PB94-964314
EPA/ROD/R07-94/076
February 1995
EPA Superfund
Record of Decision:
Strother Field Industrial Park
(O.U. 1), Winfield, KS
3/31/1994
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VII
726 MINNESOTA AVENUE
KANSAS CITY, KA.NSAS 66'101
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MEMORANDUM
SUBJECT:
Record of Decision for the Strother Field
Park super~~te, Wi~fie1d, Kansas
Michae1~~rson, Acting Director
Waste Man~~ent Division
Industrial
- FROM:
TO:
Dennis Grams, P.E
Regional Administrator
The attached Record of Decision presents the proposed remedy
for the final remedial action for the ground water and soils at
the subject site. This remedy will address the principal threat
posed by the contaminants in the ground water by preventing the
fu~ther migration of contaminants off the Strother Field
Industrial Park site and by eventually restoring the ground water
to acceptable quality (Safe Drinking Water Act Maximum, .
contaminant Leve1s-MCLs) by the extraction and treatment of
contaminated ground water. The remedy will further reduce the
threat of continued contamination of the ground water from the
treatment of the soil source areas.
The selected remedy in this Record of Decision has been
coordinated with the Office of Regional Counsel, the Office of
Public Affairs, the Congressional and Intergovernmental Liaison,
the Agency for Toxic Substances and Disease Registry and the
Kansas Department of Health and. Environment,.
On December 27, 1990, the remedy selection authority for the
Strother Field Industrial Park site was delegated to you by
Don R. Clay, Assistant Administrator. I recommend approval of
the proposed remedy.
Attachment
R;:r'..r: \.
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STROTHER FIELD INDUSTRIAL PARK SUPERFUND SITE
RECORD OF DECISION DECLARATION
SITE NAME AND LOCATION
Strother Field Industrial Park Site
winfield,'Kansas (Cowley County)
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected final remedial action
for the ground water and soils at the Strother Field Industrial
Park Site, Winfield, Kansas, chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), 42 U.S.C. section 9601 et sea.,
and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 CFR Part 300.
This decision is based 'on' the administrative record for the
Strother Field Industrial Park Site, in Winfield, Kansas.
The United States Environmental Protection Agency (EPA) and the
Kansas Department of Health and Environment (KDHE) agree on the
selected remedy. '
ASSESSMENT OF THE SITE
The actual or threatened release of hazardous substances at or from
,this site I if' not addressed through the implementation of the
response actions selected in this Record of Decision (ROD), may
present an imminent and substantial endangerment to public health,
welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The Remedial Investigation/Feasibility Study (RIjFS), conducted by
the General Electric Company from March, 1990 to July 1993 at the
Strother Field Industrial Park Site, identified the primary route
of exposure for future use as domestic use of water from existing
or new water wells either at, or downgradient, of the site.
In addition, available data shows elevated concentrations of
volatile organic compounds in soils as a principal threat to the
ongoing contamination of ground water. '
Detectable levels of trichloroethene (TCE), carbon tetrachloride,
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cis 1,2 dichloroethylene (C-1,2-DCE), trans 1,1-dichloroethylene
(t-1, 2-DCE), 1, I-dichloroethane (1, 1-DCA), 1,1 dichloroethylene
(l,l-DCE) and perchloroethylene (PCE) have been detected in the
ground water. Most of these organics, including toluene, have been
detected in the soil at various locations on the site.
This remedy will address the principal threat posed by the
contaminants in the ground water by preventing the migration of
contaminants off the Strother Field Industrial Site and by
restoring the ground water to acceptable quality (Safe Drinking
Water Act Maximum contaminant Levels-MCLs) by the extraction and
treatment of contaminated ground water. The remedy will further
reduce the threat of continued contamination of the ground water
through the treatment of the soil' sour~e areas.
The major components of the selected remedy for the affected ground
water and soil include the following:
o
Enhancement of the existing ground water extraction and
treatment system by changing the location of one existing
'withdrawal well to an existing monitoring well location
and converting three existing monitoring wells to
extraction wells with dedicated air strippers.
o
Monitoring of the ground water collection/treatment
system and the ground water contaminant plume during
ground water remediation activities.
Performing a pilot study of soil vapor extraction (SVE)
to determine its ability to remediate the subsurface soil
contamination areas.
o
o
Moni toring of the SVE system to determine performance and
establish its maximum attainable goals.
o
Monitoring of the emissions from the ground water
treatment system, arid the soil vapor extraction system to
ensure the health and safety of 'on-site personnel and
determine if additional treatment of emissions is
. necessary.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solu~ions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable, and satisfies the
statutory preference for remedies that employ treatment that
permanently and significantly reduces toxicity, mobility, or volume
as a principal element. Because this remedy may result in hazardous
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substances remaining on-site above levels that allow for unlimited
use and unrestricted exposure,. a review will be conducted no less
often than every five years after commencement of remedial action
to ensure that the remedy continues to provide adequate protection
of human health and the environment.
J\~~.
Denn1s Grams,P.E.
Regional Administrator
u.s. EPA - Region VII
I
3-3/-Y~
Date
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RECORD OF DECISION
STROTHER FIELD INDUSTRIAL PARK SUPERFUND SITE
COWLEY COUNTY, KANSAS
MARCH, 1994
U.S. Environmental Protection Agency
Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
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2.0
3.0
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5.0
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I
TABLE OF CONTENTS
site 'Background
1.1 site Location
1.2 Physical Setting
1.3 History
1.4 Past Investigations and
1.5 Highlights of Community
1.6 Summary of the Remedial
Response Activities
Participation
Investigation
Summary of Risks Presented By The Strother Industrial
Park Superfund site
2.1
2.2
2.3
2.4
contaminants of Concern
Exposure Assessment
Toxicity Assessment
Risk Characterization
Scope and Role of Response Action
Summary of Alternatives
4.1
4.2
Screening and Formulation of Alternatives
Detailed Evaluation of Remedial Alternatives
Summary of Comparative Analysis of Alternatives
5.1
5.2
Summary of EPA Evaluation criteria
Evaluation of the Alternatives
Selected Remedy
Statutory Determinations
Responsiveness Summary
Paqe
1
8
11
12
18
26
29
32
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List of Attachments
Attachment I
Attachment II
Attachment III
Attachment IV
Attachment V
Attachment VI
Attachment VII
Attachment VIII
Attachment IX
Attachment' X
Attachment XI
Attachment XII
Attachment XIII
Attachment XIV
Attachment 'xv
Glossary of Terms
Area-wide Location Map
Site-specific Location Map
Chronology of Events Leading to the RIfFS
Strother Field and Vicinity Well and
Piezometer Location Map
Strother Field Industrial Park Wells Sampled
for Chemical Analysis
Maximum COC Concentrations Detected in
Groundwater in Each Area
Standards, Criteria, and Guidelines for
Constituents Detected in Soil and
Groundwater at Strother Field
Target Levels for Remedial Action Objectives
preliminary Remed'ial Action Alternatives for
Groundwater
Preliminary Remedial Action Alternatives for
Soils
screening of preliminary Groundwater
Alternatives
screening of Preliminary Soils Alternatives
Table Listing Costs at the Preliminary
Alternative Screening Stage
Appendix D: Detailed Analysis of
Alternatives; Cost Estimates
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1.0
SITE BACKGROUND
1.1
SITE LOCATION
The Strother Field Industrial Park is located between
Winfield and Arkansas City in Cowley County, Kansas. The
Field covers an area of approximately 2 1/4 square miles and
is occupied by about 23 separate businesses. The site is
located adjacent, and to the west of u.S. Highway 77 and the
Santa Fe railroad. It is bounded by agricultural lands to
the north, south, and west; while the village of Hackney
(population 51) and the Hackney Agricultural Cooperative (a
farmers' cooperative) are on the eastern side of the
property. Area-wide and site-specific maps are included as
Attachments II and III.
strother Field is typical of an industrial park.' The Field
consists of rectangular parcels divided by roads running
north-south and east-west. Much of the land is undeveloped.
Many of the structures built by the Army during its World
War II tenancy still stand and most are still in use by the
current tenants.
1.2
PHYSICAL SETTING
All of' the Strother .Field site is located within tne Posey
Creek watershed. The basin covers an area of 19.5 square
miles and receives about 33 inches of precipitation per
year. Where Posey Creek enters the site, it is an
intermittent stream and has no flow for much of the year.
Originally, the creek flowed through the site from the
northwest to the southeast. However, in the early 1940s,
the Army re~routed the flow around the site. The creek
currently enters the site from the northwest, turns to the
east, flows along the northern property boundary to the
northeast corner, then turns south along the eastern
. property boundary, intercepting its original channel
southeast of the site. All storm waters and treated
sanitary sewage from the site eventually discharge into
Posey Creek. The creek flows to the Walnut River, which is
located approximately four miles east of the site.
The Strother Field Sewage Treatment Plant, an industrial
cooling tower, and two groundwater remediation wells supply
water to Posey Creek at a combined rate of 0.5 cubic feet
per second, (cfs). As a result, Posey Creek becomes an .
artificial perennial stream as it passes through Strother
Field. It is the only perennial surface water at the site.
Posey Creek becomes a natural perennial stream approximately
1.5 miles downstream of the site, where it begins to
intersect an alluvial aquifer which contributes baseflow to
the creek. At this point, the stream discharge is about 1.5
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cfs, which continues to increase in'the downstream direction
to its confluence with the Walnut River.
While the general topography of the site slopes from north
to southeast, a swale (low area) intersects the site from
the vicinity of the General Electric corporation's (GE)
north test cell to the area just north of the property used
by the Cessna Aircraft Company. At this point, the swale
turns about 45 degrees in the direction of the point where
Posey Creek turns away from the site toward the Walnut
,River. The swale appears to conform to what was the
original channel of Posey Creek. For the most part, the
swale is located west of any industrial operations, in the
aircraft parking area. Surface runoff from much of GE,
Struthers Thermo-Flood, and the other aircraft related
industries at the site either flows into this swale, to an
open drainage ditch parallel to the railroad spur, or to
storm sewer inlets. The swale, drainage ditches, and the
storm sewer all flow to Posey Creek at the southeastern
corner of the site.
