pump and Treat of Contaminated Groundwater at
                            the United Chrome Superfund Site
                                      Corvallis, Oregon
Site Name:
United Chrome Superfund Site
Location:
Corvallis, Oregon
Contaminants:
Heavy Metals (Chromium)
- Testing in 1983-1984 showed
concentrations of chromium up to
3,619 mg/L in the shallow aquifer
and up to 30 mg/L in the deep
aquifer
Period of Operation:
Status: Ongoing
Report covers: August 1988
through March 1997
Cleanup Type:
Full-scale cleanup (interim results)
Vendor:
Operations:
CH2M Hill, Inc.
State Point of Contact:
Tom Penpraze
Utilities Division Manager
Public Works Dept.
City of Corvallis
P.O. Box 1083
Corvallis, OR 97339-1083
Technology:
Pump and Treat
- Currently, groundwater is
extracted using 9 wells in the upper
aquifer and one well in the deep
aquifer
- Pumping rates ranged from 4-11.5
gpm for the upper aquifer and 1.5-
15.8 gpm for the deep aquifer
- Extracted groundwater was
treated with a reduction and
precipitation system until
November 1994; since that time,
extracted groundwater has been
discharged to a POTW without on-
site treatment
Cleanup Authority:
CERCLA Remedial
- ROD Date: 9/12/86
EPA Point of Contact:
Al Goodman, RPM
U.S. EPA Region 10
811 Southwest Sixth Ave.
Portland, OR 97204
(503) 326-3685
Waste Source:
Discharge to unlined disposal pit
Purpose/Significance of
Application:
Extracted groundwater was treated
on-site at the beginning of this
application; however, because
concentrations dropped over time,
on-site treatment was discontinued.
Type/Quantity of Media Treated:
Groundwater
- 62 million gallons treated as of March 1997
- Groundwater is found at 0-10 ft bgs
- Extraction wells are located in two aquifers, with flow from the upper to
lower aquifer and lower to upper at times during the year
- Hydraulic conductivity ranges from 0.5 to 60 ft/day
Regulatory Requirements/Cleanup Goals:
- Cleanup goals require a concentration for chromium of 10 mg/L in the upper aquifer and 0.10 mg/L in the deep
  aquifer.
- The system is also required to hydraulically contain the contaminant plume.
Results:
- Chromium concentrations in both aquifers have been reduced.  In the upper aquifer, average chromium
  concentrations have been reduced from 1,923 mg/L in August 1988 to 18 mg/L in March 1997.  In the deep
  aquifer, average chromium concentrations have been reduced from 1.4 mg/L in August 1991 to 0.11 mg/L in
  March 1997. Cleanup goals for chromium have been met in 11 or 23 wells in the upper aquifer and six of
  seven wells in the deep aquifer.
- Approximately 31,363 pounds of chromium have been removed from the upper aquifer and 96 pounds from
  the deep aquifer, for a total of 31,459 pounds as of March 1997.
                                              206

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                  Pump and Treat of Contaminated Groundwater at
                            the United Chrome Superftmd Site
                              Corvallis, Oregon (continued)
Cost:
- Actual costs for pump and treat were $4,637,160 ($3,329,840 in capital and $1,307,320 in O&M), which
  correspond to $75 per 1,000 gallons of groundwater extracted and $140 per pound of contaminant removed.
- Annual operating costs dropped by an order of magnitude when use of the treatment system was discontinued
  in 1992.
Description:
United Chrome products is a former industrial hard chrome plating facility that manufactured and repaired hard
chrome plated parts from 1956 until early 1985.  In 1956, a disposal pit for liquid waste was dug in the area west
of the former on-site building, and chromium-laden wastewater was discharged to the pit from 1956 to 1982. In
June 1983, EPA conducted a field investigation at the site, discovering chromium contamination in on-site
surface water and soils. The site was placed on the NPL in September 1984 and a ROD was signed in September
1986.

Groundwater contamination was addressed in two phases. Phase 1 was directed at remediation of the upper
aquifer and began in August 1988. Phase 2 was directed at remediation of the deep aquifer and began in
September 1991.  Currently, groundwater is extracted using nine wells in the upper aquifer and one well in the
deep aquifer. Until November 1994, extracted groundwater was treated on site; since that time, extracted
groundwater has been discharged to a POTW without on-site treatment.  Chromium concentrations in both
aquifers have been  reduced, but have not yet met cleanup goals. Future operations of the groundwater extraction
systems will be determined following a 1998 investigation of the remaining soil in the area of the former plating
tanks and the disposal pit.	'
                                              207

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                                                                 United Chrome Superfund Site
                                   SITE INFORMATION
Identifying Information:
United Chrome Superfund Site
Corvallis, Oregon

CERCLIS#: ORD009043001

ROD Date: September 12,1986

ESDDate:  December 12,1991



Background	
Treatment Application:
Type of Action: Remedial

Period of operation: 8/1/88 - Ongoing
(Mass Removal Data Collected From 8/88
through 3/97)
(Monitoring Well Data Collected from 8/88
through 12/96)

Quantity of groundwater treated during
application [1]: 62 million gallons
Historical Activity that Generated
Contamination at the Site: Chrome plating

Corresponding SIC Code: 3471 (Plating of
Metals)

Waste Management Practice That
Contributed to Contamination:  Discharge to
unlined disposal pit

Facility Operations [1-4]:
•   United Chrome Products is a former
    industrial hard chrome plating facility that
    manufactured and repaired hard chrome
    plated parts from 1956 until early 1985.

    In 1956, a disposal pit for liquid waste was
    dug in the area west of the former on-site
    building.  Plating tanks were located just
    northeast of the disposal pit.  Chromium-
    laden wastewater was discharged to the pit
    from 1956 to 1982. Sludges were removed
    from the pit and disposed of under the
    guidance of the Oregon  Department of
    Environmental Quality (DEQ) in 1982 and
    1983.

•   In June 1983, EPA conducted a field
    investigation at the site, discovering
    chromium contamination in on-site surface
    water and soils.  United Chrome Products
    was placed on the National Priorities List
    (NPL) on September 21, 1984.

•   EPA performed contaminated soil removal
    activities at the site from July 2, 1985 until
    November 6,1985. An on-site surface
    drainage ditch was dammed and rerouted as
    part of remedial  activities in 1988.
      EPA
•   Groundwater contamination was addressed
    in two phases. Phase I was directed at
    remediation of the upper aquifer and
    containment of the plume.  Phase II focused
    on remediation of the lower aquifer. Phase I
    began in August 1988 and Phase II began in
    September 1991.

Regulatory Context:
•   The Record of Decision (ROD) for the site
    was signed on September 12, 1986.

•   An Explanation of Significant Differences
    (ESD) was signed on December 12,1991.

•   Site activities are conducted under
    provisions of the Comprehensive
    Environmental Response, Compensation,
    and  Liability Act of 1980 (CERCLA), as
    amended by the Superfund Amendments
    and  Reauthorization Act of 1986 (SARA)
    §121, and the National Contingency Plan
    (NCP), 40 CFR 300.

Groundwater Remedy Selection: The
selected remedy was for extraction, treatment,
and surface discharge of groundwater from the
unconfined and confined aquifers and limited
excavation of contaminated soil and removal of
plating tanks and residual sludge.  The remedy
was modified by the ESD that allowed for
discharge to the City of Corvallis Publicly Owned
Treatment Works (POTW) in accordance with
the Pretreatment Requirements.
            U.S. Environmental Protection Agency
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                                                                  United Chrome Superfund Site
                              SITE INFORMATION (CONT.)
Site Logistics/Contacts
Site Lead:  PRP

Oversight: EPA

Site Contact:
Tom Penpraze
Utilities Division Manager
Public Works Department
City of Corvallis
P.O. Box 1083
Corvallis, OR  97339-1083

indicates primary contact
Remedial Project Manager:
Al Goodman*
U.S. EPA Region 10
811 Southwest Sixth Avenue
Portland, Oregon 97204
(503) 326-3685

Treatment System Vendor:
Operations Contractor: CH2M Hill, Inc.
                                 MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed Through the
Treatment System:  Groundwater

Contaminant Characterization	
Primary Contaminant Groups: Chromium

•   The contaminant of concern in the
    groundwater is chromium. The groundwater
    is contaminated with the hexavalent
    chromium species. However, cleanup
    standards are set for total chromium.
    Likewise, laboratory analyses test for total
    chromium. For these reasons, chromium
    levels tested and regulated at the United
    Chrome site are for total chromium [3].

•   Initial testing for chromium in the
    groundwater in 1983 revealed levels of up to
    3,619 mg/L in the shallow aquifer and 3.0
    mg/L in the deep aquifer. Later sampling in
    1984 revealed levels of chromium of up to
    30 mg/L in the deep aquifer [3].

•   The contaminant plume in the upper
    unconfined aquifer as estimated by the 1985
    remedial investigation (Rl) was
    approximately 1 acre in size and 17 feet
    thick, with a plume volume of over 2 million
    gallons. The Rl revealed that the
   contaminant plume in the deep aquifer was
   approximately 1.4 acres in size and 15 feet
   thick, with a plume volume of 2.4 million
   gallons [5].

   In 1988, a plume map was drawn to show
   the extent of contamination. Figure 1 shows
   the approximate boundary of the chromium
   contamination plumes in the upper and deep
   aquifers prior to treatment in August 1988.
   At that time, chromium concentrations in the
   upper aquifer as high as 19,000 mg/L were
   measured near the location of the plating
   tanks.

   Based on the plumes shown in Figure 1, the
   surface areas of the upper and deep plumes
   were 1.5 and 1.7 acres, respectively. The
   upper plume had migrated to the northeast
   concurrent with on-site flow direction. The
   chromium contamination plume in the deep
   aquifer migrated northeast of the former
   plating tanks, concurrent with groundwater
   flow in the deep aquifer.
      EPA
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                   Technology Innovation Office
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                                                            United Chrome Superfund Site
                        MATRIX DESCRIPTION (CONT.)
Figure 1.  Chromium Contaminant Plumes in the Upper and Deep Aquifers Prior to August 1988 [2]
  EPA
        U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
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                                                                   United Chrome Superfund Site
                             MATRIX DESCRIPTION (CONT.)
Matrix Characteristics Affecting Treatment Costs or Performance
Hydrogeology [2,5]:

The site hydrogeology consists of four hydrogeologic units, beginning with an upper aquifer (also called
the upper zone) underlain by an upper aquitard and ending with a deep aquifer underlain by a lower
aquitard.
     Unitl   Upper Aquifer
     Unit 2   Upper Aquitard
     Unit 3   Deep Aquifer
                         Approximately 18 feet thick and consisting of fine silt overlying the
                         upper aquitard. Recharge to the upper aquifer is limited.

                         Stiff dark gray clay, ranging from 2 to 10 feet thick, that grades into
                         deep aquifer soils at about 23 feet below the ground surface.

                         Interbedded silty sand and sandy gravel, ranging from 15 to 25 feet
                         thick. It is semiconfined above by the upper aquitard and confined
                         below by the lower aquitard. Recharge is supplied from the overlying
                         silts.  Water in this aquifer is used for drinking purposes. The nearest
                         drinking water well is approximately 3,000 feet northeast of the site.
                         Recharge to the lower aquifer is not limited.

 Unit 2    Lower Aquitard  Plastic clay at least 40 feet thick.

Groundwater in the upper and deep aquifers regionally flows northeast.  The unconfined water table in
the upper zone fluctuates seasonally between 0 and 10 feet below the ground surface. Based on
water level comparison between aquifers, groundwater flow through the upper aquitard is estimated
as high as 0.4 foot per year from the upper aquifer to the deep aquifer. For about one month a year
during dry summer conditions, the groundwater flows from the deep aquifer to the upper aquifer.

Tables 1 and 2 present technical aquifer information and well data, respectively.

                          Table 1.  Technical Aquifer Information
Thickness
Unit Name (ft)
Upper Aquifer 15-18
Deep Aquifer 1 5 - 25
Conductivity
(ft/day)
0.5 - 2.5
50-60
Average Velocity
(ft/day)
0.008 - 0.04
0.04-0.16
Flow Direction
North to
Northeast*
North to
Northeast
'Previously, local groundwater flow in the upper aquifer was affected by a former drainage ditch and flowed south
to southeast. The ditch has since been dammed and rerouted.
     Source: [5]
                          TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology

Pump and treat (P&T) (original system)
Pump and discharge to POTW (current system)
                                              Supplerriental Treatment Technology

                                              None
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                                                          U.S. Environmental Protection Agency
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                                                                    United Chrome Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation PI ,2,6,7,91
                                  Table 2. Extraction Well Data
Wells
23 Wells
7 Wells
*Pumping rate for all wells
Unit Name
Upper Aquifer
Deep Aquifer
in each unit
Depth (ft)
9-19
35-40
Design Pumping
Rate (gpm)*
7.5
10.0
     Source: [1,7]

System Description
•   Since 1988, groundwater has been extracted
    from both aquifers. The initial extraction
    system used 23 wells in the upper aquifer
    and seven in the deep, as listed in Table 2.
    The current extraction system consists of 10
    recovery wells, nine for the upper aquifer
    and one for the deep aquifer. Extracted
    water is discharged to the City of Corvallis
    POTW.

•   Two infiltration basins and one infiltration
    trench (discontinued in 1993) were
    constructed to inject water from the City of
    Corvallis into the upper aquifer.

•   Extracted water from the upper aquifer was
    formerly treated through a reduction and
    precipitation system with a 50 gpm capacity;
    however, since November 1994, chromium
    levels have been sufficiently reduced to
    allow discharge to the POTW in accordance
    with Pretreatment Standards. Extracted
    water from the deep aquifer has always
    been discharged to the POTW.

•   Recovery wells were placed throughout the
    plume, with higher extraction rates from
    recovery wells with higher chromium
    contamination levels. No computer model
    was used, and upper zone extraction well
    spacing was determined from a pump test
    and plume geometry.  Pumping rates are
    adjusted with orifice plates.  Originally, 23
    extraction wells were placed in the upper
    aquifer and seven extraction wells were
    placed in the deep aquifer. As chromium
    concentrations in extraction wells decreased
    below remedial goals, pumping from these
    wells was stopped, as discussed in the
    System Operation section.
•   Groundwater quality is monitored semi-
    annually through a network of seven
    monitoring wells in the upper aquifer and five
    monitoring wells in the deep aquifer. Active
    extraction wells (nine in the upper aquifer
    and one in the deep aquifer) are monitored
    quarterly.

System Operation
•   Average groundwater pumping rate from
    aquifer in gallons per minute (gpm):
   8/1/88 -


   1/1/89 -
12/31/88


12/31/89
1/1/90 -
6/1/90 -
1/1/91 -
1/1/92 -
1/1/93 -
1/1/94 -
1/1/95 -
1/1/96 -
1/1/97 -
12/31/90
12/31/90
12/31/91
12/31/92
12/31/93
12/31/94
12/31/95
12/31/96
• 3/31/97
 Unit

Upper

Deep

Upper

Deep

Upper

Deep

Upper

Deep

Upper

Deep

Upper

Deep

Upper

Deep

Upper

Deep

Upper

Deep

Upper

Deep
  Average
Pumping Rate
   (cmml

    10.4

   None

    9.3

   None

    11.5

    1.6

    11.2

    6.6

    8.8

    5.5

    6.4

    15.8

    4.5

    4.0

    4.4

    10.1

    4.0

    1.5

    7.0

    3.2
      EPA
             U.S. Environmental Protection Agency
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                                                                   United Chrome Superfuntf Site
                     TREATMENT SYSTEM (DESCRIPTION (CONT.)
    The volume of water in the upper aquifer
    available for extraction is limited, and the
    upper aquifer becomes dewatered with too
    much pumping. Clean potable water was
    reinjected to recharge the aquifer and flush
    any sorbed chromium. By 1992, chromium
    levels had decreased more quickly than
    originally anticipated. Some wells that had
    chromium levels below the 10 mg/L cleanup
    goal were no longer pumped. In addition, by
    1995, chromium levels had decreased
    sufficiently so that treatment of the water
    extracted from upper aquifer was no longer
    necessary.

    In 1991, because of the drop in chromium
    levels in the upper aquifer, an ESD was
    approved for the site to discharge extracted
    water which met pretreatment standards to
    thePOTW.  In November 1995, with
    permission from EPA, the treatment system
    was discontinued.
Adjustments have been made to the upper
aquifer extraction system since 1988 to
optimize contaminant capture.  Higher
pumping rates were used at wells with
greater levels of chromium contamination.
Pumping has continued from nine of the
original 23 extraction wells in the upper
aquifer,  because those nine had elevated
levels of chromium. The remaining
extraction wells in the upper aquifer were not
used because levels of chromium were
either below or slightly above the cleanup
level of 10 mg/L (less than 15 mg/L).

In the deep aquifer extraction system, only
one of the seven original extraction wells
was still operating during 1997. The cleanup
goal of 0.10 mg/L of Cr in the lower aquifer
was met in the other six extraction wells.

Future operations of the groundwater
extraction systems will be determined
following a 1998 investigation of the
remaining soil in the area of the former
plating tanks and the disposal pit.
Operating Parameters Affecting Treatment Cost or Performance
One operating parameter affecting cost or performance for pqmp and treat is the extraction rate. Table 3
presents values for this and other performance parameters.
                               Table 3. Performance Parameters
w^' * < ~ - -.-,-•«-.«-,
u Parameter " - -i, *A
Pump Rate Range
(August 1988 - March 1997)
Remedial Goals
Treatment Performance Goals:
Pretreatment Requirement
^ S "•--'• f~ •%*«** f r< -• r,, „ r
-'.- Value "1 " "'•*,
4.0 - 1 1.5 gpm, upper aquifer
1.5 - 15.8 gpm, deep aquifer
Upper Aquifer 10 mg/L, Cr
Deep Aquifer 0.10 mg/L Cr
Cr
7 Ibs/day maximum average
discharge to POTW
               Source: [1,3,4]
      EPA
         U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
	  Technology Innovation Office
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                                                               United Chrome Superfund Site
                    TREATMENT SYSTEM DESCRIPTION (CONT.)
Timeline
Table 4 presents a timeline for this application.
                                     Table 4.  Timeline
Start Data End Date
9/12/86 —
2/4/87 9/11/87
8/88 —
9/91 —
7/91 —
3792 —
5/92 —
9/92 —
1/94 —
2/94 —
9/94 —
6/95 —
1995 —
1996 —
12/97 —
11/1/92 —
11/28/94 —
•; . Activity - • • ' „ ,'?
ROD signed
Remedial design completed
Phase 1 of the remediation system begun. Pumping
monitoring begun.
Phase II of the remediation system begun. Pumping
and treating from upper aquifer and
and treating from deep aquifer begun.
EW-77, EW-18, and EW-23 shut down
EW-21 shut down
EW-43 shut down
EW-3 shut down
EW-1 shut down
EW-1 1 shut down
EW-1 3 and EW-27 shut down
EW-1 6 shut down
EW-9, DW-13, DW-17, and DW-18 shut down
DW-16, DW-12, and DW-15 shut down
EW-2, EW-7, EW-1 2, and EW-1 5 shut down
ESD signed.
EPA approval to pump groundwater and discharge to POTW without pretreatment received
Source: [2,3]
                        TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards F31
The cleanup goals require a level of 10 mg/L for
chromium in the upper aquifer and 0.10 mg/L
(the current maximum contaminant limit, or MCL)
for chromium in the deep aquifer.
Additional Information on Goals [3]

The cleanup goal of 10 mg/L for chromium in the
upper aquifer was determined to be the
maximum allowable concentration in the upper
aquifer that was still protective of the deep
aquifer, and that met the risk requirement for the
upper aquifer.  In addition, the MCL established
by EPA for total chromium was originally 0.05
mg/L but was revised to 0.10 mg/L in 1992.
Treatment Performance Goals T31
   The primary treatment performance goal is
   to hydraulically contain the contaminant
   plume.
     EPA
            U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
    	Technology Innovation Office
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                                                                  United Chrome Superfund Site
                    TREATMENti SYSTEM PERFORMANCE (CONT.)
Performance Data Assessment F1.61
•   Chromium concentrations in both aquifers
    have been reduced. Figure 2 illustrates the
    decrease in average chromium
    concentrations in both the upper and the
    deep aquifers over time.  Performance data
    indicate that the average chromium
    concentrations in the upper aquifer have
    been reduced 99%, from 1,923 mg/L in
    August 1988 to 18 mg/L in March 1997.
    Average chromium concentrations in the
    deep aquifer have been reduced 92%, from
    1.4 mg/L in August 1991 to 0.11 mg/L in
    March 1997.

•   Cleanup goals for chromium have been met
    in 11 of 23 wells in the upper aquifer and in
    six of seven wells in the deep aquifer.
    Cleanup goals have been met in all
    perimeter wells. In the upper aquifer,
    chromium concentrations in 12 wells remain
    above the 10 mg/L cleanup goal, with a

Performance Data Completeness
 maximum concentration of 64 mg/L. In the
 deep aquifer, chromium concentrations in
 one well remain slightly above the 0.10 mg/L
 cleanup goal, with a maximum concentration
 of 0.11 mg/L

 Approximately 31,363 Ibs of chromium have
 been removed from the upper aquifer and
 approximately 96 Ibs of chromium have been
 removed from the deep aquifer, for a total of
 31,459 Ibs removed.  Figures 3 and 4 show
 mass removal over time from August 1988
 through March 1997 for the shallow and
 deep aquifers, respectively. The mass
 removal rate has decreased since August
 1988. The upper aquifer continues to yield
 approximately 0.8 Ibs/day of chromium;
 however, the deep aquifer yields less than
 0.01 Ibs/day  of chromium.
Average chromium concentrations and mass removal data used in Figures 2, 3, and 4 were provided in
the 1997 First Quarterly Report. Chromium concentrations in individual wells are available in various
quarterly reports.  Monthly data from August 1988 through December 1996, the most recent data
available, were used for Figure 2.  Monthly data from August 1988 through March 1997 were used to
depict mass removal in Figures 3 and 4.

Performance Data Quality

The QA/QC program used throughout the remedial action met EPA and State of Oregon requirements.  All
monitoring was performed using EPA-approved methods, and the vendor did not note any exceptions to
the QA/QC protocols.
      EPA
         U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
	Technology Innovation Office
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                                                            United Chrome Superfund Site
                TREATMENT SYSTEM PERFORMANCE (CONT.)
   10000
    1000
i
I
E
ZJ
O
o
D)
100  -
      10
      0.1 ,-
     0.01
       Aug-87    Dec-88    Apr-90    Aug-91    Dec-92    Apr-94    Aug-95   Dec-96
                                .Shallow Aquifer _«—Deep Aquifer
          Figure 2. Chromium Levels in the Groundwater as a Function of Time [1]
  60.00
                                                                    35,000
          CO
                     i  »  Mass Rux  x  Cumulative Mass Removed i

     Figure 3. Chromium Mass Removed from the Upper Aquifer as a Function of Time [1]
  EPA
                                                   U.S. Environmental Protection Agency
                                           Office of Solid Waste and Emergency Response
                                          	Technology Innovation Office
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                                                                  United Chrome Superfund Site
                               TREATMENT SYSTEM COST
                             -Mass Flux
. Cumulative Mass Removed :
         Figure 4.  Chromium Mass Removed from the Deep Aquifer as a Function of Time [1]
Procurement Process
The City of Corvallis operates the remediation systems. EPA has contracted with CH2M Hill, Inc. to
oversee and evaluate the remediation system.

Cost Analysis                                                                       	

All costs for investigation, design, and construction of the treatment system at this site were borne by
EPA. The City of Corvallis has borne the costs of operation and made payment to EPA under terms of a
Consent Decree.
                                                             U.S. Environmental Protection Agency
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                                                    	   Technology Innovation Office
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                                                                 United Chrome Superfund Site
                         TREATMENT SYSTEM COST (CONT.)
Capital Costs [8]
Administration and Mobilization
Monitoring Wells and Sampling
Site Work
Groundwater Extraction
Treatment System
Construction Management and
Other Engineering Services
State Oversight
Other Costs
Total Remedial Construction










Cost Data Quality

$745,035
$131,903
$300,195
$611,669
$1,374,625
$130,235

$13,656
$22,522
$3,329,840











Operating Costs [9]
1987-1 998 (fiscal year)
1988-1989
1989-1990
1990-1991
1991-1992
1992-1993
1993-1994
1994-1995
1995-1996
1996-1997
Cumulative 1987-1997
Other Costs \8]
Remedial Investigation/Feasibility
Study
Corps Oversight
Total RI/FS
Remedial Design
State Oversight
Total Remedial Design
EPA Oversight (Contractor included)


$11,722
$177,405
$97,838
$531,626
$251,573
$90,523
$53,428
$36,748
$25,374
$31,081
$1,307,318

$263,832

$4,759
$268,590
$348,810
$15,059
$363,869
$250,000

Actual capital and operating cost data were provided by the EPA Remedial Project Manager (RPM) and
the City of Corvallis for this site.
                      OBSERVATIONS AND LESSONS LEARNED
   Actual costs for the P&T application at
   United Chrome were approximately
   $4,637,160 ($3,329,840 in capital costs and
   $1,307,320 in operating costs. This cost
   corresponds to $75 per 1,000 gallons of
   water treated and $140 per pound of
   contaminant removed.

   Operations costs dropped by an order of
   magnitude when the treatment system was
   discontinued in 1992.

   The City of Corvallis realized the chromium
   level in the treatment system influent would
   drop below pretreatment standards prior to
   complete remediation, and planned
      EPA
 accordingly. They used a modular shorter-
 term treatment system at a cost of $1.3
 million, compared to a more expensive
 permanent remedy.