1.3
HISTORY
The land now occupied by Strother Field was farm land before
1940 wh~n the cities of Arkansas City and Winfield purchased
it to build a municipal airport. Work had already begun on,
.the air strip when, in 1942, the u.S. Army Air Force asked
the cities to purchase additional land and to lease the
property to the federal government to be used as a military
base. The Army constructed an air base, which it operated
as a basic training school from 1942 to 1945. The Army
returned the land, with improvements, to Arkansas City and
Winfield in 1946. Gradually, the cities developed the Field
into an industrial park. Many of the buildings and airfield
runways existing today were constructed by the u.S. Army Air
Force during the early 1940s. The Strother Field Industrial
Park is managed by the Strother Field commission, which
represents Arkansas City and Winfield.
Much of the past activity has been related to aircraft
construction and maintenance. Similarly, land use during
the Army's tenancy was typical of a military air base. It
included aircraft maintenance and support activities, as
well as housing/barracks' and related personnel facilities.
Most of the Army's industrial activities centered around the
aircraft parking apron and the area to the south of the
current GE operations. The Army used the .land in the
central part of the Field, currently occupied by GE, for
. hangars, barracks, classrooms, and offices. The land to the
south was used by the Army for aircraft repair, hangars,
vehicle maintenance (i.e., motor pool) and for grounds and
facilities maintenance (i.e., civil engineering shops). The
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Army constructed a dump at the north end of the Field.
other properties at the Field have accommodated office
buildings, an auto repair shop, oil field servicing,
warehousing, and manufacturing industries. Presently, there
are 23 industries located at the Field, including the
Strother Field Commission and the Sewage Treatment Plant.
Since 1986, five of the site tenants have stored hazardous
materials on-site and/or generated hazardous waste. These
include pesticides, fuels and solvents, fuels, oils,
solvents, acid, and antifr~eze. During 1983 and 1984
inspections of the Field, the Kansas Department of Health
and Environment (KDHE) discovered that ten site tenants were
using, or had used, organic solvents. Thesolvents
identified by KDHE were used as paint thinners and
strippers, degreasers, and cleaning compounds. Specific
compounds included toluene, xylene, methyl ethyl ketone,
lacquer thinner, 1, 1, I-trichloroethane, carbon
tetrachloride, methylene chloride, orthodichlorobenzene,
perchloroethylene, trichloroethylene, and proprietary
materials containing chlorinated solvents.
Some tenants either have or have had underground or above-
ground storage tanks used for fuel storage.
.Strother Field originally obtained its water from a series
of wells located along the eastern boundary of the Field.
Following the discovery of VOCs in these wells in 1983, new
wells were drilled on the western and northeastern
boundaries of the site. The nearby community of Hackney and
the Hackney Agricultural Cooperative also obtain water from
wells in the area east of the Field. An underground sewage
system conveys wastewater from the Field to a treatment
plant located southeast of the site, across u.s. Highway 77.
There are no septic fields on the site. However,
residential ~reas outs~de the. industrial park probably.have
septic systems, as Cowley County does not supply sewage
treatment in the area. The Field manages storm water
through a network of ditches and underground pipes, most of
which run adjacent to the roads and eventually discharge
into Posey Creek, east of the Field.
Natural gas and electricity are available to tenants of the
Field from the City of Winfield. Tenants are responsible
for their own solid waste disposal. The nearest municipal
landfill is located approximately one and one-half miles
southeast of the Field. In the past, two areas were used as
landfills by the tenants. One of these is north of the
Field and dates back to the Army's tenancy in the early
1940s. It was taken out of service in 1975. The other is
across Highway 77, near the wastewater treatment plant. It
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was taken out of service in 1971. A third possible dump
site was identified as a potential source area of VOCs. It
is located east of GE's north test cell and is the former.
location of the Army's small arms firing range. Tenants of
the Field may have disposed of bulk liquids in a trench at
. this location..
1.4
PAST INVESTIGATIONS AND RESPONSE ACTIVITIES
In August of 1982, KDHE detected dissolved organic solvents
in water supply wells at Strother Field during a Synthetic
Organic Chemical Survey. The predominant compounds detected
in the groundwater samples were trichloroethylene (TCE),
1,2-dichloroethylene (1, 2-DCE), 1, ~, ~-trichloroetharie (TCA).,
tetrachloroethylene (PCE), and 1,1-dichloroethylene (1,1-
DCE). In 1983, KDHE attempted to verify these findings and
to learn more about the extent and potential sources of
these constituents.
KDHE also received reports that unknown quantities of spent
chlorinated solvents had been disposed of at two inactive
landfills located northwest and southeast of the active
industrial park. Further, a third disposal site may have
beep located in the vicinity of GE's north test cell.
These factors led KDHE to require that the Strother Field
Commission develop alternative drinking water supplies for
the tenants. Two of the original wells which had been found
to contain dissolved organic solvents were subsequently
converted to recovery/remediation wells as part of an
overall groundwater containment and treatment system.
Presently, wells REM-1, SFW-2, and SFW-8 are extracting
groundwater at rates of 100, 100, and 150 gallons per minute
(gpm), respectively, for the purpose of cleanup and.
containment. The contaminated groundwater recovered from.
these wells is processed through air-stripping towers and
the treated effluent is discharged to Posey Creek (through
the Publicly Owned Treatment Works (POTW) in the case of
well REM-1) in accordance with existing State discharge
permits. Over the next several years, KDHE directed
numerous additional investigations and monitoring programs.
On March 28, 1990, GE entered into a consent agreement with
KDHE to conduct a Remedial Investigation and Feasibility
Study (RI/FS) pursuant to the Comprehensive Environmental
Response, compensation, and Liability Act (CERCLA).
Attachment IV presents a chronological summary of events
beginning with KDHE's initial investigations, through the
present time. Since much of the information presented in
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the table refers to sampling events from groundwater
monitoring wells, a well location map has been provided as
Attachment v.
1.5
HIGHLIGHTS OF COMMUNITY PARTICIPATION
Community participation was provided in accordance with
CERCLA, as amended by SARA and, to the extent practicable,
the National Contingency Plan (NCP). Community
participation highlights include the availability of several
key documents in the administrative record, a public .comment
peri0d and a pUblic hearing.
A community relations plan for the Strother Field Industrial
Park Site was completed by KDHE and approved by EPA in
.of May of 1991. This document lists contacts and interested
parties throughout government and the local community and
specifies the community relations activities expected to be
undertaken during the remedial process. It also establishes
communication pathways to ensure dissemination of pertinent
information.
The administrative record for Strother Field Industrial Park
site was released in February of 1991. The records have
been made available to the public at the following
addresses:
Kansas Department of Health and Environment
Bureau of Environmental Remediation
Forbes Field, Building 740
Topeka, Kansas 66620-7500
913-296-3393
Strother Field Commission
Terminal Building, 4th and A
Strother Field Industrial Park
P. o. Box 747
Winfield, Kansas 67156
316-221-9280
United States Environmental Protection Agency
Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
913-551-7000
A press release was issued on November 17 announcing the
release of the Proposed Plan, commencement of the public
comment period and notice of the Public Hearing for the
Strother Field Industrial Park Site.
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The Public Hearing was held on December 14, 1993 to present
the Proposed Plan and to receive comments. The extension of
the comment period through January 21, 1994, was also
announced as a result of a request to extend the period to
comment. At this meeting representatives of EPA and KDHE
were available to answer questions 'and record comments
concerning the Proposed Plan.
All comments received by EPA and KDHE t~roughout the comment
period are addressed in the Responsiveness Summary in this
Record of Decision.
1.6
SUMMARY OF THE REMEDIAL INVESTIGATION
Although previous studies had provided a great deal of
information on the distribution of constituents in the
groundwater, less was known about the sources of these
substances. Therefore, the first task of the RI was to
examine the available data and develop a strategy to locate
source areas. Twelve potential source areas were identified
based on their proximity to known areas of contamination, as
well as upon historical information about chemical and waste
management practices. One of these areas, near the Hackney
Agricultural Cooperative, is not part of the Strother Field
Industrial Park. The contamination associated with the
H,ackney Coop is being addressed by KDHE and monitoring wells
will continue to be sampled to characterize that plume'of
contamination. A soil gas survey was completed on each of
those areas on the Strother Field Industrial Park to locate
zones of elevated VOCs. soil samples from the vertical zone
which exhibited the highest concentration of VOCs in the.
soil gas survey were then obtained and subsequently
analyzed. These results were compared to historical records
of past chemical use practices and a high correlation was
found between zones of contamination and specific activities
conducted by the tenant or property owner at those locations
(see Attachment VI). ' ,
From north to south, these source areas include:
Northern Groundwater Plume:
.
.
the inactive north landfill (Area 1),
the ditch located north of GE's porth
10), and
the third suspected dump (Area 11).
test cell (Area
.
North-Central Groundwater Plume:
.
two former drum storage areas and a loading area at
Struthers Thermo-Flood (Area 8).
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'.
Eastern Groundwater Plume:
.
the vicinity of the Hackney Agricultural cooperative
(no source investigations conducted at this location).
Central Groundwater Plume:
.
former discharge lines from GE's hangar building 9
, (Area 3), and
GE's former solvent tank and supply lines to the former
vapor degreaser in building 5 (Area 3).
.
Southern Groundwater Plume:
.
Greif Brothers' paint waste treatment operation (Area
4) ,
Greif Brothers' loading dock (Area 4),
Greif Brothers' degreasing operations and associated
solvent storage tank (Area 4),
Gordon Piatt's property next to Greif Brothers'
hazardous waste drum storage area (Area 4) "and
the inactive south landfill (Area 2).
.
.
.
At each of these source areas, VOCs appear to have been,
released onto or into the soil. The soils in the northern
plume area were relatively free of VOCs, with the exception
of a sample obtained near GE's north test cell (Area 10),
which contained degradation products of TCE and TCA. The
soil gas survey results for the north-central plume (Area 8) .
revealed elevated levels of DCE, a degradation product of
PCE, TCE, and TCA. Additionally, one shallow soil sample in
the north-central area was found to contain elevated levels
of toluene. In the central plume area, TCE and its
degradation product were found in a boring near the former
location of GE's building 5 vapor degreaser; the soil gas
survey revealed elevated levels of DCE in this area, as well
as in the vicinity of GE's building 9 hangar (Area 3).
Soils in the southern portion of the site (Area 4) contain
PCE, TCE, TCA, and their degradation products, with one
exception. Toluene and methyl ethyl ketone Were the
predominant VOCs found at the Greif Brothers' paint waste
treatment operation. Insufficient data was obtained from
the Hackney area to characterize soil contamination.