 Normal groundwater recharge to the upper
 aquifer is limited and reinjection of water into
 the aquifer was necessary to continue
 flushing the contaminated aquifer.
 Therefore, it was necessary to remove as
 little water as possible from the upper aquifer
 and to optimize the contaminant removal per
 gallon of water pumped. The flexible
 pumping and injecting system enabled the
 remediation system to operate in these
 conditions.

         U.S. Environmental Protection Agency
  Office of Solid Waste and Emergency Response
	Technology Innovation Office
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                                                                  United Chrome Superfund Site
                                      REFERENCES
1.  United Chrome Quarterly Report/First
    Quarter 1997. Tom Penpraze, City of
    CorvalliSj April 4, 1997.

2.  Case History:  Effective Groundwater
    Remediation at the United Chrome
    Superfund Site. U.S. EPA Region 10, CH2M
    Hill, undated.

3.  Record of Decision. U.S.  EPA Region 10,
    September 12, 1986.

4.  Explanation of Significant Differences. U.S.
    EPA Region 10, November 1, 1992.

5.  Final Remedial Investigation Report.
    Ecology and Environment, Inc., July 26,
    1985.
6.  Process Modification Request.
    Correspondence U.S. EPA Region 10,
    November 28, 1994.

7.  United Chrome 1996 Annual Report. Tom
    Penpraze, City of Corvallis, March 11, 1997.

8.  Ground-water Remedial Cost Analysis.
    Pump and Treat of Contaminated
    Groundwater at the United Chrome  Products
    Site, Corvallis, OR, unpublished document
    prepared under the U.S. EPA Hazardous
    Site Control Division Remedial Operations
    Guidance Branch.

9.  Draft comments provided by the City of
    Corvallis, August 1998.

10.  Draft comments provided by Allan
    Goodman, EPA Region 10.
Analysis Preparation
This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
Emergency Response, Technology Innovation Office. Assistance was provided by Eastern Research
Group, Inc. and Tetra Tech EMI Inc. under EPA Contract No. 68-W4-0004.
      EPA
            U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
   	Technology Innovation Office
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              220

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Pump and Treat of Contaminated Groundwater at
         the U.S. Aviex Superfund Site,
               Niles, Michigan
                     221

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                   Pump and Treat of Contaminated Groundwater at
                              the U.S. Aviex Superfund Site,
                                       Niles, Michigan
 Site Name:
 U.S. Aviex Superfund Site
 Location:
 Niles, Michigan
Contaminants:
Chlorinated solvents and
volatiles - nonhalogenated
- Maximum concentrations
detected in 1985 sampling event
were 1,1,1-TCA (200,000 ug/L),
1,2-DCA (1,600 ug/L), and diethyl
ether (DEE, at 5,700 ug/L)
Period of Operation:
Status: Ongoing
Report covers: 7/93 - 12/96
Cleanup Type:
Full-scale cleanup (interim results)
Vendor:
EPA Contractor:
Jack Brunner
Tetra Tech EM Inc.
200 East Randolph Dr, Suite 4700
Chicago, IL 60601
(312)856-8700
Air Stripping Tower: LANTAC
Construction Subcontractor: ATEC
Associates Inc.
2777 Finley Road, Unit 4
Downers Grove, IL  60515
Technology:
Pump and Treat
- Groundwater is extracted using 5
wells, located on site, at an average
total pumping rate of 232 gpm
- Extracted groundwater is treated
with air stripping and discharged to
a surface water under a NPDES
permit
Cleanup Authority:
CERCLA Remedial
-RODDate:  9/7/88
State Point of Contact:
Carl Chavez
MDEQ
P.O. Box 30426
Lansing, MI 48909-7926
(517)373-8174
                                 EPA Point of Contact:
                                 Ken Glatz, RPM
                                 U.S. EPA Region 5
                                 77 West Jackson Blvd.
                                 Chicago, IL  60604-3507
                                 (312)886-1434
Waste Source:
Ruptured drums, leaking
underground pipe
Purpose/Significance of
Application:
Performed modeling for system
optimization (MODFLOW and
Randomwalk).
Type/Quantity of Media Treated:
Groundwater
- 329 million gallons treated as of December 1996
- DNAPL suspected in groundwater at this site
- Groundwater is found at 20 ft bgs
- Extraction wells are located in 1 aquifer
- Hydraulic conductivity ranges from 9.1 to 45.4 ft/day
Regulatory Requirements/Cleanup Goals:
- Remediate the groundwater to levels established by MDEQ and the maximum contaminant levels (MCLs)
established by the SDWA.
- Cleanup goals include DEE (43 ug/L), 1,1,1-TCA (200 ug/L), 1,2-DCA (5 ug/L), 1,1-DCE (7 ug/L), TCE (5
ug/L), PCE (0.88 ug/L), benzene (5 ug/L), toluene (2,000 ug/L), ethylbenzene (680 ugL), and xylene (440 ug/L).
- A secondary goal of the system is to create an inward hydraulic gradient to contain the contaminant plume.
                                             222

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                   Pump and Treat of Contaminated Groundwater at
                               the U.S. Aviex Superfund Site,
                                 Niles, Michigan (continued)
Results:
- The average concentration of total contaminants has decreased from 158 to 67 ug/L over 3 1/2 years of
operation; however, contaminant concentrations have declined but remain above cleanup goals.
- Approximately 664 pounds of contaminants have been removed from the groundwater from September 1993 to
December 1996.
- Plume containment has been maintained in this application; however, additional contamination has been
identified outside of the original plume. This has been attributed to historically elevated levels not discovered
during the RI/FS.
Cost:
- Actual costs for the P&T system from 1993-1996 were approximately $1,942,000 ($1,332,000 in capital and
  $610,000 in O&M), which correspond to $5 per 1,000 gallons of groundwater extracted and $2,925 per pound
  of contaminant removed.
Description:
The site was operated as a non-lubricating automotive fluids manufacturer from the early 1960s until 1978.
Fluid manufacturing included repackaging of bulk products and formulation of new products from bulk
ingredients. In July 1972, an underground pipe carrying diethyl ether (DEE) broke during excavation activities,
releasing an unknown quantity to the soil and groundwater. In November 1978, a fire ruptured chemical-storing
drums. The water used to extinguish the fire washed unknown amounts of chlorinated hydrocarbons onto
unpaved areas. After the 1978 release, U.S. Aviex performed a groundwater investigation. The site was placed
on the NPL in 1983 and a ROD was signed in 1988.

The pump and treat system currently in use at U.S. Aviex consists of five  extraction wells installed to 100 ft bgs,
and an air stripper 56 ft tall, 4 ft in diameter, and packed with plastic media. Groundwater monitoring data
indicate that while maximum contaminant concentrations have dropped (up to 99% for 1,1,1-TCA), they remain
above cleanup goals. In addition, contamination has been detected in wells down-gradient of the plume
identified in the RI/FS, and EPA is in the process of further characterizing the plume.
                                              223

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                                                                       U.S. Aviex Superfund Site
                                   SITE INFORMATION
Identifying Information:
Treatment Application:
U.S. Aviex Superfund Site
Niles, Michigan

CERCLIS#: MID980794556

ROD Date: September?, 1988



Rapknrnund
Type of Action: Remedial

Period of operation:  7/93 - Ongoing
(Performance Data Collected Through
December 1996)

Quantity of material treated during
application: 329 million gallons of groundwater
treated
Historical Activity that Generated
Contamination at the Site:  Production of
industrial organic chemicals

Corresponding SIC Code: 2869, (manufacture
of industrial organic chemicals)

Waste Management Practices That
Contributed to Contamination:  Ruptured
drums, leaking underground pipe

Location:  Niles, Michigan

Facility Operations: [1,2]
•   The site, a six-acre parcel of land, operated
    as a non-lubricating automotive fluids
    manufacturer, from the early 1960s until
    1978. Fluid manufacturing included the
    repackaging of bulk products and the
    formulation of new products from bulk
    ingredients.

•   In July 1972, an underground pipe carrying
    diethyl ether (DEE) broke during excavation
    activities, releasing an unknown quantity to
    the soil and groundwater.

•   In response to the 1972 pipeline break, U.S.
    Aviex installed five on-site monitoring wells
    and supplied affected residences with
    bottled water. No remedial work was
    documented from 1972 to 1978.

•   In November 1978, a fire ruptured chemical-
    storing drums. The water used to extinguish
    the fire washed unknown amounts of
    chlorinated hydrocarbons onto unpaved
    areas [1].  Operations at the site ceased  in
    1978.
•   After the 1978 release, U.S. Aviex performed
    a groundwater investigation. In 1982, U.S.
    Aviex entered into an agreement with the
    Michigan Department of Environmental
    Quality (MDEQ) to construct an on-site
    pump and treat (P&T) system to contain the
    identified contamination.

    In November 1983, U.S. Aviex began
    extraction and treatment of groundwater
    from two extraction wells as an interim
    remedy during the remedial investigation.
    Contaminated soils were left in place.

•   In 1983, the site was placed on the National
    Priorities List (NPL).  In 1987, the MDEQ
    installed an alternate water supply system to
    affected residences.

•   The Remedial Investigation/Feasibility Study
    (RI/FS) began in 1985, funded by U.S.
    Aviex. In 1988, U.S. Aviex was declared
    bankrupt and the RI/FS was completed by
    the EPA.

•   Currently, EPA is further characterizing the
    site to determine the full extent of the
    contaminant plume.

Regulatory Context:
•   The 1987 interim remedy was constructed
    under a 1982 agreement with the MDEQ.
    The performance data presented in this
    report do not address the performance of the
    1983 interim remedy, but does address
    performance of the current system from July
    1993 to December 1996.
      EPA
            U.S. Environmental Protection Agency
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                    Technology Innovation Office
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                                                                     U.S. Aviex Superfund Site
                              SITE INFORMATION (CONT.)
Background (Cont.)
•  The Record of Decision (ROD) for the U.S.
   Aviex site was signed on September 7,
   1988, and addressed both on-site and off-
   site contamination in the soil and
   groundwater.  The selected remedy for soil
   remediation was soil flushing; however, it
   was determined after the ROD during pre-
   design investigations that the soil was clean.
   No soil flushing was performed.

•  Site activities are conducted under
   provisions of the Comprehensive

Site Logistics/Contacts	
    Environmental Response, Compensation,
    and Liability Act of 1980 (CERCLA), as
    amended by the Superfund Amendments
    and Reauthorization Act of 1986 (SARA)
    §121, and the National Contingency Plan
    (NCP), 40 CFR 300.

Remedy Selection:  The selected remedy for
groundwater treatment is extraction of
groundwater, followed by treatment through air
stripping, with discharge of treated water to
nearby surface water.
Site Lead: EPA-Lead 1988-1996
          Michigan Department of
          Environmental Quality (MDEQ)-Lead
          1996-Ongoing

Oversight: EPA

Remedial Project Manager:
Ken Glatz
U.S.  EPA Region 5
77 West Jackson Boulevard
Chicago, Illinois 60604-3507
(312) 886-1434

State Contact:
Carl Chavez*
MDEQ
PO Box 30426
Lansing, Michigan 48909-7926
(517) 373-8174
Treatment System Vendors:
EPA Contractor. Jack Brunner*
Tetra Tech EM Inc. (Formerly PRC
Environmental Management, Inc.)
200 East Randolph Drive, Suite 4700
Chicago, Illinois 60601
(312) 856-8700
Air Stripping Tower:  LANTAC
Construction Subcontractor: ATEC Associates,
Inc.
2777 Finley Road, Unit 4
Downers Grove, Illinois 60515
* Indicates Primary Contacts
                                 MATRIX DESCRIPTION
Matrix Identification
Type of Matrix Processed Through the
Treatment System: Groundwater

Contaminant Characterization M. 3. 4. 5. 61
Primary Contaminant Groups: Volatile
organic compounds (VOCs)
   The groundwater contaminants of concern
   detected at the site are the following VOCs:
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                                                                       U.S. Aviex Superfund Site
                             MATRIX DESCRIPTION (CONT.)
    benzene, 1,2-dichloroethane(1,2-DCA), 1,1-
    dichloroethene (1,1-DCE),frans-1,2-
    dichloroethene (frans-1,2-DCE), DEE,
    dichlorofluoromethane (DCFM),
    tetrachloroethene (PCE), 1,1,1-TCA,
    trichloroethene (TCE), and
    trichlorofluoromethane (TCFM).
    Contamination only has been detected in the
    upper water table aquifer.

    The index contaminants of the site are DEE,
    1,1,1-TCA, and 1,2-DCA.

    The maximum concentrations of the index
    contaminants detected in on-site wells
    during a 1985  sampling event (data provided
    by U.S. Aviex) were 1,1,1-TCA (200,000
    ug/L), DEE (5,700 ug/L), and
    1,2-DCA (1,600 ug/L). The concentration of
    1,1,1-TCA was greater than 60% of its
    solubility. The maximum concentrations
    detected in off-site wells during the 1984
    sampling event were 1,1,1-TCA (3,000
    ug/L), DEE (4,800 ug/L), and 1,2-DCA
    (1,700 ug/L).