The concentration of VOCs in the soils within the source
areas increases with depth, indicating that the predominant
pathway for past and future migration would likely be
vertically into the groundwater. Consequently, additional
groundwater monitoring wells were installed to learn more
about the geology and hydrogeology of the site, and to more
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accurately predict the distribution and movement of
contaminants in the groundwater. The data obtained from
these wells was used to prepare isoconcentration.maps,
potentiometric surface maps, and to calibrate a groundwater
model.
The groundwater data show five distinct plumes of VOCs, as
indicated above. These plumes correlate well with respect
to the location and the composition of the contamination
from" each of the corresponding source areas. The primary
constituents in the north, north-central, and central plumes
are TCE, TCA, and their degradation products. The major
constituents in the southern plume are PCE, TCA, TCE, and
their degradation products. The major constituents in the
Hackney area are carbon tetrachloride and chloroform, a
degradation product of carbon. tetrachloride.
According to the groundwater model prepared by GE's
consultant, these constituents are, to some extent, being
captured by the current groundwater recovery system. Three
areas were identified where contaminant migration in
groundwater is potentially progressing beyond the recovery
capabilities of the present system. These include the
southern-most portion of the site, a localized "hot spot"
near well DM-15 at GE', s north test cell, and the Hackney
area. 'Well RI-7, located southeast of the site, s~owed .
elevated levels of TCE, suggesting that some constituents at
the south end of the site may have escaped the capture zone
of recovery well SFW-8. This is supported by the
piezometric surface contours which show that the influence
of SFW-8 is weak in' this area. In the north, well DM-15 has
consistently shown high levels of VOCs, inconsistent with
its proximity to recovery well REM-I. This suggests that
localized geologic conditions may pose a barrier to flow
from DM-15 to the recovery well. contaminants that appear
to originate from the Hackney area (carbon tetrachloride and
. chloroform) are migrating toward the site due to the
influence of recovery wells SFW-2 and SFW-8.
2.0
SUMMARY OF RISKS .PRESENTED BY THE STROTHER FIELD INDUSTRIAL
PARK SUPERFUND SITE
As part of the RIfFS, a Baseline Risk Assessment (BLRA) for the
Strother Field site was performed. The objectives of the BLRA
were to assess the magnitude and potential of actual or potential
harm to public health and the environment resulting from the
release of hazardous substances from the site in the absence of
remedial action (i.e. the "no-action" alternative). To conduct
the BLRA, numerous tasks were performed, including identification
of contaminants contributing to potential risk, assessing
potential exposure pathways, assessing the toxicity of the
constituents of concern, and characterizing/quantifying the risk.
The BLRA r~port was based predominantly on data collected during
the remedial investigation.
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2.1 CONTAMINANTS OF CONCERN
The initial phase of the BLRA included compiling a list of .
hazardous constituents which were present at the site based
on the results of the various sampling activities. Volatile
organic compounds have been identified in groundwater,
surface water, and soils at or near Strother Field. The
chemicals that contribute most significantly to human health
risk are: vinyl chloride, PCE, TCE, DCE, TCA, and DCA. The
contaminants of concern (COCs) detected in groundwater
either on-site or off-site and the maximum concentrations
detected of the COCs are i~lustrated in Attachment VII. The
corresponding MCLs and KALs, or regulatory levels of concern
of the COCs are presented in Attachment VIII.
2.2
EXPOSURE ASSESSMENT
This BLRA focused on potential or actual risks to human
health posed by contaminants at, or released from the
Strother Field Site. The human population most likely to be
exposed to contaminated groundwater and air are those
individuals living and working in the vicinity. It should
be noted that the BLRA for Strother Field focused on those
exposures with. the highest probability of occurrence.
TheoBLRA centered' on the potentially significant release
mechanisms of the known contaminants including the leaching
of contaminants into and subsequent movement with the
groundwater and the discharge of contaminants into surface
soils. In its evaluation of the potential release
mechanisms, the BLRA identified several scenarios with a
high probability for exposure to populations living and
working in tb~ vicinity of the site. These scenarios,
evaluated for current and future conditions included the
ingestion of groundwater and the potential for ingestion of
ground water leaching from contaminated soils.
2.3 TOXICITY ASSESSMENT
Potential carcinogenic and non-carcinogenic effects
associated with the major chemicals of concern detected at
Strother Field are described qualitatively in the following
discussion.
1,1 Diqhloroethane (l,l-DCA), also known as ethylidene
dichloride, is classified as a group C carcinogen (possible
human carcinogen). Very high doses produce some liver and
kidney lesions. Acute exposures produce local irritation
and central nervous system depression.
1,1 Dichloroethene (l,l-DCE) commonly known as vinylidene
chloride, is classified as a group C carcinogen. 1,1
Dichloroethene is absorbed through all routes and is
extensively metabolized in the liver, primarily by oxidation
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and conjugation. There are numerous known interactions with
other compounds that cause toxic effects.
1,2 Dichloroethene (1,2-DCE) and its cis-dichloroethene and
trans-dichloroethene isomers are not demonstrated human
carcinogens. The major effect of acute doses of 1,2 DCE is
central nervous system depression. Repeated inhalation
causes 1esions in the lungs, liver and kidney.
Trichloroethene (TCE) is classified as a group B2 carcinogen
(a probable human carcinogen). Trichloroethene is well
absorbed after inhalation and ingestion, and to' some extent
through the, skin. It tends to accumulate in fat cells. It
has been shown to cause pulmonary adenocarcinoma, lymphoma,
and hepatocellular carcinoma in multiple strains of mice.
Subchronic and chronic exposures of animals to TCE appears
to result in liver and kidney toxicity. '
Tetrachloroethene, commonly known as perchloroethene (PCE),
is a group C carcinogen. Mouse and rat studies have
indicated that PCE is a teratogen and reproduction toxin.
In addition, both oral and inhalation exposure of laboratory
animals to PCE for intermediate and long-term exposure leads
to liver, kidney and spleen toxicity.
,Vinyl Chloride is a group A carcinogen (a known human
carcinogen). It is virtually completely absorbed following
ingestion, but dermal absorption is negligible. Repeated
low doses in workers produce scleroderma-like skin changes,
lung toxicity, thrombocytopenia, liver toxicity and x-rays
show evidence of bone destruction of the distal finger
bones.
2.4
RISK CHARACTERIZATION
The BLRA evaluated potential non-carcinogenic and
carcinogenic risks posed by the indicator contaminants in
the various exposure media at the site. Carcinogenic risks
were characterized in terms of upperbound excess lifetime
cancer risks and non-carcinogenic risks were characterized
in terms of a hazard index and hazard quotients.
Under future conditions, the BLRA identified potentially
significant risks to human populations using 'groundwater at
the site as a drinking water source. The carcinogenic risk
was estimated to be in excess of 1 in 1,000 from ingestion
of groundwater. EPA considers this level of risk to be
significant. The contaminants that contributed major
portions of the risk are 1,1 DCE and vinyl chloride. USEPA
guidance suggests that target carcinogenic risks resulting
from exposure at Superfund sites may range between 1 in
10,000 to 1 in 1,000,000. Using this range as a baseline, a
risk level greater than 1 in 10,000 is considered to be
"significant" and a risk level less than 1 i~ 10,000 is
10
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3.0
considered "insignificant". Usually, remediation goals (the
point of compliance) for groundwater are the Maximum
contaminant Level (MCL), Kansas Action Level (KAL) or the
established clean up level for individual contaminants to
reach and/or maintain an acceptable risk level.
SCOPE AND ROLE OF RESPONSE ACTION
As discussed in section 3.0, the BLRA indicates that the greatest
risk to human health could occur from future ingestion of
contaminated groundwater. The primary route of exposure for
future use would be through domestic use of water from existing
or new water wells. The point of ingestion may be either at, or
downgradient, of Strother Field. The contaminants of concern
(COC~) detected in groundwater either on-site or off-site and the
maximum concentrations detected of the COCs are illustrated in
Attachment VII. The corresponding MCLs and KALS, or regulatory
levels of concern of the COCs are presented in Attachment VIII.
Based upon the findings of the RI/FS, the following remedial
response objectives have been established for Strother Field.
5.
6.
1.
To prevent ingestion and direct contact with soil which
contains one or more of the constituents listed in
Attachment IX, at levels which exceed the target levels
for soils. . .
2.
To prevent the migration of hazardous constituents from
soils at levels which would cause previously non-
impacted groundwater to become impacted by one or more
of the constituents listed in Attachment IX, at levels
which exceed the target levels for groundwater.
To restore soil quality within the boundaries of the
Strother Field Industrial Park such that it no longer
contains any of the consti~uents listed in Attachment
IX, at levels which exceed the target levels for soils.
3.
4.
To prevent human consumption of groundwater containing
one or more of the constituents listed in Attachment
IX, at levels which exceed the target levels for
groundwater.
To prevent the off-site migration of any groundwater
containing one or more of the constituents listed in
Attachment IX, at levels which exceed the target levels
for groundwater.
To restore groundwater quality within the boundaries of
the Strother Field Industrial Park such that it no
longer contains any of the constituents listed in
Attachment IX, at levels which exceed the target levels
for groundwater.
11
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The conclusions of the BLRA and the identification of response
objectives provide the basis for selection of a preferred
alternative. The preferred alternative will address groundwater
contamination through extraction and treatment (air-stripping) to
acceptable levels (MCLs or KALs). Soils will be remediated
through in-situ treatment (soil vapor extraction), consistent
with the goal to reduce contaminant toxicity, mobility, and
volume and to minimize potential future releases to groundwater.
The preferred alternative will reduce the threat of continued
groundwater contamination by minimizing the potential impact of
active source areas and will reduce the potential for gro~ndwater
contaminant migration in the downgradient direction.
4.0 SUMMARY OF ALTERNATIVES
4.1
SCREENING AND FORMULATION OF ALTERNATIVES
The feasibility study evaluates five general response
actions which could be applied to the contaminated media and
conditions known to exist at the Strother Field site. The
general response categories include: (1) no action; (2)
institutional controls; (3) containment; (4) removal; and
(5) treatment. The feasibility study identified and
screened remedial action technologies associated with
general response action. The screening criteria used
the analysis included .effectiveness, implementability
Oost of the remedial action technology.