    The concentration of 1,1,1-TCA detected
    during the 1985 remedial investigation,
    200,000 ug/L,  is greater than 20% of its
    solubility limit.

    Figure 1 illustrates contaminant
    concentrations detected during a 1988 RI/FS
    sampling episode performed by EPA. The
    plume extends southwest of the U.S. Aviex
    property, in the direction of observed
    groundwater flow.
Based on the map shown in Figure 1, the
initial contaminant plume was estimated to
be approximately 18 acres in size. Based on
an average depth of 30 feet as measured
during the RI/FS and a standard porosity of
0.30, the plume volume in 1988 was
calculated for this report to be approximately
53,664,000 gallons.

From  1996-1997 EPA reexamined the
plume. Figure 2 illustrates the plume
delineated by data from a December 1996
quarterly sampling event.

The additional assessment performed in
1997 detected DCA and DEE at
concentrations greater than cleanup levels,
in wells outside the initially identified plume
(see later discussion under performance
data assessment).

DCA has been detected at concentrations
above the cleanup level of 90 ug/L up to
approximately 2,400 feet northwest of the
initial plume boundary.

DEE has a ROD-specified  maximum
contaminant level (MCL) of 43 ug/L  based
on the 1988 MDEQ standard; however, the
health-based drinking water (HBDW)
standard is currently 3,700 ug/L.  No
elevated levels of DEE above the current
HBDW standard have been detected outside
the initial plume. DEE has been detected
above the 43 ug/L limit given in the ROD up
to approximately 3,900 feet northwest of the
initial plume boundary.
Matrix Characteristics Affecting Treatment Costs or Performance [1. 3. 5. 7]

Hydrogeology:

Two distinct hydrogeologic units have been identified beneath this site.  The upper water table aquifer is a
sand and gravel aquifer which extends from the water table, at approximately 20 feet below ground
surface, to approximately 110 feet below ground surface. A discontinuous sandy clay layer divides the
upper aquifer from the lower aquifer. Limited data are available on the lower aquifer, but it is known to be
an artesian non-flowing aquifer confined by the sandy clay layer in the area of the site. The groundwater
flow patterns observed in the confined aquifer are similar to those patterns of the upper aquifer.
Replacement residential wells were installed in this aquifer. No contamination has been detected in the
lower aquifer in the site vicinity.
      EPA
        U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
                Technology Innovation Office
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                                                               U.S. Aviex Superfund Site
                      MATRIX DESCRIPTION (CONT.)
EPA
 Figure 1. Distribution of Contamination (1988) [7]
                                    U.S. Environmental Protection Agency
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	Technology Innovation Office
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                      MATRIX DESCRIPTION (CONT.)
                                                               U.S. Aviex Superfund Site


              Figure 2. Distribution of Contamination (December 1996) [9]
EPA
       U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
              Technology Innovation Office
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                                                                      U.S. Aviex Superfund Site
                             MATRIX DESCRIPTION (CONT.)
Matrix Characteristics Affecting Treatment Costs or Performance (Cont.)

Groundwater in the site vicinity flows southwest, which concurs with the plume distribution southwest of
the source. Prior to startup of remediation in 1993, the contaminant plume migrated further southwest
than the previous sampling events indicated. Further characterization has been completed by Tetra Tech
EM Inc. for the EPA and MDEQ to determine the extent of the plume, and is reported in their Additional
Groundwater Assessment Summary Report.

The additional assessment determined that groundwater in the site vicinity of U.S. Aviex flows southwest,
but regionally returns to northwest flow. Further discussion of the assessment is given in the Performance
Data Assessment section.

Table 1 includes technical aquifer information.

                             Table 1. Technical Aquifer Information
Unit Name
Thickness
(ft)
Conductivity
(ft/day)
Average Velocity
(ft/day)
Upper Aquifer 70-100 9.1-45.4 0.5
Lower Aquifer Not Characterized Not Characterized Not Characterized
* Groundwater flows southwest in the site vicinity, but flows northwest regionally.
Flow Direction
Southwest*
Not Characterized
Source: [1]
                          TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology
Pump and treat with air stripping

System Description and Operation \2, 3. 5. 8.101
Supplemental Treatment Technology

None
                                 Table 2. Extraction Well Data
Well
Name
EW-1
EW-2
EW-3
EW-4
EW-5
Unit Name
Upper Aquifer
Upper Aquifer
Upper Aquifer
Upper Aquifer
Upper Aquifer
Depth (ft)
100
100
100
100
100
Design
Yield (gal/min)
100
50
50
50
50
         Source: [1]

System Description
•   In 1982, U.S. Aviex entered into an
    agreement with the MDEQ to construct a
    P&T system in an effort to prevent further
    migration of the groundwater contaminant
    plume detected both on and off site. The
    P&T system consisted of two extraction
    wells, an air stripper, and a force main.
   The extraction wells were placed on site in
   the area of the 1978 release to hydraulically
   contain the source.  Groundwater was
   extracted, passed through the air stripper,
   and pumped to the force main outfall.

   This P&T system was an interim remedy that
   operated from 1982 until its shutdown in
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                                                                   U.S. Aviex Superfund Site
                  TREATMENT SYSTEM DESCRIPTION (CONT.)
1988. No monitoring data were available
from MDEQ or EPA records for operation
from 1982 until 1988.  Therefore, this report
does not address the cost or performance of
this interim  remedy.

After the RI/FS was conducted in 1985 to
characterize contamination in the area and
the ROD was signed in 1988, the existing
P&T system was modified to meet
requirements specified by the EPA in the
ROD.

The two extraction wells constructed as part
of the 1982 P&T system were replaced in
1993 by a network of five extraction wells at
a depth of 100 feet. Table 2 presents a
summary of extraction well data and the
specific design extraction rates. The total
system design extraction rate is 300 gallons
per minute (gpm).  Assuming the system is
operational 95% of the time and total
extraction is 329 million gallons, the actual
average volume of water treated is
estimated to be approximately 190 gpm.

The air stripper from the 1982 P&T system
was retrofitted to meet the new remedial
design requirements.  The operating air
stripper is 56 feet tall and 4 feet in diameter.
Influent wastewater is distributed over a  bed
of plastic media, 46 feet high, packed in the
air stripper. Air introduced at the bottom of
the tower passes countercurrent to the
groundwater, stripping the contaminants
from the groundwater. The effluent vapor
from the air stripper is discharged directly to
the atmosphere. Treated water from the air
stripper is ultimately discharged to the St.
Joseph River via an effluent force main to
the Bame-Huntley drain  in accordance with
National Pollutant Discharge Elimination
System (NPDES) permit requirements.

Groundwater quality is monitored through
the five extraction wells and surrounding
network of 18 monitoring wells.
Groundwater flow is monitored through a
network of 10 piezometers.
System Operation
•   Quantity of groundwater pumped from
    aquifer in gallons (gal):

     Year    Average Volume Pumped (Gal)

     1993             58,850,000
     1994             104,650,000

     1995             79,720,000
     1996             86,120,000
     1997             67,290,000


•   The site is operational 95% of the time.  The
    treatment system is shut down four times
    per year or as needed for cleaning of the
    wells and system maintenance.

•   The present extraction system was designed
    to contain the contaminant plume defined in
    the 1988 RI/FS and to allow for optimization
    of groundwater extraction rates from wells in
    source zone areas and off-property.

•   EW-1 is located at the downgradient edge of
    the plume.  Modflow and Randomwalk
    computer models determined that an
    extraction rate of 100 gpm from EW-1 would
    contain the plume.  The other extraction
    wells, also analyzed by computer model,
    were designed to remove groundwater from
    areas closer to the source areas.

•   The average groundwater extraction rates
    from 1993 until 1996 for each extraction well
    are listed below:

      Well        Average Pumping Rate
                       (gal/min)

     EW-1                133

     EW-2                24

     EW-3                12

     EW-4                16

     EW-5                47


•   Pumping from EW-1 was increased from 123
    gpm in 1994 to 159 gpm in 1996, in an effort
    to contain the contaminant plume. At
    system operation startup in 1993,
    contaminant concentrations were detected
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                                                                         U.S. Aviex Superfund Site
                      TREATMENT SYSTEM [DESCRIPTION (CONT.)
System Description and Operation (Cont.)
    above clean-up levels in wells installed
    outside the remedial system capture zone to
    monitor collection system performance. To
    increase the system capture zone, pumping
    from EW-1 was increased.  This approach
    has not been completely successful and the
    extent of the plume was re-investigated.
    The investigation by the EPA and state
    concluded that historical contamination
    existed outside the original plume, as
    discussed in the Performance Data
    Assessment section of this report.

    Because low levels of contamination were
    detected in extraction wells EW-3 and
    EW-4, these wells  were shut down from
    1994 through December 1996.

    Pumping from EW-2 was adjusted according
    to fluctuations in contaminant
      concentrations from this well. When
      contaminant concentrations decreased in
      1995, pumping was decreased. When
      contaminant concentrations increased in
      1996, pumping increased.

      Well EW-5 is located at the source area of
      the plume. It has pumped at about 50
      gallons per minute from 1994 through
      December 1996.

      New plastic packing material was put in the
      air stripper in 1993 because of fouling.  The
      packing media has not been changed since
      that time.

      Based on  additional assessment,  several
      options were identified by the treatment
      vendor for possible expansion of the
      treatment  system [9].
Operating Parameters Affecting Treatment Cost or Performance
The groundwater extraction rate is a major operating parameter affecting cost or performance for this
technology. Table 3 presents the average extraction rate between system start up in July 1993 through
December 1996 and the required performance parameters.

                                 Table 3:  Operating Parameters
                       -^Parameter
                   Average Extraction Rate
                      Remedial Goal
                         (aquifer)
                   Performance Standard
                        (effluent)
                   NPDES Requirements
         Source: [1, 8]
             'Value
           190-280 gpm
           DEE 43 pg/L
         1,1,1-TCA 200 pg/L
          1,2-DCA5pg/L
          Benzene 5 pg/L
       Ethylbenzene 680 pg/L
         Toluene 2,000 pg/L
          Xylene 440 pg/L
         Chloroform 2 ug/L
          1,1-DCE7pg/L
           TCE 5 pg/L
          PCE 0.88 pg/L
       trans-1,2-DCE 700 ug/L
trichlorofluoromethene (TCFM) 32,000 pg/L
dichlorofluoromethane (DCFM) 3,000 ug/L
           DEE 275 ug/L
         1,1,1-TCA 120 ug/L
         1,2-DCA 560 ug/L
         Benzene 51 ug/L
        Ethylbenzene 62 ug/L
         Toluene 100 pg/L
          Xylene 40 pg/L
         Chloroform 43 pg/L
          1,1-DCE3pg/L
         • TCE 94 pg/L
           PCE 20 pg/L
       trans-1,2-DCE 90 pg/L
          TCFM 20 pg/L
          DCFM 20 ug/L
      EPA
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                                                                     U.S. Aviex Superfund Site
                    TREATMENT SYSTEM DESCRIPTION (CONT.)
Tim A! In A
A timeline for this remedial project is shown in Table 4.
Start Date
1982
1986
9/7/88
09/88
4/92
7/93
1993
1997
End Date
—
_
	
09/91
6/93
—
_

Activity
Interim P&T system installed
Interim P&T system shut down and RI/FS completed
Record of Decision signed
Remedial design
Remedial construction, including replacement of interim extraction wells
Remedial system begins operations; quarterly monitoring of groundwater begins
Contamination detected in downstream monitoring wells; pumping from EW-1 and
EW-5 increased
Extent of plume examined
Source: [2,3,5]
                        TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards f1]

•   The cleanup goals for the site are to
    remediate the groundwater to levels
    established by the MDEQ and the maximum
    contaminant levels (MCL) established by the
    Safe Drinking Water Act (SDWA); these
    levels are applied throughout the aquifer.
    The cleanup goals for DEE, 1,1,1-TCA, and
    1,2-DCA are listed in Table 3.
Treatment Performance Goals Ml
                                                Additional Information on Goals [11

                                                •   The MDEQ health-based cleanup
                                                    concentration for DEE is now 3,700 ug/L, not
                                                    43 ug/L as given in the ROD. EPA and
                                                    MDEQ are deciding on future action
                                                    regarding the cleanup standard for DEE.

                                                •   Emissions during operation of the air stripper
                                                    will not be monitored because influent
                                                    groundwater contaminant levels are not
                                                    significant and vapor emissions comply with
                                                    Clean Air Act and permitting requirements.
    The primary goal for the treatment system is
    to reduce index contaminant concentrations
    to levels which meet the NPDES
    requirements listed in Table 3.
                                                    The secondary goal for the treatment system
                                                    is to create an inward hydraulic gradient to
                                                    contain the contaminant plume.
Performance Data
                             fA S 6 8. 91
For this discussion and Figures 2 and 3, total
contaminant concentration includes
concentrations of benzene, 1,2-DCA, 1,1-DCE,
trans-1,2-DCE, DEE, DCFM, PCE, 1,1,1-TCA,
TCE, and TCFM. In addition, this discussion
addresses system performance only for the
current P&T system; the interim system (1982-
1986) is not included in this assessment.