Remedial action technologies were screened for applicability
to the specific affected media types - soil and groundwater.
each
for
and
The remedial action technologies evaluated for soil
included: (1) containment through technologies such as
capping or hydrologic barriers and controls; (2) excavation
and treatment; (3) fixation and stabilization; and (4) soil
vapor extraction (SVE)..
The' remedial action technoiogy evaluated for g~oundwater was
groundwater extraction and treatment by various technologies
or combinations of technologies such as air-stripping,
carbon adsorption, and UV photolysis.
The remedial alternatives selected for further evaluation
are presented below. The alternatives described are media-
speci£ic, thus requiring a combination for the final site-
wide remedial alternative to address both soil and
groundwater. These alternatives are numbered to correspond
to those presented in the Final FS report (October, 1993).
REMEDIAL ACTION ALTERNATIVES FOR GROUNDWATER
The FS identified eight (8) alternatives for groundwater
(numbered 1-8 below):
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Alternative 1. This is the "no action" Alternative required by
the NCP. It is the baseline against which the effectiveness of
the other Alternatives will be judged. Under the no-action
Alternative, no institutional controls would be implemented and
no monitoring, control, or remediation of the groundwater
contamination would be conducted. By definition, this would
require that the existing groundwater recovery and treatment
system and the quarterly monitoring program be discontinued.
Alternative 2. This is a limited-action Alternative which
consists primarily of institutional controls. It includes land
title covenants (deed restrictions) to prevent future use of
contaminated groundwater for human consumption. These covenants
would preclude the construction of new potable water supply wells
and the conversion of existing wells for use as potable water
supplies in areas that are or may be impacted by the groundwater
contamination. This Alternative aiso includes the posting of
warning signs and continued operation of the existing groundwater
monitoring program. These institutional controls would serve to
reduce the likelihood that persons on- or off-site would be
exposed to contaminated groundwater before natural processes
(e.g., biodegradation and dilution) have reduced the
concentration of constituents to acceptable levels. This
Alternative would also require that the existing groundwater
recovery and treatment system be discontinued. However, the
quarterly groundwater monitoring program would be retained and
modified, as necessary, to serve as an early warning system for
potential off-site migration of contamination at levels above the
cleanup standards.
Alternative 3. This Alternative most closely represents the
current site status, but includes institutional controls as
described for Alternative 2, with the exception of warning signs.
Groundwater monitoring would continue on a quarterly basis.
Wells REM-1, SFW-2, and SFW-8 would continue to remove
groundwater at current rates (100, 100, and 150 gpm respectively)
for the purpose of cleanup and containment. The contaminated
groundwater recovered from wells REM-1, SFW-2, and SFW-8 would
continue to be processed through the existing air-stripping
towers and the treated effluent would continue to be discharged
to Posey Creek (through the POTW in the case of REM-1) in
accordance with existing state discharge permits.
Alternative 4. The remaining Alternatives, including Alternative
4, emphasize accelerated cleanup of the groundwater plumes. In
general, the strategy for each of these Alternatives would be to
extract groundwater from the zone of highest VOC concentration
within the four plume areas. Existing recovery well REM-1 would
be moved to the location of monitoring well DM-15. Monitoring
wells DM-14, DM-5, and GGP-2 would be converted to
extraction/recovery wells. Wells SFW-2 and SFW-8 would continue
to operate primarily to prevent off-site migration, serving to
extract and remove groundwater contaminants in the process. The
contaminated groundwater recovered from wells DM-15 (using the
existing IREM-1" tower), SFW-2, and SFW-8 would continue to be
13
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,
processed through the existing air-stripping towers and the
treated effluent would co~tinue to be discharged to Posey Creek
(through the POTW in the case of DM-1S) in accordance with
existing discharge permits. For Alternative 4, the VOCs in the
water recovered from wells DM-14, DM-S, and GGP-2 would be
removed through the use of dedicated air-stripping towers located
in the vicinity of each well. Effluent from the towers would
discharge to Posey Creek and would require state discharge
permits. The towers would be designed to achieve an effluent
quality that is consistent with the current state standards for
discharges from SFW-2 and SFW-8 to Posey Creek. Alternative 4
would include all of the institutional controls described for
Alternative 3.
Alternative 5. This Alternative would include identical features
as Alternative 4, except that the treated groundwater effluent
from the five of the six air-stripping towers would be further
processed through carbon adsorption units. Recovery well DM-15
would not require a carbon adsorption system since discharge from
this system is to a water treatment system (POTW). Each of the
five air-stripping towers would be outfitted with a dedicated
carbon treatment unit, requiring slight modifications to the
existing units. The air-strippers would provide primary
treatment and the carbon units would serve as a polishing step
and safety factor against possible VOC surges at levels above the
design capacity of the stripping towers. The carbon treatment
units would thereby provide assurance. against poteptial
exceedances of NPDES discharge criteria. The spent activated
carbon would be transported as a hazardous waste to an off-site
reprocessing or disposal facility, depending on economic
considerations.
Alternative 6. This Alternative would be identical to
Alternative 5, except that the treated effluent from each
activated carbon adsorption unit would be reinjected into the
groundwater at a point up-gradient of the plume from which it was
extracted. .The oxygen-enriched injection water should promote
more rapid bio-degradation. In addition, the injection water
should help "flush" contaminants from the aquifer, increase the
hydraulic head across the plume area, and maintain the design
water level for efficient operation of the extraction system.
Therefore, reinjection is not a disposal technology, but a means
of improving the efficiency/rate of the cleanup process.
Alternative 7. This Alternative would be similar to Alternative
4, however, UV photolysis units would be added as a pre-treatment
.process on the six groundwater recovery wells prior to treatment
through the air-stripping towers. The UV systems would serve as
the pre-treatment step and the air-stripping towers would
constitute the polishing step. UV photolysis would serve to
"mineralize" VOCs to inorganic compounds, thus reducing the
quantities of hazardous substances which would require treatment
through the air-stripping towers. since the incoming
concentration of contaminants in groundwater feeding the air-
strippers would be effectively reduced, this Alternative would
14
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result in lower air emissions compared to other Alternatives.
The UV photolysis units are more expensive and require greater
operator attention than the carbon adsorption units: however,
they do not produce a residue (such as the contaminated activated
carbon) that must be managed as a hazardous waste and disposed of
off-site. .. .
Alternative 8. This Alternative would be identical to
Alternative 4, except that the groundwater removed from the
extraction wells would be used for non-contact cooling in various
industrial processes before passing through the air-stripping
towers. The efficiency of the air-stripping towers would be
improved since VOCs are more effectively removed from warm water.
In addition, since potable water is currently being used as the
sole source of process cooling water, aquifer draw-down would be
reduced. Further, by combining the groundwater recovery and.
process cooling water systems, greater emphasis would be placed
on maintaining the recovery systems. The systems would have to
include provisions for by-passing a portion of the groundwater
around the cooling water system to maintain an optimum thermal
balance in the plant. .
REMEDIAL ACTION ALTERNATIVES FOR SOILS
The FS identified nine (9) alternatives for soils (numbered 9-17
below) :
Alternative 9. This is the "no action" Alternative required by
the NCP. It is the baseline against which the effectiveness of
the other Alternatives will be judged. Under the no-action
Alternative, no funds would be expended for monitoring, control,
or remediation of the soil contamination.
Alternative 10. This is a limited-action Alternative which
consists primarily of institutional controls. It would include
land title covenants (deed restrictions) to warn future owners of
the property and to provide a means of controlling future
construction in areas that have been impacted by the
contamination. It would also include access restrictions to
reduce the likelihood of accidental exposure to soil containing
hazardous constituents, by both site personnel and trespassers.
These access restrictions would consist of warning signs and a
training program to educate site personnel of the risks and the
need to monitor sensitive areas. Finally, this Alternative would
include an asphalt cap to retard migration of the hazardous
constituents into the underlying groundwater, combined with
annual soil sampling and semi-annual groundwater monitoring to
document the effectiveness of the process. These measures are
designed to prevent human contact and to discourage migration
while the concentrations of VOCs are reduced by biodegradation.
Alternative 11. This Alternative would employ soil excavation to
reduce the concentrations of VOCs in the soil to below the
cleanup levels. The excavated soil would be managed as a RCRA
15
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hazardous waste, if necessary, and transported to a RCRA-
permitted treatment/disposal facility. No other soil measures
would be necessary, since the soil would have achieved all three'
Remedial Aqtion Objectives.
Alternative 12. In this Alternative, the soil would be
excavated, treated on-site, then returned to the excavation or to
a suitable borrow area. The treatment process would consist of
placing the soil in a pile and removing VOCs by aeration/soil
venting. -The institutional controls would be the same as
Alternative 10 and the excavated soils would have to be managed
as a RCRA hazardous waste until analysis verified that the
cleanup levels had been achieved.
Alternative 13., This Alternative would employ in-situ soil vapor
extraction to remove VOCs from the contaminated soil without,
excavation. The institutional controls would be the same as
Alternative 10 until soil monitoring revealed that the
performance criteria had been achieved. A pilot study would be
completed during the remedial design to determine the technical
feasibility of the SVE system, develop performance criteria and
provide information to expand the SVE system at the location of '
the pilot study area as well as to design systems at other source
areas.
Alternative 14. This Alternative would be similar to Alternative
12, e~ce~t that the"soil would be treat~d ex-situ by soil drying, ,
'then returned to the excavation.
Alternative 15. This Alternative would employ in-situ soil
stabilization to immobilize the VOCs. Although the process has
the potential to eliminate migration and to prevent direct
contact with the contaminants, the Alternative would include the
same institutional controls as Alternative 10 until soil
monitoring/sampling' revealed that the constituents had been
effectively immobilized.
Alternative 16. This Alternative would consist of a combination
of several other Alternatives, including institutional controls,
limited excavation, and ex-situ thermal drying. It would begin
with excavation of "hot spots" (i.e., soils in which the level of
contamination represents an excess cancer risk of 1in 10,000 or
greater). The VOCs would be removed from the excavated soil
using a mobile dryer, then the clean soil would be returned to
the excavation. Next, the area would be regraded and the storrn-
water system modified as necessary to redirect run-on and run-off
around the area of concern. Finally, the area would be capped
with asphalt. This Alternative would also include all of the
institutional controls described for Alternative 10.