•   Contaminant concentrations have declined
    but remain above cleanup goals. The
    maximum concentration of 1,1,1-TCA has
      EPA
                                                    dropped from 200,000 ug/L to 400 ug/L, a
                                                    99.8% reduction. The maximum
                                                    concentration of DEE dropped from 5,700
                                                    ug/L to 100 ug/L, a 98% reduction. The
                                                    maximum concentration of 1,2-DCA dropped
                                                    from 4,800 ug/L to 33 ug/L, a 99% reduction.

                                                    As illustrated in Figure 3, average total
                                                    contaminant concentrations have also
                                                    declined, indicating contaminant reduction
                                                    across the entire plume. The average
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                                                                        U.S. Aviex Superfund Site
                      TRE^TMENf SYSTEM jDESCRIPTION (CONT.)
 Performance Data Assessment fContl
    concentration of total contaminants has
    decreased from 158 to 67 ug/L over 3 Yz
    years of operation, a 58% reduction.  The
    average concentration of 1,1,1 -TCA has
    decreased from 107 to 40 yg/L over 3 !4
    years of operation, a 63% reduction.

 •   NPDES permit requirements have been met
    consistently over the 42 months of operation.

 •   In 1993, contaminants were detected at
    concentrations above cleanup goals in
    downgradient monitoring wells beyond the
    limits of the plume initially identified. The
    increased pumping rate in EW-1 was not
    sufficient to recapture the plume.

 •   The additional assessment, as discussed in
    the Matrix Description section, found
    contamination outside of the initial plume.
    However, the assessment determined the
    elevated DCA and DEE levels were not due
    to loss of plume containment.  Wells along
    the perimeter and just outside the extraction
    well capture zone were not found  to contain
    elevated levels of contaminants, which
    indicates that plume containment  had been

 Performance Data Completeness
 maintained. The discovery of contamination
 outside the originally estimated plume has
 been attributed to historically elevated levels
 not discovered during the RI/FS.

 To address the additional contamination, the
 number of extraction wells may be expanded
 or innovative remediation may be applied.

 Figure 4 presents the removal of total
 contaminants through the treatment system
 from September 1993 to December 1996.
 Over this period the P&T system removed
 approximately 664 pounds of total
 contaminant mass from the groundwater.

 During system startup in the first two months
 of operation, the contaminant mass removal
 was low, at 0.064  Ib/day. The removal rate
 increased to 0.65 Ib/day in November 1993,
 as shown  in Figure 3. However, as
 contaminant levels in the groundwater
 dropped from 1993 to 1995, the removal rate
 also dropped from 0.65  Ibs/day in November
 1993 to 0.22 Ib/day in December 1995.
•   Data are available for contaminant
    concentrations in the groundwater in the
    extraction wells during quarterly sampling
    events from May 1993 to December 1996.
    Data are available for contaminant
    concentrations in the influent to the
    treatment system from September 1993 to
    September 1996. Data regarding the
    additional contamination outside the plume is
    available in Reference 9.

•   Contaminant mass removal, depicted in
    Figure 4, was determined using analytical
    results of samples from the influent stream
    to the treatment plant from each well and the
    extraction well flow data, along with
    treatment effluent data, from September
    1993 to September 1996.

Performance Data Quality
The geometric mean of total contaminant
concentrations, depicted in Figure 3, was
determined using analytical results from
annual sampling of extraction wells and
monitoring wells.  The geometric mean
represents the trend of contaminant
concentrations across the entire plume.

All extraction wells within the original plume
were used for calculation of the mean
concentration. When concentrations below
detection limits were encountered, half of the
detection limit was used for evaluation
purposes.

No data were available for the interim P&T
system (1982-1986); therefore, the system
performance was not evaluated as part of
this report.
The QA/QC program used throughout the remedial action met the EPA and the MDEQ requirements.  All
monitoring was performed using EPA-approved methods: SW-846 Methods 601, 602, 624, 625,
Hardness, and TDS. The vendor did not note any exceptions to the QA/QC protocols.

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                                                            U.S. Aviex Superfund Site
               TREATMENT SYSTEM DESCRIPTION (CONT.)
  300
    Jan-93 Aug-93  Mar-94  Sep-94  Apr-95  Oct-95  May-96 Dec-96  Jun-97
                         . 1,1,1-TCA-B—Total Contaminants
  Figure 3. Average Contaminant Concentrations from May 1993 until December 1996 [8]
                                                                      700
1
I
u.
                         .Mass Flux (Ib/day)
 .Mass Removed (Ib) i
Figure 4. Mass Flux Rate and Cumulative Total Contaminant Removal from September 1993 to
                               December 1996 [8].
  EPA
       U.S. Environmental Protection Agency
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                                                                         U.S. Aviex Superfund Site
 Procurement Process
                                TREATMENT SYSTEM COST
 EPA contracted with Tetra Tech EM Inc. (formerly PRC Environmental Management, Inc.) for design and
 construction oversight. ATEC Associates, Inc. constructed and operated the remedial system.

 Cost Analysis                                                            	

 The costs incurred during initial remedial actions and during the beginning of the RI/FS through 1986 were
 paid for by U.S. Aviex.  MDEQ and EPA provided the remainder of the remedial costs.
Capital Costs F41
  Remedial Construction of 1993 P&T System

  Mobilization and Preparatory Work         $223,833

  Monitoring and Analysis                  $45,511

  Site Work                            $354,241

  Extraction Wells                       $130,731

  Vapor Phase Carbon Filter                 $8,550

  System Construction                   $559,954

  Decontamination of Equipment and Area       $8,855

  Total Remedial Construction           $1,331,675
                                                    Other Costs f4.51
 Operating Costs from July 1993 until December 1996
 Utilities

 Sampling and Analytical Services

 Other Operations and Maintenance

 Total Operating Expenses


Other Costs F4.5T	
 $29,110

$238,887

$342,327

$610,324
 Total Remedial Design

 EPA Oversight Costs

 1987 Air Stripper

 1987 Effluent Force Main Outfall
$586,775


$170,000

 $25,000

 $50,000
Cost Data Quality
Actual cost data are available from the site manager for this application.
                       OBSERVATIONS ANDILESSONS LEARNED
    The actual cost for groundwater treatment at
    U.S. Aviex from 1993-1996 was
    approximately $1,942,000 ($1,332,000 in
    capital and $610,000 in operations and
    maintenance), which corresponds to $2,925
    per pound of total contaminants removed
    and $5.00 per 1,000 gallons of groundwater
    treated.

    The impact of remediation on the plume size
    is inconclusive because of the new data
    regarding historically elevated contaminant
    levels.
   Contamination has been detected in wells
   downgradient of the plume identified in the
   RI/FS.  As a result, further characterization
   and expansion of the remedial system is
   necessary. The further action will increase
   the cost.

   No performance data are available on the
   interim  P&T system; however, operation of
   this system before the 1993 P&T system
   went on line may have impacted the total
   cost of the remediation.  The interim system
   began remediation and contained part of the
   source area prior to full-scale remediation.
      EPA
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                                                                     U.S. Aviex Superfund Site
                 OBSERVATIONS AND LESSONS LEARNED (CONT.)
Observations and Lessons Learned fConU
    Monitoring data from extraction wells
    indicate that while maximum contaminant
    concentrations in the groundwater have
    dropped significantly (up to 99% for 1,1,1-
    TCA), they remain above cleanup goals.
    After four years of P&T operation the rate of
    contaminant removal has slowed [4]. While
    no dense non-aqueous phase liquid
    (DNAPL) has been directly observed during
    sampling, high initial concentrations of 1,1,1-
    TCA (greater than 60% of its solubility)
    indicated the potential presence of DNAPL.
    DNAPLs act as a constant source of
    contamination and can replenish
    groundwater plumes as they slowly desorb
    and dissolve from saturated sediments into
    the aqueous phase.  If DNAPLs are present,
    locating and eliminating them would improve
    the effectiveness of this remedy [6].
   The treatment system achieved a maximum
   rate of total contaminant removal of 0.65
   Ib/day during the first year of operation. The
   total contaminant removal rate has
   continuously declined since the beginning of
   operations.  By December, 1995, the total
   contaminant removal rate had declined to
   0.29 Ib/day. The decline in contaminant
   removal rate is typical of P&T systems, in
   that they remove contaminants most
   efficiently at the beginning of operations,
   when contaminant levels are highest.
                                      REFERENCES
 1.  Record of Decision. U.S. Environmental
    Protection Agency, September?, 1988.

 2.  Correspondence with Mr. Carl Chavez, SMU
    #3 Project Manager, Michigan Department of
    Environmental Quality.  May 5, May 13, and
    May 22,1997.

 3.  Remedial Action Report Completion
    (RACR). PRC Environmental Management,
    Inc., January 26,1994.

 4.  Ground-Water Cost Analysis. U.S.
    Environmental Protection Agency,
    unpublished.

 5.  Correspondence with Mr. Ron Riesing and
    Mr. Rick Hersemann, PRC Environmental
    Management, Inc. (Now Tetra Tech EM
    Inc.).  April 21, May 9, May 15, and
    November 12 1997; March 24 and April 3,
    1998.

 Analysis Preparation
6.   Dense Nonaqueous Phase Liquids. Halin,
    Scott G. And J.W. Weaver, U.S.
    Environmental Protection Agency, March
    1991.

7.   Remedial Investigation/Feasibility Study. EDI
    Engineering and Science, 1988.

8.   Annual Summary Monitoring Reports. PRC
    Environmental Management, Inc., 1993-
    1997.

9.   Additional Groundwater Assessment
    Summary Report. U.S. Aviex Site, prepared
    by Tetra Tech EM Inc. for EPA Region 5
    February 27,  1998.

10. Comments on draft report provided by Ron
    Riesing, Tetra Tech EM, Inc. May 20,1998.
 This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
 Emergency Response, Technology Innovation Office in consultation with the MDEQ. Assistance was
 provided by Eastern Research Group, Inc. and Tetra Tech EM Inc. under EPA Contract No. 68-W4-0004.
       EPA
            U.S. Environmental Protection Agency
     Office of Solid Waste and Emergency Response
                    Technology Innovation Office
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Pump and Treat of Contaminated Groundwater at
     the Western Processing Superfund Site,
              Kent, Washington
                    237

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                  Pump and Treat of Contaminated Groundwater at
                         the Western Processing Superfund Site,
                                      Kent, Washington
Site Name:
Western Processing Superfund Site
Location:
Kent, Washington
Contaminants:
Chlorinated solvents; volatiles -
nonhalogenated (toluene); PAHs;
and metals
- Maximum initial concentrations
of chlorinated solvents and metals
were trans-1,2-DCE (390 mg/L),
TCE (250 mg/L), cadmium (2.5
mg/L), nickel (280 mg/L), and zinc
(510 mg/L)
Period of Operation:
Status: Ongoing
Report covers:  10/88 - 12/96
Cleanup Type:
Full-scale cleanup (interim results)
Vendor:
Contractors:
OHM Remediation Services, Corp.
(Formerly CWM)
Landau Associates, Inc.
PRP Contact:
PaulJohansen
Western Processing
20015 72nd Avenue South
Kent, Washington 98032
(425) 393-2565

State Point of Contact:
Christopher Maurer, P.E.
Washington Department of
Ecology
Technology:
Pump and Treat and Vertical
Barrier Wall
- Groundwater is extracted on-site
using 15 wells at an average total
pumping rate of 190 gpm; this
water is treated with air stripping
and reinjected through an
infiltration system
- Prior to 1996, groundwater was
extracted using 210 shallow,
vacuum-operated recovery well
points
- A slurry wall (vertical barrier
wall), 40 ft deep,  encloses the 13-
acre site
- Groundwater is  extracted off-site
using 3 wells at an average total
pumping rate of 40 gpm; this water
is treated with filtration and air
stripping prior to  reinjection or
discharge to a POTW
Cleanup Authority:
CERCLA Remedial
-RODDate: 9/85
EPA Point of Contact:
Lee Marshall, RPM
U.S. EPA Region 10
1200 Sixth Avenue(ECL-l 16)
Seattle, WA 98010
(206) 553-2723
 Waste Source:
 Unauthorized dumping, spills, and
 leaks from surface impoundments
 Purpose/Significance of
 Application:
 Met goals for off-site plume within
 eight years of operation; shallow
 well points replaced recently with
 deeper wells to provide for
 containment; relatively large and
 expensive system.	
Type/Quantity of Media Treated:
Groundwater
- 974 million gallons treated as of December 1996
- LNAPL observed and DNAPL suspected in groundwater at this site
- Groundwater is found at 5-10 ft bgs
- Extraction wells are located in 2 aquifers; the aquifers are influenced by
a nearby surface water
- Hydraulic conductivity ranges from 1 to 100 ft/day
                                               238