Alternative 17. This Alternative would be the same as
Alternative 13, except that the vapors from the soil vapor
extraction system would pass through a carbon adsorption unit to ,
remove the VOCs. The spent activated carbon would be transported
as a hazardous waste to an off-site reprocessing or disposal
16
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facility, depending on economic considerations.
4.2
DETAILED EVALUATION OF REMEDIAL ALTERNATIVES
Groundwater alternatives:
The "No Action" alternative provides that the three existing
groundwater extraction wells and associated air-stripping
units would be removed from service. All other remedial
action alternatives considered for Strother Field include a
number of common components. Alternatives 3 - 8 provide a
similar approach to addressing groundwater remediation, with
Alternatives 4 - 8 similar in scope regarding groundwater
treatment. Alternatives 4 - 8 include continued operation
of the existing groundwater remediation system (with one.
extraction well slightly relocated) with the addition of
three additional extraction wells and accompanying air-
stripping units. The additional wells would provide further
groundwater containment and would expedite the eventual
restoration of groundwater to acceptable quality. The
systems would be similar in design to those currently
operating, which have demonstrated effectiveness.
Alternative 7 would include the addition of a UV photolysis
. pre-treatment component prior to the air-stripper units to
minimize air emissions. from the stripper units, if
necessary.. Alternative 5 includes .post-stripper granular
activated carbon treatment units to assure that treated
groundwater discharge would fall within the NPDES permitted
limits. The determination regarding the need for these pre-
and post-treatment systems would be based upon monitoring.
data collected from the existing systems during the design
of the additional systems.
Soil alternatives:
Alternatives 9 - 17 differ in their approach to soil
remediation. Alternative 9 is the statutorily mandated "no
action" alternative, used as the baseline for comparison.
Institutional controls, such as deed restrictions, along
with containment techniques (capping) would be utilized to .
prevent human exposures in Alternative 10. Alternatives 11,
12, and 14 would include the excavation of approximately
10,000 cubic yards of contaminated s011 near the Grief
Brothers facility. The means of disposal of the soils would
differ among the three Alternatives, with landfilling, soil
venting, and soil drying the respective treatment/disposal
options. Alternatives 13 and 15 would utilize in-situ
treatment methods to remove or immobilize volatile
contaminants in place. Alternative 13 would utilize SVE,
similar to the treatment method proposed in Alternative 12,
but would not require excavation to implement. Alternative
15 would leave contamination in-place, but would
solidify/stabilize the affected soils to restrict the
17
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potential for contaminant migration or release to the
environment. Elements from Alternatives 10 and 14 would be
combined to implement Alternative 16. Reduced soil volumes
would be excavated (approximately 1000 cubic yards near the
Grief Brothers facility) and subsequently treated through
thermal drying. Alternative 16 would add an asphalt cap
over the entire area where contaminated soils have been
detected at levels which may contribute to additional
groundwater contamination.
Attachments. XII, XIII and XIV summarize the evaluation of
the alternatives for groundwater, soil and their costs at
the Preliminary Screening stage, respectively. Capital
costs, operational costs, and maintenance costs were
evaluated for each remedial action alternative. A discount
factor of seven percent (7%) was used to calculate present
worth costs. . .
5.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
5.1
SUMMARY OF EPA EVALUATION. CRITERIA
The following section presents a summary of the criteria
that USEPA uses to evaluate remedial action alternatives.
.5.1.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT
Addresses whether a remedy provides adequate protection and
describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
5.1.2
COMPLIANCE WITH ARARs
Adqresses wh~ther a remedy will meet all .of the applic~ble
or relevant and appropriate requirements of Federal and
State environmental statutes and regulations and/or provides
grounds for invoking a waiver.
5.1.3 LONG-TERM EFFECTIVENESS AND PERMANENCE
Refers to the
-------
and any adverse impacts on human health and the environment
that may be posed during the construction and implementation
period until cleanup goals are achieved.
5.1.6
IMPLEMENTABILITY
Refers to the technical and administrative feasibility of a
remedy, including the availability of materials and services
needed to implement a particular option.
5.1.7
COST
Evaluates the estimated capital cost, operation and
maintenance costs, and net present worth costs.
5.1.8
STATE AND SUPPORT AGENCY ACCEPTANCE
Discusses whether, based on their review of the RIfFS and
Proposed Plan, the agencies concur with, oppose, or have ,no
comment on the preferred alternative at' the present time.
5.1.9
COMMUNITY ACCEPTANCE
This criteria is assessed in the Record of Decision
following a review of'the public comments received on the RI
and FS reports, the administrative record, and the ,Proposed
Plan. It is embodied in the Responsiveness Summary attached
hereto.
5.2
EVALUATION OF THE ALTERNATIVES
This section profiles the performance of the preferred
alternative against the nine criteria, noting how it
compares to the other options under consideration. The
tables'included (Attachments X, XI, XII, XIII)' summarize the
'screening information of the various remedial action
alternatives for both groundwater and soil.
5.2.1
OVERALL PROTECTION
.
The preferred alternatives for groundwater and soil
media provide suitable protection of human health and
the environment by eliminating, reducing, and
controlling risk through treatme~t, engineering
controls, and institutional controls. The preferred
alternative for groundwater, Alternative 4 provides
hydraulic control to minimize the possible migration of
VOC contaminants and utilizes treatment to remediate
groundwater to acceptable quality. The preferred soils
alternative, Alternative 13, with the contingency of
Alternative 14, would serve to reduce the risk of
further migration of soil contaminants into groundwater
through treatment (in-situ SVE, or the contingent,
excavation, treatment and capping). Implementation of
19
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,
the soils alternative is dependent, as noted
6, upon the succ~ssful completion of a pilot
demonstrate the technical feasibility of the
to remove VOCs from site soils. The overall
concentration of.VOCs in the soil and groundwater at
the site would decrease over time with implementation
of the preferred alternative.
in section
study to
SVE system
Groundwater Alternative 3 is not comparable in scope to
-the other groundwater alternatives, and would.offer
less protection from possible off-site contaminant
migration. Groundwater Alternatives 5 - 8 offer
equivalent protection of human health and the
environment as the preferred alternative. Alternatives
5 and 7 may offer additional risk reduction based on
reduced VOC discharge levels (Alternative 5) or reduced
air emissions (Alternative 7). Additional data
gathering is planned to evaluate potential incremental
risk reduction which may accrue as a result of
implementation of the additional treatment options
offered by Alternatives 5 and 7. If significant risk
reduction is noted as a result of this analysis, these
Alternatives may be implemented, as appropriate, as
part of the preferred alternative for groundwater.
Soil Remedial Alternatives 11 - 15 offer equivalent
protection of human health and the environment.
However, the primary factor requiring solI remediation
was based on the preference to reduce the toxicity,
mobility, and the volume of contaminants at the site,
thereby minimizing the possibility of future releases
to groundwater and expediting the overall groundwater
cleanup.
Alternatives 1 and "9, the "no action" alternatives do
not meet the criteria for protection of human health
and the environment.. The institutional controls
alternatives may be useful in tandem with other.
alternatives, but alone are not sufficiently protective
of human health and the environment.
5.2.2
COMPLIANCE WITH ARARs
Applicable or Relevant and Appropriate Requirements
(ARARs) are defined as clean-up standards, standards of
control, or other environmental protection standards
that are used to address problems or situations at a
contaminated site. ARARs are classified within three
categories: 1) Chemical Specific Requirements - health
or risk based numerical values, which represent an
acceptable concentration in the media of concern in the
absence of consideration of site-specific exposure
conditions: 2) Location-Specific Requirements -
limitations on allowable concentrations of hazardous
20
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substances due to impacts in special locations, such as
critical habitats; and 3) Performance, Design, or
other Action-Specific Requirements - technology based
requirements or limitations or actions taken with
respect to hazardous wastes.
Primary ARARs considered for the Strother Field site
include:
1) Maximum Contaminant Levels (MCLs)
under the Safe Drinking Water Act are
appropriate standards .for remediation
groundwater (Chemical-Specific).
2) Effluent limitation guidelines as governed by the
Clean Water Act through the National Pollutant
Discharge Elimination System (NPDES) are ARARs for any
discharge resulting from site remediation, such as pump
and treat (Chemical-Specific).
as promulgated
the relevant and
of contaminated
3) No specific ARARs exist for contaminated soils at .
Strother Field, therefore, additional guidelines will
be evaluated. Risk-based remediation goals for soils
have been established to determine if any significant
exposures to surficial soils may be occurring.
. Analyses indicate that no significant threat is posed
by VOC levels found in surface soil samples which are
likely exposure routes. Performance standards will be
developed during the pilot study of the SVE system of
the remedial design of the preferred alternative.
These performance standards will be established to
prevent further degradation of the groundwater. In the
event that the contingent alternative for the soils is
implemented, performance standards will be developed
for the treatment of excavated soils and the risk-based
remediation goals for' s,oils will be used for those
soils at the surface after the placement of treated.
soils. '
There are no location or action specific ARARS.
The "no-action" alternatives for both soil and
groundwater would not satisfy ARARs, nor would the
institutional controls alternatives, without additional
measures or combinations of al terna'tives. The
remaining alternatives would meeT. their respective
ARARs.
5.2.3
LONG TERM EFFECTIVENESS AND PERMANENCE
Groundwater Alternatives 4 - 8 would actively remove
VOCs from known contaminant plumes. Gro~ndwater
modeling indicates that each of these alternatives
would be able to reach remediation goals for site
groundwater in an acceptable time frame (10 - 15 years)
21
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and would yield a permanent, non-reversible cleanup.
Alternative 3 provides fewer groundwater recovery wells
(three wells - Alternative 3; six wells - Alternatives
4-8), and therefore would not be comparable in scope to
the other alternatives. Consequently, Alternative 3
may not be capable of achieving groundwater remediation
goals for all areas of the site.
soil Alternatives 11, 12, and 14 would reduce
. contaminant levels in source areas to comparable levels
which would meet remediation goals. The preferred
alternative, Alternative 13, would require pilot scale
testing to validate its effectiveness. It is
anticipated that the preferred alternative would be
equally effective in reducing VOC levels at the site,
assuming appropriate system design feat~res are
incorporated following the pilot study. Alternatives
10 and 15 would not remove contamination from the
source areas. The asphalt cap proposed in Alternative
10 may present long-term maintenance problems, should
other actions not be taken in tandem to reduce soil
contaminant levels. Similar problems may result from
the soil stabilization associated with Alternative 15.