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                   Pump and Treat of Contaminated Groundwater at
                          the Western Processing Superfund Site,
                                Kent, Washington (continued)
Regulatory Requirements/Cleanup Goals:
- Groundwater cleanup goals were established in terms of surface water quality goals for Mill Creek (adjacent to
  the site), based on federal ambient water quality criteria. These goals were required to be met within three
  years.  Surface water goals were established for cadmium (1.1 ug/L), chromium (207 ug/L), copper (11.8
  ug/L), lead (3.2 ug/L), mercury (0.012 ug/L), nickel (158 ug/L), silver (0.12 ug/L), zinc (120 ug/L),  cyanide
  (5.2 ug/L), and hardness (100 ug/L).
- Remedial goals for the off-site aquifer were established for cis-l,2-DCE (70 ug/L) and trans-1,2-DCE (70
  ug/L).
- An BSD, issued in 1995, changed the focus of the remediation from site restoration to containment.
Results:
- Monthly monitoring data indicated that the surface water quality in Mill Creek met the established criteria by
  mid-1990. Further, concentrations for TCE, vinyl chloride, and zinc decreased in on-site wells by two orders
  of magnitude from 1988 to 1995.  However, elevated concentrations of contaminants remain in on-site wells.
  As of June 1995, concentrations were reported as high as TCE (55,200 ug/L), DCE (14,600 ug/L), vinyl
  chloride (5,490 ug/L), cadmium (1,360 ug/L), and zinc (117,000 ug/L).
- The system achieved the cleanup goal for DCE in all three of the extraction wells located in the off-site plume.
  Concentrations of DCE have decreased in the off-site plume from above 2,000 ug/L  in 1988 to less than 70
  ug/L in January 1996. In addition, containment for the off-site plume has been achieved.
- A total of 102,000 pounds of contaminants have been removed from the groundwater during eight years of
  operation.
Cost:
- Actual costs for pump and treat were $48,730,000 ($16,032,629 in capital, including the slurry wall, and
  $32,697,483 in O&M), which correspond to $50 per 1,000 gallons of groundwater extracted and $478 per
  pound of contaminant removed.
Description:
This site operated as a waste processing facility from 1961 to 1983. Over 400 businesses transported industrial
wastes to the site to be stored, reclaimed, or buried. Processes used at the site included recovery of metals from
sludges and liquid wastes, spent solvent recovery, reprocessing of pickle liquor, and waste oil reclamation. In
March 1981, during a RCRA audit, EPA first discovered violations of regulations governing waste storage, drum
management, surface impoundments, and waste piles. Remedial investigations were conducted between 1983
and 1985. An initial ROD was issued in September 1985, and an amended ROD in September 1986.

Groundwater is extracted on-site using 15 well; this water is treated with air stripping and reinjected through an
infiltration system.  Prior to 1996, groundwater was extracted using 210 shallow, vacuum-operated recovery well
points.  Groundwater is extracted off-site using 3 wells; this water is treated with filtration and air stripping prior
to reinjection or discharge to a POTW. The original approach to this site was an aggressive effort to fully restore
the site to original conditions within seven years. Restoration was a priority and high costs were incurred to
achieve this goal, including high operating costs.  After eight years of pump and treat, the goal of restoration was
changed to containment based on the technical impracticability of achieving full restoration.
                                                239

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                                                              Western Processing Superfund Site
                                    SITE INFORMATION
Identifvina Information!.
Western Processing Superfund Site
Kent, Washington

CERCLISf: WAD009487514

ROD Date: September 1985
Amended September 1986
Explanation of Significant Differences (ESD)
December 1995
                                                 Treatment Application:
Type of Action:  Remedial

Period of operation: 10/88-Ongoing
(Performance data collected through December
1996)

Quantity of groundwater treated during
application:  974 million gallons
Historical Activity that Generated
Contamination at the Site: Waste processing

Corresponding SIC Code: 4953W
(Miscellaneous waste processing)

Waste Management Practice That
Contributed to Contamination: Unauthorized
dumping, spills, and leaks from surface
impoundments

Location:  Kent, Washington

Facility Operations: [3, 7]
•   The 13-acre site operated as a waste
    processing facility from 1961 to 1983.  Over
    400 businesses transported industrial
    wastes to the site to be stored, reclaimed, or
    buried.  Processes at the site included the
    recovery of metals from sludges and liquid
    wastes; spent solvent recovery; reclamation
    of caustics, flue ash, and ferrous sulfide;
    reprocessing pickle liquor; electrolytic
    destruction of cyanides; chemical
    recombination to produce zinc chloride and
    lead chromate; and waste oil reclamation.
    Operations ceased in  1983 by order of the
    EPA.

•   In March 1981, during a RCRA audit, EPA
    first discovered violations of regulations
    governing waste storage, drum
    management, surface impoundments, and
    waste piles.

    In 1983, EPA performed an emergency
    waste removal operation to stabilize the
    site. Over 460,000 gallons and 127 drums
    of waste liquids were  removed.

 •   Remedial investigations were conducted
    between 1983 and 1985.
    Site cleanup activities were divided into two
    phases.  Phase I involved removing tanks,
    buildings, impoundments, and waste piles
    from the site. Phase II involved subsurface
    cleanup.

    The initial ROD was issued in September
    1985.  It was amended in 1986 to reflect the
    requirements to be included in the Consent
    Decree.

    In April 1987, a Consent Decree was
    entered to begin Phase II cleanup activities.
    In the summer of 1987, construction
    activities began, which included installing
    two extraction and treatment systems and a
    slurry wall, enclosing the site. Extraction
    and treatment began in October 1988.

    After eight years of remediation that
    focused on groundwater and soil restoration,
    the objective was changed to contain the
    contamination on site and prevent further
    off-site migration. An ESD was issued in
    December 1995 to reflect a Technical
    Impracticability (Tl) Waiver.

    A new extraction system was installed in
    1996 to  provide more automated operation
    during the period of containment. A new
    treatment system was constructed for all
    groundwater extracted during containment
    operations and became operational in June
    1997.
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                                                            Western Processing Superfund Site
                              SITE INFORMATION (CONT.)
Background fCont.}
Regulatory Context:
•   Site activities are conducted under
    provisions of the Comprehensive
    Environmental Response, Compensation,
    and Liability Act (CERCLA) of 1980, and the
    National Contingency Plan (NCP), 40 CFR
    300.

•   The ROD for the site was signed in
    September 1985 and amended in
    September 1986. A Consent Decree was
    issued in 1987.  An ESD was issued in
    December 1995.

Site Logistics/Contacts	
Groundwater Remedy Selection:
•   Originally, the selected remedy was
    extraction and treatment of groundwater in
    conjunction with a passive containment
    system (slurry wall) and an aggressive effort
    to restore groundwater quality to acceptable
    levels within five to seven years. In the
    ESD, the remedy was changed to
    containment of the on-site and off-site
    plumes.
Site Lead:  PRP

Oversight:  EPA/State of Washington
(Joint Oversight)

Remedial Project Manager:
Lee Marshall
U.S. EPA Region 10
1200 Sixth Avenue (ECL-116)
Seattle, WA 98010
(206) 553-2723
State Contact:
Christopher Maurer, P.E.
Washington Department of Ecology

Contractors:
OHM Remediation Services, Corp. (Formerly
CWM)
Landau Associates, Inc.

PRP - Lead:
Paul Johansen*
Western Processing
20015 72nd Avenue South
Kent, Washington 98032
(425) 393-2565
indicates primary contact
Matrix Identification
                                 MATRIX DESCRIPTION
Type of Matrix Processed Through the
Treatment System: Groundwater
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                                                              Western Processing Superfund Site
                             MATRIX DESCRIPTION (CONT.)
Contaminant Characterization n. 2.13.171
Primary Contaminant Groups:  Halogenated
volatile organic compounds (VOCs), polycyclic
aromatic hydrocarbons (PAHs), phenolic
compounds, and metals

•   The primary organic contaminants of
    concern are trichloroethene (TCE), cis- and
    frans-1,2-dichloroethene (DCE), methylene
    chloride, toluene, and vinyl chloride.

•   The metal contaminants of concern are
    cadmium, zinc, chromium, nickel, copper,
    and lead.

•   Figures 1 and 2 show plume maps from
    1988,1991, and 1995 for TCE and vinyl
    chloride.

•   Investigations conducted during the
    remedial  investigation identified more than
    90 of EPA's priority pollutants at the site,
    mostly volatile and semivolatile organic
    compounds and metals.

•   The maximum  initial concentrations of
    contaminants detected were 390 mg/L
    (frans-1,2-DCE), 250 mg/L (TCE), 510 mg/L
    (zinc), 280 mg/L (nickel), and 2.5 mg/L
    (cadmium).

•   In 1989, an EPA toxicologist suggested that
    the organic compound oxazolidinone
    present in the site groundwater might be
    genotoxic.  As a result, an activated carbon
    system was added to remove this
    compound from the treated groundwater.
    The compound was later found to be non-
    hazardous and the carbon treatment system
    was removed [13].
An immiscible liquid has been visually
observed floating in samples taken from
several on-site wells, confirming the
presence of light nonaqueous phase liquid
(LNAPL). The levels of DCE found in
groundwater samples were also greater than
6% of solubility. Although this concentration
indicates the likely presence of a dense
nonaqueous phase liquid (DNAPL), DNAPLs
were never found.

The volume of the plume was estimated for
this report to be approximately 500 million
gallons, based on monitoring data collected
in 1987 [17].

The majority of contaminants are found on
site within the upper unconfined aquifer.
The on-site plume contains many
contaminants and primarily impacts Mill
Creek to the west of the site.

A separate, deeper plume containing
primarily c/s-1,2-DCE is also present off
site. This plume originates on site in the
southern portion of the site.
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                                                        Western Processing Superfund Site
                       MATRIX DESCRIPTION (CONT.)
       Figure 1.  Trichloroethene (TCE) Contour Maps (Concentrations in ug/L) [10]
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                                                      Western Processing Superfund Site
                      MATRIX DESCRIPTION (CONT.)
          Figure 2.  Vinyl Chloride Contour Maps (Concentrations in ug/L) [10]
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                                                               Western Processing Superfund Site
                              MATRIX DESCRIPTION (CONT.)
Matrix Characteristics Affecting Treatment Costs or Performance
Hydrogeology [1]:

Three major geologic units comprise the hydrogeologic system in the vicinity of the site.  These units
comprise the White River Alluvium, the valley fill deposits that occur throughout the Kent Valley and
beneath the Western Processing site. The alluvial fill consists primarily of sand, silt, and clay with
occasional layers of sandy gravel.  The  White River Alluvium is not considered to be a major drinking
water source due to naturally occurring poor water quality. Groundwater is encountered at 5 to 10 feet
below ground surface.  Shallow groundwater (Unit 1) flows northwest from the site and discharges into
Mill Creek. The deeper aquifer (Unit 2)  begins approximately 40 feet below ground surface.
Groundwater in this unit flows northwest also, but passes below Mill Creek. Contaminants in Unit 2 were
transported downgradient of the site and Mill Creek; contaminants in Unit 1 migrated to Mill Creek prior
to the installation of a slurry wall around the site.
 Unitl (Shallow Aquifer)
 Unit 2 (Deep Aquifer)
A complex sequence of discontinuous interbedded silt, sand, and clay
lenses to a depth of 40 feet below ground surface.

A fairly continuous fine to medium sand with intermittent silty zones
existing below 40 feet. This sand unit extends to a depth of 150 feet
below ground surface.
Tables 1 and 2 present technical aquifer information and technical well data, respectively.

                             Table 1.  Technical Aquifer Information
Unit Name
1
2
Thickness
(ft)
35-40
75-100
Conductivity
(ft/day)
1 -10
10-100
Velocity
(ft/day)
.27
0 02 - 0 2
Flow Direction
Northwest
Northwest
bource: [1]
                           TREATMENT SYSTEM DESCRIPTION
Primary Treatment Technology

Pump and treat (P&T) with air stripping and
metals precipitation
In situ soil flushing (1988 -1996)
                       Supplemental Treatment Technology

                       Passive containment system (slurry wall)
                       Carbon polishing (1990-1991)
                       Peroxide oxidation (1988 -1989)
                       Chromium reduction (1988 -1989)
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                                                               Western Processing Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
        Description and Operation
                                 Table 2.  Extraction Well Data
Well Name
Wellpointsl -210
U-wells 1 - 6
T2-T4
'Cumulative extraction yield
Unit Name
Unitt
Unitl
Unit 2
Depth (ft)
30
40
70
Design Yield
(gal/min)
100-2001
15 each
15 each
Source: [2]

System Description [2, 4,14]
•   Remedial systems at the site originally
    included an on-site extraction and treatment
    system, an off-site extraction and treatment
    system, and a slurry wall that enclosed the
    13-acre site.

•   The on-site extraction system, which
    operated from 1988 until 1997, consisted of
    210 vacuum-operated recovery well points.
    These were divided into seven well-point
    groups, all of which were connected to three
    30-horsepower centrifugal-vacuum  pumps.
    Each of the well point installations was sand
    packed continuously from 5 to 30 feet below
    ground surface. Well points were installed
    over the entire site, with a greater density of
    well points in the areas known to have
    higher concentrations of contaminants.

•   The objective of the on-site extraction
    system was to create and sustain a net
    inward flow of groundwater at the site
    perimeter and a net upward flow of
    groundwater within the area surrounded by
    the slurry wall. An infiltration system (soil
    flushing) was placed in the shallow on-site
    soils within the slurry wall to flush
    contaminants out. The soil-flushing system
    was designed to expedite leaching  of
    contaminants from the shallow soils.

 •   The well-point system was designed to offer
    flexibility and 'Variable" pumped volume.
    Header pipes and valves at the top of  each
    well could be used to select  specific flow
    rates from each section of the system.
The extraction system was modified in late
1996 and early 1997. Use of the shallow
vacuum-operated well points (on site) was
discontinued and a set of 15 deeper
recovery wells were installed in 1996 to
replace the vacuum-operated well point
system.

The original treatment system for
groundwater extracted included stripping of
VOCs, followed by oxidation of phenolic
compounds with hydrogen peroxide,
reduction of hexavalent chromium to the
trivalent form, pH adjustment,  metals
precipitation,  and carbon polishing. The
carbon polishing step was removed in  1991.
Treated water was reinjected into the
ground through the infiltration system or
discharged to the POTW.

Because of severe fouling of the on-site
stripping tower by inorganic precipitates, the
treatment sequence was modified in
September 1989 to provide metals
precipitation before stripping of VOCs [10.]

After 1989, the treatment system was
modified to provide metals removal before
air stripping,  and phenol oxidation and
hexavalent chromium reduction were
discontinued. The treatment system was
 replaced in 1997 with a new automated
 system for VOCs only.

 Liquid-phase carbon filters were used  to
 remove oxazolidinone from treated water
 before discharge to the POTW.  EPA
 eventually determined that this compound
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                                                               Western Processing Superfund Site
                      TREATMENT SYSTEM DESCRIPTION (CONT.)
System Description and Operation fCont.)
    had no detrimental health effects and the
    carbon polishing was discontinued.

•   The slurry wall, which is 40 feet deep and
    laterally confines the on-site contaminants
    to the site boundaries, enhances the
    recovery process.  The soil/bentonite wall
    was installed using a backhoe and bucket
    excavator.

•   The off-site extraction system consisted of
    three deep wells (trans wells) screened
    between 40 and 70 feet below ground
    surface.  The purpose of the trans wells was
    to extract groundwater from an off-site
    plume of c/s-1,2-DCE. The Consent Decree
    required overlapping zones of influence for
    these extraction wells.  Each well was fitted
    with a submersible electric pump and
    designed to produce up to 15 gpm which
    was determined to provide sufficient
    overlapping zones.

•   Water extracted from the off-site trans wells
    was directed to a separate treatment system
    consisting of a sand filter bed and an air
    stripper.  Effluent from this system was
    reinjected to the infiltration gallery or
    discharged to the POTW.

•   Contaminant concentrations in groundwater
    and water levels are monitored using a
    system of 51 monitoring wells and 28
    piezometers located on and off the site in
    both Units 1 and 2.

System Operation [2, 4, 6, 7,10,13,14]
•   Construction and installation of the on-site
    and off-site extraction and treatment
    systems was completed in 1988. The slurry
    wall installation was completed in 1989 [2].

•   Six new extraction wells (U-wells) were
    installed in the spring of 1993. Four of
    these were placed within the slurry wall and
    two were placed off site adjacent to  the
    slurry wall, where high concentrations of
    organic contaminants were detected. These
    wells were equipped with dedicated  down-
    well pumps and were connected directly to
    the existing treatment system. Well depths
    were approximately 40 feet [7].
•   The average extraction rate for the site has
    been approximately 230 gpm based on
    annual averages from 1988 to 1997.  The
    annual rate was reduced to 140 gpm  in
    1996 and 40 gpm in 1997 [10].  The
    extraction rate was reduced in conjunction
    with the change to a containment focus from
    a restoration focus, and because the
    infiltration of about 100 gpm of treated water
    was discontinued at the end of 1996.

Groundwater Pumped From Aquifer in gallons
per minute (gpm):
 Year

 1989

 1990

 1991

 1992

 1993

 1994

 1995

 1996

 1997
  Average GPM Pumped

On-Site System    Off-Site System
     225

     225

     225

     225

     225

     225

     200

     100

     40
40

40

40

40

40

40

40

40

40
   The original on-site treatment system
   included a phenol oxidation and a chromium
   reduction process, which were discontinued
   by December 1988 because it was found
   that the concentrations of phenol and
   chromium in the influent were  below effluent
   permit limits [14].

   Effluent from both treatment systems
   continue to be combined and discharged to
   the local POTW under a Waste Discharge
   Permit. The limitations in the permit have
   not been exceeded since operations began
   [10].

   The Western Processing facility also has a
   permit from the Puget Sound Air Pollution
   Control Agency for the emissions from the
   air stripper [6].

   The site is operational seven days per week,
   24 hours per day.  From 1988  until 1996,
   the system has operated 97%  of the time for
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                                                                  Western Processing Superfund Site
                       TREATMENT SYSTEM DESCRIPTION (CONT.)
Su«?tem Dfiseriniion and Ooeration fCont.)
    a total of approximately 70,000 hours [13].
    The new extraction and treatment systems
    that became operational in 1997 have
    experienced similar operational efficiency.

    Air stripping media for the off-site treatment
    system was changed once in the first year of
    operation because of fouling caused by scale
    buildup.  Acid washing of the stripping tower
    was conducted once every three weeks to
    minimize scale buildup. This procedure
    required four hours of down time [13].
The carbon system used to remove
oxazolidinone from the treated groundwater
required carbon changeouts approximately
once per month in 1990 and early 1991. The
air phase carbon system associated with the
air stripping process required carbon
changeouts approximately once per month at
first, but has averaged about once every eight
months due to declining contaminant
concentrations and the use of more efficient
activated carbon.
nnoratlnn Paramr>tpr<; Affectina Treatment Cost or Performance
Table 3 presents operating parameters affecting cost and performance at this site.

                                 Table 3.  Performance Parameters
	 ''" 	 ' ' ''Parameter 	 '•'•• 	 	 --. 	
Average Extraction Rate (for both on- and off-site systems)
Air Discharge Requirements
Treated Groundwater Discharge Permit Requirements (daily
averages)
Remedial Goal (Surface Water Requirements)2
Remedial Goal (Off-site Aquifer)
Note: Average system yield over eight years of operation was 2
Source: [3, 10]
•" .-. :•:. :;;:^::^Jiilt: .11: i
230 gpm
Hydrochloric gas 100mg/l
Methylene Chloride 1 00 mg/l
Arsenic 1.0 mg/l
Cadmium 0.5 mg/l
Chromium 2.75 mg/l
Copper 3.0 mg/l
Lead 2.0 mg/l
Mercury 0.1 mg/l
Nickel 2.5 mg/l
Silver 1 .0 mg/l
Zinc 5.0 mg/l
Cyanide 2.0 mg/l
Organics1 Monitoring only
Cadmium 1.1 ug/L
Chromium 207 ug/L
Copper 11. 8 ug/L
Nickel 158 ug/L
Lead 3.2 ug/L
Zinc 120 ug/L
Mercury .01 2 ug/L
Silver .12pg/L
Cyanide 5.2 ug/L
For Hardness 1 00 ug/L
frans-1,2-DCE -70|jg/L
C/S-1.2-DCE 70 ug/L
30 gpm for both systems based on annual data.

'Organics include: Acrdein, Acrylonltrile, Benzene, Carbon Teirachloride, Chlorinated Benzene, Chloroform, Dichlorobenzene,
1,2-DIchIoroethane, Dichioroethylenes, Dichloropropane, Dichloropropene, Ethylbenzene, 1,1,2,2-Tetrachloroethane, Toluene,
1,1,2-Trlcnloroethane, Trtchloroethene
*Attha time of the Consent Decree, the organic compounds detected in Mill Creek did not have associated Ambient Water Quality Criteria
values.
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                                                            Western Processing Superfund Site
                    TREATMENT SYSTEM PERFORMANCE (CONT.)
Timeline
Table 4 presents a timeline for major events performed during this remedial project.

                                  Table 4.  Project Timeline
,,,.:*• ,,»*-. s
Start Date
9/85
9/86
4/87
4/87
10/88
5/88
3/90
12/92
10/86
9/95
6/96
12/95
1/97
6/97
EitdDite
'
___
	
	

10/89
	
5/93
8/93
	
—
	
—
—
V V* ^>"^.L«^> /iLUlr.4, Activity '„ VT 1*rt ^ "> <**•'," * "*
Record of Decision issued
Amended Record of Decision issued
Consent Decree issued
Subsurface remediation begun
Operations for both P&T systems begun
Slurry wall constructed around the site
Three-year performance standards achieved for Mill Creek (surface water goals)
Five deep wells added to the collection system
Mill Creek restoration goals achieved
Tl Waiver Petition submitted
Containment wells installed
ESD issued in response to Tl Waiver (restoration goal changed to containment goal)
Containment pumping phased into operation
New treatment system started
Source: [3, 7,10]
                         TREATMENT SYSTEM PERFORMANCE
Cleanup Goals/Standards f11.14]

As determined by the Consent Decree and the
amended ROD, the following cleanup goals
were established:

•   Surface water quality goals for Mill Creek
    (adjacent to site) are Federal Ambient
    Water Quality Criteria (AWQC).  The
    Consent Decree required that these goals
    be met within three years. Attachment A
    includes the Consent Decree text which
    pertains to surface water goals.

•   Off-site groundwater goals were established
    by the Consent Decree for cis- and trans-
    1,2-DCE.
Additional Information on Goals [11]

•  Shallow groundwater from the site
   discharges to Mill Creek. The surface water
   requirements were a means of measuring
   cleanup within shallow groundwater beneath
   the site. There were no other on-site
   cleanup goals set for the shallow
   groundwater.

•  The ESD, issued in 1995, did not change
   the surface water or off-site groundwater
   cleanup or treatment performance goals
   from the amended ROD. The focus of
   remediation was changed from site
   restoration to containment.
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                                                              Western Processing Superfund Site
                     TREATMENT SYSTEM PERFORMANCE (CONT.)
Treatment Performance Goals F111
As determined by the Consent Decree and the
amended ROD, the following treatment
performance goals have been established:

•   Achievement of an inward flow of shallow
    groundwater (<40 ft bgs) within a specified
    area of the site.  This area is approximately
    defined by the property boundaries (see
    Figure 1 of this  report).

•   Achievement of either: 1) a reversal of
    groundwater flow for Unit 2 at a depth of 40
    to 70 feet at the western boundary of the
    site; or 2) establishment of a hydraulic
barrier to regional groundwater flow at the
40- to 70-foot depth at the western boundary
of the site.

Combined wastewater effluent from the
treatment systems must meet discharge
criteria included in the POTW discharge
permit. Specific criteria are included in
Table 3.

All air emissions must comply with a
discharge permit issued from the Puget
Sound Air Pollution Control Agency.
Specific criteria are included in Table 3.
Performance Data Assessment MO. 14.151
For this report, total metals includes zinc, nickel,
chromium, copper, and cadmium.  Total VOCs
includes TCE, DCE, vinyl chloride, methylene
chloride, and chloroform.

•  According to monthly surface water
   monitoring data, surface water criteria in Mill
   Creek were achieved by mid-1990. Figure
   3 shows concentrations of zinc in the
   downstream monitoring point of Mill Creek.
   Zinc concentrations were the highest of any
   metal contaminant.  By mid-1990,
   concentrations were below 100 ug/L.

•  The P&T system achieved the cleanup goal
   of 70 ug/L of DCE in all three of the
   extraction wells in the off-site trans plume.

•  Concentrations of DCE in the off-site plume
   have decreased since operations began in
   1988. As shown in Figure 4, concentrations
   of DCE have decreased in all three trans
   wells from above 2,000 ug/L in 1988 to  less
   than 100 ug/L in January 1996, a 95%
   reduction.

•  Contaminants have not increased in
   downgradient monitoring wells as noted in
   the 1996 Quarterly Report. On the basis of
   this information, plume containment for the
   off-site plume has been achieved [17].
Monitoring well data from on-site wells (N-
wells, U-wells, and monitoring wells) show
contaminant concentrations for TCE, vinyl
chloride, and zinc decreased by two orders
of magnitude from 1988 to 1995.

The maximum concentrations of
contaminants detected in on-site well points
(extraction wells) during the June 1995
sampling event were zinc (117,000 |jg/L),
cadmium (1,360 ug/L), DCE (14,600 ug/L),
vinyl chloride (5,490 \Jtg/L), and TCE
(55,200 ug/L).