Alternatives 10 and 15 are not viewed as sufficiently
permanent, stand-alone alternatives in comparison to
the other options.
5.2.4
REDUCTION IN TOXICITY, MOBILITY, AND VOLUME
All of the action alternatives proposed for groundwater
remediation, Alternatives 3 ~ 8, would permanently
remove contaminants from the groundwater, thereby
reducing the volume of contaminants in the aquifer. In
addition, the mobility of the contaminants in the
groundwat~r would also be influenced through hydraulic
control. Alternative 3 would not offer equivalent
reduction in volume compared to the other groundwater
action alternatives, since less comprehensive
groundwater treatment would be provided. Alternatives
5 and 7 may offer additional reductions in toxicity and
volume of contaminants contained in effluent and
exhaust discharges. Health risks associated with these
discharges will be evaluated during the design phase of
the preferred alternative to determine if the
additional costs associated with Alternatives 5 and 7
are justifiable based upon commensurate reduction of
risk.
Soil Remedial Alternatives would offer varying degrees
of reduction in toxicity, mobility, and volume of site
contaminants. The excavation alternatives
(Alternatives 11, 12, and 14) would offer more complete
treatment of soils, however, from a more limited area
22
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than that proposed in the preferred alternative. It is
felt that the preferred alternative offers the most
significant reduction of contaminants from active
source areas which have the potential to continue to
impact groundwater at the site.
The preferred alternative, the combination of
Alternative 4 for groundwater and Alternative 13 for
soil, provides for a reduction of contaminants from the
. soil and groundwater through treatment and recovery
(volume), provides control of the migration of
contaminants from the site (mobility), and treats
. contaminated groundwater and soil to acceptable levels
as determined by USEPA and KDHE (toxicity). Reduction
of VOC contaminants in the soil (volume and mobility)
greatly incr~ases the overall efficiency of the cleanup
by decreasing the time needed to achieve groundwater
remediation. .
23
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5.2.5
SHORT TERM EFFECTIVENESS
As discussed previously, an interim remedial system
consisting of three groundwater extraction and air-
stripping systems is presently in operation at Strother
Field. Minimal risks to the community and on-site
workers were observed during construction and
implementation of the interim system. Therefore, since
the preferred groundwater alternative is an expansion
. of the interim system, minimal risk is expected.
The additional treatment options associated with
Groundwater Alternatives 5 - 8 should pose no
additional risks during' implementation relative to the
preferred alternative. Alternative 8 may increase the
possibility. of exposures to groundwater during the'
operational lifetime, due to the presence of
contaminated groundwater in process equipment in
various facilities at the site, and the potential for
failures within these systems.
Soil Remedial Alternatives 11, 12, and 14 - 16 would
pose potential exposure risks during the soil
excavation associated with each alternative. The
preferred soil alternative, Alternative 13, would
require less intrusive activity into contaminated. soils
relative to the. excavation options. The risks
associated with implementation of the preferred
alternatives appears to be manageable, assuming that
appropriately trained personnel and operating
procedures are utilized during construction.
5.2.6
IMPLEMENTABILITY
Few administrative difficulties are anticipated which
would delay implementation of any of the proposed
Groundwater.Remedial Alternatives, including the
preferred alternative. The Groundwater Alternatives
contain a common element, the continued utilization of
the existing groundwater recovery and treatment system.
No problems are anticipated with the continued
operation of this system, or the addition of similar
systems at other locations on the site to enhance
overall groundwater treatment and recovery. The
additional groundwater treatment options provided in
Alternatives 5 and 7 are rather straightforward, proven
technologies and would require only minor modifications
to the existing systems and those additional systems
offered by the preferred alternative. No problems are
envisioned with implementation of the enhanced
groundwater alternatives, if risk analysis indicates
that they are necessary, since these technologies have
been used extensively. Skilled workers needed to
construct the enhanced groundwater recovery and
treatment system are available in this area. All
24
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permits for such systems are in place and regulated by
KDHE. Operating personnel are familiar with this type
of groundwater treatment system since they have been in
operation at the site for several years.
A pilot study is required to implement the preferred
alternative, SVE, for soil remediation. This is a
proven technology for remediation of VOCs in soils.
The pilot study is proposed to assist in providing
'appropriate data for system design, pertinent to soil
conditions at the site. Each of the potential soil
Remedial Alternatives may encounter technical'
difficulties due to the proximity of source areas in
relation to on-site buildings and operations. This
problem most seriously impacts the excavation
alternatives, due to potential structural problems
associated with extensive excavation near buildings.
5.2.7
COST
Attachment XIV includes a summary of present worth
costs for each alternative evaluated in this Proposed
Plan during the Preliminary Alternative Screening stage
in the FS. This was used to compare costs among the
Alternatives at that stage of the FS. The Alternatives
were then analyzed in greater detail and refinements in
duration, capital costs, annual O&M costs and present
worth costs were made.
Groundwater:
The range for Preliminary Screening of estimated
capital cost was from $0 for Alternative I to
$1,222,000 for Alternative 6. The preferred
Alternative 4 had an estimated capital cost of
$312,000. As refined the estimated capital cost of
Alternative 4 is $541,600. '
The range for Preliminary Screening of estimated annual
operation and maintenance (O&M) costs was from $0 for
Alternative 1 to $440,000 for Alternative 7. The
preferred Alternative 4 had an estimated annual
operation and maintenance (O&M) cost of $220,000. As
refined the estimated annual O&M cost of Alternative 4
is $280,000. .
The range for Preliminary Screening of estimated
present worth costs was from $0 for Alternative 1 to
$5,777,426 for Alternative 6. The preferred
Alternative 4 had an estimated present worth of '
$2,642,683. As refined the estimated present worth of
Alternative 4 is $3,511,000.
2S
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Soil:
The range for Preliminary Screening of estimated
capital cost was from $0 for Alternative 9 to
$1,430,000 for Alternative 11. The preferred
Alternative 13 had an estimated capital cost of
$850,200. As refined the estimated capital cost of
Alternative 13 is $541,600.
.The range for Preliminary Screening of estimated annual
operation and maintenance (O&M) costs was from $0 for
Alternative 9 to $166,100 for Alternative 17. The
-preferred Alternative 13 had an estimated annual
operation and maintenance (O&M) cost of 53,100. As
refined the .estimated annual O&M cost is $180,000.
The range for preliminary Screening of estimated
present worth costs was from $0 for Alternative 9 to
$2,051,242 for Alternative 17. The preferred Alter-
native 13 had an estimated present worth of $1,067,920.
As refined the estimated present worth is $3,207,000.
The present worth of the Pilot Study is $60,000.
5.2..8
STATE AND SUPPORT AGENCY ACCEPTANCE
Both the Kansas Department of Heaith and Environment
and the u.S. Environmental Protection Agency support
the preferred alternative.
5.2.9
COMMUNITY ACCEPTANCE
Comments were received during the comment period and
reviewed. Summaries of those comments and EPA's
responses are in Section 8.0.
6.0
SELECTED .REMEDY
The selected remedy includes both cleanup of the groundwater
plumes and a sequence by which the cleanup of the contaminated
soils can be determined during the Remedial Design.
Groundwater:
Alternative 4. This alternative will emphasize the cleanup
of the groundwater by extracting groundwater from the zone of
highest VOC concentration within the four plume areas - no
actions are planned at this point for the fifth plume area, the
Hackney area plume, which is not considered a part of the
Strother Field site. However, monitoring will continue to
determine if the existing recovery system is affecting the
movement of that fifth plume area. Existing recovery well REM-1
would be moved to the location of monitoring well DM-15.
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Monitoring wells DM-l4, DM-5 and GGP-2 would be converted to
recovery wells. Recovery wells SFW-2 and SFW-8 would continue to
operate primarily to prevent off-site migration, although they
would also continue to remove contaminants in the process. In
'addition, 'the contaminated groundwater recovered from wells DM-15
(using the existing "REM-l" tower), SFW-2and SFW-8 would
continue to be processed through the existing air-stripping
towers and the treated effluent would continue to be discharged
to Posey Creek (through the POTW in the case of DM-15) in
accordance with existing discharge permits. For Alternative 4,
the VOC's in the water recovered from wells DM-14, DM-5 and GGP-2
would be removed through the use of dedicated air-stripping
towers located in the vicinity of each well. Effluent from
towers would be discharged to Posey Creek and would require
discharge perm,its. The towers would be designed to achieve
effluent quality that is consistent with the current state
standards for discharges from SFW-2 and SFW-8 to Posey Creek.
Institutional controls will include land title covenants (deed
restrictions) to prevent future use of contaminated groundwater
for human consumption on those properties under which the
groundwater is contaminated. These covenants would preclude the
construction of new potable water supply wells and the conversion
of existing wells for use as potable water supplies in areas that
are or may be impacted by the groundwater contamination.
the
state
an
In addition to Alternative 4, an air sampling program will,
be implemented during the Remedial Design to determine the levels
. of contaminants in the exhaust vapors being discharged from one
of the new air-strippers. A health based evaluation of the data
will be made to determine if additional treatment is necessary to
minimize emissions from the air-strippers. Additionally,
analysis of effluent data will be performed to determine if
further treatment, such as activated carbon, is necessary to meet
discharge require~~nts.
soil:
Alternative 13. Alternative 13 would employ in-situ soil
vapor extraction to remove VOCs from the contaminated soils at
the northeast and northwest corners of the Grief Brothers
facility and at Building 5 of General Electric. A "Pilot study"
during the Remedial Design is needed to evaluate whether
Alternative 13 can be implemented for remediation of soils to
reduce the overall toxicity, volume, and mobility of on-site
contaminants. This treatment and reduction of the contamination
would reduce the potential for additional contaminant migration
into groundwater. The pilot study will be completed at the
northeast corner of the Grief Brothers facility. The pilot study
will determine the technical feasibility of the SVE system,
develop performance criteria and provide design information to
expand the SVE system at that location and to design systems at
both the other source areas. The pilot study will include
monitoring of exhaust vapors from the SVE system for a health
based evaluation of the contaminants to determine if treatment of
27
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the emissions from the system is necessary.