Figure 5 shows the contaminant removal
rate in pounds per day for the P&T systems
from 1988 through 1996. This figure
includes combined removal rates for total
metals and total VOCs from both treatment
systems. The extraction rate decreased to
less than 20 Ibs/day within 3 years. It has
remained below 20  Ibs/day since then.
A total of 102,000 Ibs of contaminants was
removed during eight years of operation.
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                                                            Western Processing Superfund Site
                  TREATMENT SYSTEM PERFORMANCE (CONT.)
   1,000
     100
o
§
       1
      Mar-86    Aug-87   Dec-88   May-90   Sep-91    Jan-93   Jun-94   Oct-95    Mar-97
                                         -Mill Creek Data
   Figure 3. Zinc Concentration at Downstream Monitoring Point of Mill Creek (1988-1996) [10]
    10,000 -r
I
o
I
0)
  o
  o
      1,000
       100
         Dec-88
May-90      Sep-91      Jan-93
                                                        Jun-94
                                                                     Oct-95
                  4. Total DCE Concentrations in 3 Trans Wells (1988-1996) [10,15]
Mar-97
— •— T2
-B-T3 ->
k— T4 ^
<— Goal
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                                                             Western Processing Superfund Site
                     TREATMENT SYSTEM PERFORMANCE (CONT.)
                   May-90    Sep-91    Jan-93
      Jun-94
Oct-95
Mar-97
                               -Mass Flux
-Mass Removed
           Figure 5.  Mass Flux and Cumulative Contaminant Removal (1988-1996) [10,15]
Performance Data Assessment (ConU
    •   Data from annual reports indicate that
       inward flow gradients have been
       achieved in all but two deep (45 ft)
       piezometer pairs, which are both
       located in the northwest portion of the
       site.  These two piezometer pairs, each
       composed of one piezometer located
       inside and one outside of the slurry wall,
       have historically displayed neutral or
       outward gradients [10].

Performance Data Completeness
       Discharge requirements established by the
       wastewater discharge and air emission
       permits have been met consistently by
       treatments systems on site [10].
   Data are available in annual reports for
   concentrations of contaminants in the
   groundwater and surface water according to
   the following schedule [10]:
       Monitoring wells           Quarterly
       N-Wells                  Bimonthly
       Trans Wells              Monthly
       U-Wells                  Bimonthly
       Well Points               Annually
       Stream Sampling Points    Quarterly
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                                                                Western Processing Superfund Site
                     TREATMENTiSYSTEM PERFORMANCE (CONT.)
Performance Data Completeness fCont.)
    Data are available for influent and effluent
    concentrations to both treatment plants on a
    monthly basis.

    Contaminant mass removal data for the on-
    site system was provided by the site
    engineer.

    Contaminant mass removal for the off-site
    system was calculated from annual well
    concentration data and pumping rates from
    each well.
                                             Figures 2 and 3 were generated from data
                                             provided in annual reports. Figure 4 was
                                             generated from data provided by the
                                             primary contact for this site. Annual data
                                             were used to generate the graph.

                                             Data are available from 1988 through 1996
                                             for this report. The 1995 Annual Report
                                             includes data from 1988 through 1995.
                                             Quarterly reports were used for data through
                                             the first quarter of 1996.
Eerfs
ice Data Quality
The QA/QC program used throughout the remedial action met the EPA and the State of Washington
requirements. All monitoring was performed using EPA-approved SW-846 methods, and the vendor did
not note any exceptions to the QA/QC protocols.
                                TREATMENT SYSTEM COST
           ant Proces!
 The Western Processing Trust Fund contracted with Chemical Waste Management (now OHM) to
 construct and operate the initial P&T system at the site. Landau Associates is the primary technical
 consultant to Western Processing Trust Fund.  Tacoma Pump and Drilling Company has been contracted
 to provide parts of the installation.

 Cost Analysis

 •   All costs for investigation, design, construction and operation of the treatment system at this site
     were borne by the PRPs. The following costs are for the remediation systems operating at this site
     through 1995 and exclude excavation and disposal [17].
 Caoital Costs T13.16.171
  Remedial Construction

  Administration and Mobilization               $2,827,998

  On-Site Laboratory and Monitoring Wells        $1,051,610

  Site Work                              $3,282,631

  Slurry Wall                             $1,382,744

  Extraction/Reinjeotion Wells and Infiltration       $2,977,339
  System

  Original Treatment System                  $1,895,740

  Original Air Stripping System                $2,311,988

  Oversight                               $302,579

  Total Construction                      $16,032,629
                                                    Ooeratina Costs M3.161
                                           Operations and Maintenance           $18,866,923

                                           Administration and Taxes              $4,057,576

                                           Operational and Environmental          $7,657,272
                                           Monitoring
                                           Wastewater Treatment Discharge Fees    $2,115,712

                                           Total Operating Expenses           $32,697,483
                                           (1988-1995)
        EPA
                                                       U.S. Environmental Protection Agency
                                               Office of Solid Waste and Emergency Response
                                                               Technology Innovation Office
                                                253
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                                                                Western Processing Superfund Site
                           TREATMENT SYSTEM COST (CONT.)
  Rgmedial Investigation

  Remedial Investigation/ Feasibility Study     $2,366,654

  Oversight                            $13,191

  Total Investigation                   $2,379,845
  Remedial Design

  Remedial Design                     $1,382,919

  Oversight                            $22,644

  Total Design                       $1,405,563


gaaLDataflualltv
Actual capital and operations and maintenance cost data are available from Landau Associates, Inc.
                        OBSERVATIONS AND LESSONS LEARNED
   The cost for groundwater remediation
   between 1988 and 1995 was approximately
   $48,730,000 ($16,032,629 in capital costs,
   including the slurry wall, and $32,697,483 in
   operating costs), corresponding to a unit
   cost of $50 per 1,000 gallons of
   groundwater treated and $478 per pound of
   contaminant removed.

   The average annual operating expenses
   estimated using the above information are
   about $4,500,000.

   The original approach to this site was an
   aggressive effort to fully restore the site to
   original conditions within seven years.
   Restoration was a priority and high costs
   were incurred to achieve this goal. For
   example, the on-site extraction system
   consisted of over 200 thirty-foot well points
   each connected to a vacuum extraction
   system. This system was very costly to
   install and operate, but was expected to
   restore the site. After eight years of P&T,
   the goal of restoration was changed to
   containment based on technical
   Impracticability of achieving full restoration.

   Goals set for surface water (Mill Creek)
   were time-specific.  Mill Creek goals were
   set to be achieved within three years of the
   Consent Decree. The PRPs made the
   decision to install a slurry wall around the
     EPA
 site at a cost of approximately $1.4 million
 to achieve this goal.

 More detailed study of the interactions of
 the broad range of contaminants found at
 the site was started in 1990. This effort
 included studies relating to contaminant
 transport and partitioning coefficients, as
 well as additional testing on the LNAPL
 layer and recovery system. These studies
 added an additional $600,000 in overall
 costs.

 The use of a slurry wall and a groundwater
 extraction system was successful at
 meeting the surface water criteria for Mill
 Creek.  The surface water goals were
 achieved within the three-year window
 granted by the Consent Decree.

 Cleanup efforts at this site were very
 complicated from an engineering
 perspective. Organic and inorganic
 compounds were located  in the saturated
 zone to depths  of 40 feet and below. Many
 source areas were spread over the 13-acre
 site and subsurface source zones were
 likely present in several areas.  The
 chemical and hydrogeologic complexity of
 this site led to increased costs and
 ultimately a change in approach from
 restoration to containment.
         U.S. Environmental Protection Agency
 Office of Solid Waste and Emergency Response
	Technology Innovation Office
                                            254
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                                                             Western Processing Superfund Site
                  OBSERVATIONS AND LESSONS LEARNED (CONT.)
   The most rapid reductions in contaminant
   concentrations occurred between 1988 and
   1991 (see Figure 3). Contaminant
   concentrations level out from 1991 through
   1996. This trend has been observed at
   several other P&T sites.
                                      REFERENCES
1.   Final Report Hvdroaeoloaical Assessment.
    Hart Crowser and Associates, Inc., October
    1984.

2.   Remedial Action Plan Phase II: Subsurface
    Cleanup. Landau Associates, Inc.,
    September 1984.

3.   Record of Decision. U.S. Environmental
    Protection Agency, September 1985.

4.   Schedule Work Plan. Chemical Waste
    Management, Inc., December 1987.

5.   Quarterly Interpretive Report 4th Quarter
    1993. Landau Associates, Inc., April 1994.

6.   Remedial Action Report. Landau
    Associates, Inc., May 1994.

7.   Remedial Action Report. Installation of
    Extraction Wells 5U1A. 5U2A. 1U3A.  1U4A.
    1U5A. 1U6A and Well Points 207-210.
    Landau Associates Inc., May 24,1994.

8.   Technical Impracticably Waiver Petition.
    Western Processing. Landau Associates,
    Inc., September 12,1995.  (Referenced as
    T.I.  Petition.)

9.   Technical Impracticably Waiver Petition.
    Western Processing (Appendices). Landau
    Associates, Inc., September 12,1995.
    (Referenced as T.I. Petition.)

Analvsis Preparation             	
10. 1995 Annual Evaluation. Western
   Processing. Landau Associates, Inc., May
   14,1997.  (Referenced as 1995 Annual
   Evaluation.)

11. Copy of Western Processing Consent
   Decree. Filed April 10,1987.

12. [Explanation of Significant Differences.
   Western Processing Superfund Site. U.S.
   Environmental Protection Agency,
   December 11,1995.

13. Correspondence with Paul Johansen and
   Bill Enkeboll, July 8,1997.

14. 1991 Annual Evaluation.  Landau
   Associates, Inc., Augusts, 1992.

15. Quarterly  Interpretive Report. 3rd Quarter
   1996. Landau Associates, Inc., April 2,
   1997.

16. Groundwater Remedial Cost Analysis.
   U.S. Environmental Protection Agency
   Unpublished.

17. Comments on draft report provided by Lee
   Marshall,  Region 10 Project Manager, and
   Bill Enkeboll, Landau Associates.
This case study was prepared for the U.S. Environmental Protection Agency's Office of Solid Waste and
Emergency Response, Technology Innovation Office.  Assistance was provided by Eastern Research
Group, Inc. and Tetra Tech EM Inc. under EPA Contract No. 68-W4-0004.
      EPA
            U.S. Environmental Protection Agency
    Office of Solid Waste and Emergency Response
    	Technology Innovation Office
                                            255
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                                                              Western Processing Superfund Site
                                        Attachment A
                              Consent Decree Text Pertaining to
                                    Mill Creek Standards

Allowable Concentrations in Mill Creek.

    a.  If the concentration of a Mill Creek indicator chemical (as listed in Table 1) or other priority
       pollutant at the upstream (background) monitoring point in Mill Creek is less than two-thirds of
       the applicable upstream Federal Ambient Water Quality Criterion for Aquatic Organisms
       (Water Quality Criterion)1, the maximum allowable concentration at the downstream
       compliance point1 shall be the downstream Water Quality Criterion3.

    b.  If a Water Quality Criterion is not achievable because the upstream (background) concentration
       of a chemical is near or above the Water Quality Criterion, the maximum allowable
       concentration at the downstream compliance point shall be the level described below:

       i.   If the concentration of a Mill creek indicator chemical or other priority pollutant at the
           upstream (background) monitoring point in Mill Creek is at or above two-thirds of the
           upstream Water Quality Criterion but less than the upstream Water Quality Criterion, the
           maximum allowable concentration at the downstream compliance point shall be no more
           than the background concentration plus fifty (50) percent of the background concentration;
           or

       ii.  If the concentration of a Mill Creek indicator chemical or other priority pollutant at the
           upstream (background) monitoring point in Mill Creek is at or above the upstream Water
           Quality Criterion, the maximum allowable concentration at the downstream compliance
           point shall be no greater than background plus eighty (80) percent of the upstream Water
           Quality Criterion.

    c.  Meeting the above performance standards shall not require responsibility for any contaminated
       water entering Mill Creek between the upstream monitoring and downstream compliance
       points that is contaminated by a source other than the Site or Western Processing activities.
       Upon demonstration by the Consenting Defendants that water contaminated by a source other
       than the Site or Western Processing activities is entering Mill Creek between the upstream
       monitoring and downstream compliance points and quantification of such contamination by the
       Consenting Defendants, an appropriate adjustment will be made by the Governments for the
       Contaminants attributable to such .other source.
    1The applicable Water Quality Criteria shall be those final criteria published in the Federal Register as of the
date of entry of this Consent Decree.

    2The upstream monitoring point and the downstream compliance point are those described in subparagraph
IV.D.7.b. below.

    Designation of upstream and downstream is necessary because the applicable Water Quality Criterion varies
depending on the hardness of the water.
      EPA
        U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
               Technology Innovation Office
                                            256
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