In the contingency that the pilot study determines that the
SVE system may not be technically feasible, Alternative 14 will
be implemented. Alternative 14 proposes excavation of the
contaminated soils in the area of the northeast and northwest
corners of the Grief Brothers facility, treating the soil by soil
drying, and placing the treated soil back into the excavation in
controlled lifts. The areas at the northeast and northwest
corners of the Grief Brothers facility that overlie the
contaminated soil that cannot be excavated due to interference
with structures, etc., will then be capped with asphaltic
concrete to prevent direct infiltration by percolation of water
from precipitation and surface runoff.
Estimation of Costs:
The following capital and operation and maintenance costs were ,-
obtained from Appendix D (Attachment XV) of the Feasibility
study. Appendix D has been attached since the proposed
alternative has used separate components in assessing costs
associated with the groundwater remediation plan and the soil
remediation plan. The present worth calculations were completed
by using the BEN computer model as directed by EPA Guidance. The
model assumptions included a discount rate of 7%, a start date of
December of 1994 and an annual inflation rate of 1.3% for
comparative p~rposes.
Groundwater:
Alternative 4:
Capital:
o & M:
Pre$ent Worth:
Implementation
Time:
$ 541,000
$ 280,000
$3,511,000
10 years
Note:
Additional costs may be incurred if treatment of
exhaust vapors from the air-strippers is required.
Costs for the monitoring, signs & alarms and land &
title covenants are included for both groundwater
and soil alternatives since they are consistent
independent of which soil alternative is used.
Soils:
Pilot study:
$60,000
Alternative 13:
Capital:
o & M:
Present Worth:
Implementation
Time:
$1,380,000
$ 180,000
, $3,207,000
2 years
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Note:
pilot Study cost estimates are based on a recent study
at similar site. Additional costs may be incurred if
treatment of exhaust vapors is required.
In the contingency that the Pilot Study determines that the SVE
system is not technically feasible:
Alternatiye 14:
Present Worth (soil
excavation)
Capital (Asphalt cap):
O&M (Asphalt cap):
Present Worth (Asphalt
Implementation Time of
Total (soil excavation
plus asphalt cap)
cap) :
cap:
$1,200,000
$ 51,000
$ 13,000
$ 180,700
10 years
$1,380,000
7.0
STATUTORY DETERMINATIONS
Under its legal authorities, the Environmental Protection
Agency's primary responsibility at Superfund sites is to
undertake remedial actions that achieve protection of human
health and the environment. In addition, section 121 of CERCLA
establishes severa~ other statutory requirements and preferences.
These specify that when complete, the selected remedial action
for this site must comply with applicable or relevant and
appropriate environmental laws unless a statutory waiver is
justified. The selected remedy also must be cost effective and
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to .the maximum.
extent practicable. Finally, the statute includes a preference
for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity or mobility of
hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory
~equirements. .
1.
Protection of Human Health and the Environment
The selected remedies for groundwater and soil media provide
suitable protection of human health and the environment by
eliminating, reducing, and controlling risk through treatment,
engineering controls, and institutional controls. The selected
remedy for groundwater, Alternative 4 provides hydraulic control
to minimize the possible migration of VOC contaminants and
utilizes treatment to remediate groundwater to acceptable
quality. The selected remedy for soils, Alternative 13, with the
contingency of Alternative 14, would serve to reduce the risk of
further migration of soil contaminants into groundwater through
treatment (in-situ SVE, or the contingent, excavation, treatment
and capping). Implementation of the soils alternative 13 is
dependent, as noted in section 6, upon the successful completion
of a pilot study to demonstrate the technical feasibility of the
SVE system to remove VOCs from site soils. The overall
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concentration of VOCs in the soil and groundwater at the site
would decrease over time with implementation of the selected
remedy.
2. Compliance with Applicable or Relevant and Appropriate
Requirements
The Applicable or Relevant and Appropriate Requirements
(ARARs) are defined as clean-up standards, standards of control,
or other environmental protection standards that are used to
address problems or situations at a contaminated site. ARARs are
classified within three categories: 1) Chemical Specific
Requirements - health or risk based numerical values, which
represent an acceptable concentration in the media of concern in
the absence of consideration of site-specific exposure
conditions; 2) Location-Specific Requirements - limitations on
allowable concentrations of hazardous substances due to impacts
in special locations, such as critical habitats; and 3)
Performance, Design, or Other Action-Specific Requirements -
technology based requirements or limitations or actions taken
with respect to hazardous wastes.
Primary ARARs considered for the Strother Field site
include:
A) Maximum contaminant Levels (MCLs) as promulgated under
.the Safe Drinking Water Act are the relevant and appropriate
standards for remediation of contaminated groundwater.
Attachment IX displays the ARARs for the groundwater at the
site. For compounds without a MCL, proposed MCL or state
ground water standard, a risk based cleanup level
corresponding to an excess lifetime cancer risk of 1 x 10(-
6) will be calculated using slope factors for carcinogens
(Chemical-Specific) .
B) Effluent limitation guidelines as governed by the Clean
Water Act through the National Pollutant Discharge. .
Elimination System (NPDES) are ARARs for any discharge
resulting from site remediation, such as pump and treat
(Chemical-Specific).
C) No specific ARARs exist for contaminated soils at
Strother Field, therefore, additional guidelines will be
evaluated. Risk-based target levels for remediation goals
for soils have been established (Attachment IX) to determine
if any significant exposures to surficial soils may be
occurring. Analyses indicate that no significant threat is
posed by VOC levels found in surface soil samples which are
likely exposure routes. Performance standards will be
developed during the pilot study of the SVE system of the
remedial design of the preferred alternative. These
performance standards will be established to prevent further
degradation of the groundwater. In the event that the
contingent alternative for the soils is implemented,
performance standards will be developed for the treatment of
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excavated soils and the risk-based remediation goals for
soils will be used for those soi1s at the surface after the
placement of treated soils.
There were no location or action specific ARARs.
3.
Cost Effectiveness
The selected remedy for both ground water and soils provides
the best balance among the evaluation criteria. It provides a
higher degree of overall protection th~n the less costly
alternatives by treating known source areas and preventing the
migration of contaminated ground water from the area.
4. utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
.Extent Practicable. .
EPA has determined that the selected remedy for both ground
water and soils represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost
effective manner for the site. Of those alternatives that are
protective of human health and the environment and comply with
applicable standards, EPA has determined that this selected
remedy provides the best balance of trade-offs in terms of long-
term effectiveness and permanence, reduction in toxicity,
mobility, or volume achieved through treatment, short-term
effectiveness, implementability,.cost, while also considering the
statutory preference for treatment as a principal element and
considering state and community input.
5.
Preference for Treatment as a principal Element
The selected remedy uses technology for ground water
treatment and active soil vapor extraction for source control and
thus satisfies the statutory preference for remedies that employ
treatment of the principal threat which permanently and'
significantly reducess the toxicity, mobility, or volume of
hazardous substances as a principal element.
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8.0
RESPONSIVENESS SUMMARY
8.1
overview
In the proposed plan released for public comment, EPA and
KDHE presented a preferred alternative which 'set forth the
proposed final remedy for the ground water contamination and the
soils contamination (which includes a contigency for an alternate
remedy) a~ the Strother Field Industrial Park Superfund site.
After receiving pUblic comments on the preferred
alternative, EPA has selected the alternative set forth in this
Record of Decision (ROD).
8.2
Summary of comments received during Public Comment Period
Comments received during the' public comment period from
November 19, 1993 through January 21, 1994 are summarized below
with the EPA response for each.
A. The following comments were received from Mr. David Tripp of
the law firm of Stinson, Mag & Fizzell, on behalf of the Strother
Field Commission at the Public Hearing on December 14, 1993. A
written comment letter was received from Mr. Mark Krusorof the
law firm of Mathews, Taylor & Krusor, on behalf of Energy Plus,
,Inc., d/b/a Strother Manufacturing Company dated January 3, 1994'.
Energy Plus, Inc. stated they wished 'to incorporate by reference
the comments of the Strother Field Commission on EPA's "Proposed
Plan for Strother Field Industrial Park Superfund Site,"
submitted at the public hearing on December 14, 1993, at Strother
Field.
1. Strother Field Commission and Energy Plus, Inc.
submitted three general comments: the first relating to title
history of the site; the second relating to the status of the
municipality under the Superfund; the third relating to the
preferred alternatives addressed by EPA in its proposed plan.
Only the third comment will be addressed since the purpose of the
comment period is to record, review and consider comments on the
poroposed action that EPA intends to take at the site. The other
comments relate to the potential liability of parties and is not
relevant to EPA's selection of a remedy that is protective of
human health and the environment and pursuant to the NCP and
CERCLA. The comments on the proposed action can be briefly
summarized into four sections and will be responded to below:
a. The Strother Field Commission and Energy Plus,
Inc. are of the opinion that the hypothetical scenarios
and risk models as considered in the baseline risk
assessment do not reflect the actual health risks at
the site. They state that the hypothetical ingestion
of ground water and contaminated soils by persons
living and working in the vicinity of the site do not
exist at the site. They state that none of the
tenants, employees, visitors or guests to Strother
32
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Field are exposed to drinking water contaminated by
elevated levels of VOC's. They also state that EPA
appears to assume that visitors or workers may breathe
vapors or ingest soil particles at limited locations
within the Strother Field site.
EPA Response: The objectives of the Baseline Risk
Assessment (BLRA) that was completed during the
Remedial Investigation (RI) were to assess the
- magnitude and potential of actual or potential harm to
pUblic health and the environment resulting £rom the
release of hazardous substances from the site in the
absence of remedial action (i.e. the "no-action"
alternative}. The BLRA focused on potential or actual
risks to human health posed by contaminants at, or
released from Strother Field. As stated in the RI
report, section 5.1, paragraph #3 - "...the risk
assessment is intended primarily to be used as a guide
in determining the need for, and selecting remedial
alternatives and not as a comprehensive scientific
estimation of actual risk."
The BLRA indicates that the greatest risk to human
health could occur from future ingestion of
contaminated ground water. The primary route of
exposure would be through domestic use of w~ter from
existing or new water wells. The point of ingestion-
may be either at, or downgradient, of Strother Field
Industrial Park. The affected aquifer is the principal
drinking water aquifer in the area. The Strother Field
Commission relocated its water supply wells to
upgradient areas in the 1980's after KDHE discovered
the elevated levels of volatile organic contaminants
(VOC's) in the drinking water. Ground water is
extracted from the same aquifer immediately
downgradient from the Strother Field Industrial Park
for drinking purposes for both water district and
private well users. The conclusions of the BLRA and
the direct threat to ground water users directly
downgradient of the contamination support the need for
remedial action as described in the selected remedy.
The Feasibility Study (FS) further examined the
threat posed by contaminated soils at the site and
determined that although there does not appear to be a
direct threat to human health from exposure at the
surface, the levels at depth will continue to be a
source of contamination by continuing to leach
contaminants to the ground water in the three areas
mentioned and that some action was needed to reduce
contaminant toxicity, mobility and volume. The
treatment and reduction of contamination in the soils
will tend to reduce the length of time necessary to
remediate the ground water.
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b. The Strother Field Commission and Energy Plus,
Inc. are of the opinion that the costs associated with
the preferred alternatives are excessive in response to
the identified problems. They stated that EPA could
have selected more limited response actions, achieved
virtually equivalent environmental results at
substantially lower costs.
EPA Response: EPA uses the following criteria to
, evaluate remedial action alternatives: Overall
protection of human health and the environment:
Compliance with ARARs: Long-term effectiveness and
permanence: Reduction of toxicity, mobility, or volume;
Short-term effectiveness; Implementability; Cost; state
and support agency acceptance; and community
acceptance. section 6.2 of the Proposed Plan for the
Strother Field Industrial Park Superfund site profiles
the performance of th~ preferred alternative against
eight of the nine criteria. The selected remedy as
described in this Record of Decision (ROD) was '
determined after reviewing the comments submitted to
the EPA on the Proposed Plan during the comment period.
The EPA determined that the selected ground water
remedy was the most protective of human health and
environment based on all the above listed criteria, not
just on cost. The EPA determined that the selected
soils remedy was the most effective method to'reduce
the toxicity, mobility and volume of the contamination
as well as to aid in reducing the time necessary to
clean up the ground water.
c. The Strother Field Commission and Energy Plus,
Inc. is of the opinion the Proposed Plan is not as good
as it could be due to lack of technical support to the
parties by EPA. They state that the traditional pump
and treat technology that is being proposed to contain
and treat the ground water at the site has been found
to be ineffective, and therefore more expensive, to
clean up contaminated aquifers to achieve the ARARs
(maximum contaminant levels (MCLs) per the Safe
Drinking Water Act (SWDA). They propose that a
consortium of universities (such as Kansas State
University), engineering firms, state agencies and EPA
be formed to review proposed alternatives (to derive
alternatives to currently applied treatment
technologies), review the findings of the baseline risk
assessment and the cost effectiveness of the proposed
system in order to determine whether, a different result
could be reached. They suggest that this review be
limited to a discrete time period and involve several
meetings among all parties that are practically
available.
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EPA Response: The RI and FS were completed under a
state administrative order with both KDHE and EPA
reviewing the ongoing work. Access to published
documents concerning clean up technologies were
available during the work through government, industry
and private publications. The references cited in both
RI and FS documents indicate that the contractor
reviewed available literature. Both EPA and KDHE are
of the opinion that the contractor made an adequate
. attempt at resea~ching existing and developing
technologies during the review of workplans, reports
and technical discussions. EPA has made the.
determination that the selected remedial action is
necessary to contain and treat the contamination of the
drinking water aquifer with the best available
technology at this time. The pump and treat technology
has been proven effective at the site after reviewing
performance of existing systems. Time is of the
essence to implement the selected remedy since it has
been determined that the current system needs to be
adjusted and an additional extraction well is needed at
the southern end of the Industrial Park. The Rural
Water District wells and other private wells that are
immediately downgradient of the site would be adversely
effected if the existing system would fail to contain
the entire plume of contamination. The soil vapor
extraction (SVE) technology selected to address the
three source areas has been used extensively and is
considered to be a proven technology in reducing the
amount of contamination in the soil so that it does not
leach into the ground water. The selected remedy has
provided for a full scale pilot study in one of the
source areas to ensure the effectiveness of the
technology and to provide performance data and design
information for the expansion of the SVE at that
location as well as' the two other source areas. In the
event. that the SVE Pilot study provides information
that the technology may not be technically feasible or
provide inadequate performance results, a different
response action has been provided for.
It is expected that the Remedial Design (RD) and
Remedial Action (RA) will be completed under a Consent
Decree (CD) between the EPA and .the Potentially
Responsible Parties (PRPs). It will provide for review
and oversight of all work to ensure that the
implementation of the selected remedy is completed
according to the approved workplans in addition to
providing for a review of the remediation systems in 5
years.
d. The Strother Field Commission and Energy Plus,
Inc. state that the limited action alternatives
identified in the proposed plan are more consistent
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with the goals of the Superfund. They ask that EPA
reconsider the available alternatives and select the
alternative that would allow the existing pump and
treat system to operate and thus allow time for new or
emerging technologies to be identified should
additional response actions be warranted at the site.
They state that this would be most applicable to the
site since there is no immediate threat to human health
or the environment.
EPA Response: .The EPA has responded to this comment in
detail in the above sections of the Record of Decision
(ROD) and in the responses to comments A, Band C
above. Due to the potential risk posed to users of the
ground water immediately downgradient of the site
resulting' from the contaminated ground water and the
continued leaching of contamination from the soils to
the ground water at the site, EPA has made the
determination that the selected remedy as described in
section 6.0 in this ROD is necessary to protect human
health and environment at the Strother Field Industrial
Park Superfund Site.
B. The following comments were received from Mr. James H.
Andreasen of the law firm of Spencer Fane Britt & Browne, on
behalf of General Electric Aircraft Engine Maintenance Center
(GE-AEMC), in a letter dated January 17, 1994. The GE-AEMC
letter commented on the statements that the Strother Field
Commission made concerning site history and the position of the
Commission's liability under CERCLA. The GE-AEMC also stated
"While GE-AEMC might not have made all the same choices that EPA
did, GE-AEMC believes the proposed remedy is appropriate and
consistent with the National Contingency Plan.". The GE-AEMC
also stated that the Strother Field Commission's comment
requesting a joint agency/academic consortium may have been
appropriate at an, earlier stage in' the project' but they do not
support that request at this time since it would delay the
cleanup of the property.
EPA Response: The above comments from GE-AEMC are supportive of
the Proposed Plan and thus of the Selected Remedy as described
above.
C. The following comments were received from Mr. Paul S.
McCausland of the law firm of Young, Bogle, McCausland, Wells &
Clark, on behalf of the Greif Brothers Corporation, in a letter
dated January 19, 1994. The Greif Brothers corporation (Greif)
stated that they were not satisfied with the limited scope of the
RI, the inaccuracy of the computer model cost estimates and EPA's
proposal of an unstudied remedy. Greif engaged Allied
Environmental Consultants (AEC) to complete an investigation of
the source areas at their facility. The report "Environmental
Site Investigation: Greif Brothers Strother Field Facility;
36
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Winfield, Kansas" was enclosed with the letter. The two major
areas of disagreement and comments will be described and
responded to below:
1. Greif stated that the AEC report provided a realistic
appraisal of the nature and extent of the soil contamination
and rejects the use of Soil Vapor Extraction (SVE) because
of tQe physical characteristics of the soil and contaminants
are not conducive to that technology. They recommend that
the removal by excavation of the contaminated soil at the
northwest and northeast corners of their building and
treating it will be more acceptable and already has been
acknowledged to be acceptable by Donley and the EPA.
EPA Response: EPA has reviewed the report submitted by
Greif and completed by AEC. The EPA Region VII Quality
Assurance Management Office reviewed the data contained in
the AEC Report. Since only data summaries were included a
complete review of data quality could not be made. A total
of twenty soil borings (16 outside and 4 inside the Greif
Brothers, Inc. plant) were drilled and two monitoring wells
were installed. The geology of the site on page 7 describes
the upper soils as dense, fat. highly plastic clays, which
remain very consistent throughout the investigation area.
The cross sections in Appendix B refer to the same soils as .
silty .low plasticity clays. The.boring logs. in Appendix.C
refer to the same soils as silty clay, stiff, moist with
caliche. Appendix F presents a summary table for the two
soil samples, BH615 and BH620, that were tested for certain
properties in the geotechnical laboratory.
There are discrepancies in the description of the same soil
lithologic unit as described above. The description of the
soil as to its plasticity is normally confirmed by a
laboratory test called Atterberg Limits (ASTM D4318). That
test, along with field determinations of an experienced
geotechnical technician logging the materials according to.
their engineering characteristics, can produce an accurate
determination of the soil lithologic unit. Only two samples
were tested in the geotechnical laboratory out of the 20
borings completed during the investigation. The
permeability test referenced was an in-liner falling head
permeabilty test. .That laboratory test is normally run on
pervious soils since a relatively higher permeability is
required to obtain good precision. One of the objectives c.f
the investigation was to determine the charateristics and.
suitability of the soils for a Soil Vapor Extraction (SVE)
remediation system to be considered. The boring logs
indicate caliche seams, increasing with depth. This
indicates movement of water in the capillary zone above the
water table. A laboratory permeability test such as the
falling head permeability test does not give a good
indication of the insitu (in place) permeability of the soil
strata. A few constant head field permeability tests (as
37
-------
referenced in Bulletin No. 36 of the waterways Experiment
Station, Corps of Engineers) would have given a more
accurate range of field permeability values. Soil structure
(both in the micro and macro structure of the soil) is
extremely important in determining the field permeability of
a soil unit and in determining if SVE can be applied. The
borings did show the contamination at depth, indicating that
the soil litholoqic unit permeability would be greater than
the laboratory value since the contamination had been
transported downward through the soil column by some
leaching mechanism or combination of mechanisms.
The AEC report shows that the contamination of the soils
above the preliminary remediation goals (PRGs) at the
northwest and northeast corners of the Greif Bros. main
building are at depth and are very close to the building'
structure. Excavation to the depths required to remove the
contaminated soil would probably require'considerable
shoring and underpinning of the building foundation, which
would have to be designed by a structural and geotechnical
engineer. There will need to be additional investigation
during the remedial design to characterize the areal extent
of the contamination.
EPA has determined that the AEC report submitted with
Greif's ,comments does not provide the information needed'to
chang,e the selected remedy concerning the contaminated soil's
at the Strother Field Industrial Park 'Superfund site. Field
testing to determine the insitu permeability of the upper
soil lithologic unit and additional laboratory tests to
determine the material classification of the soil unit would
have been helpful in the assessment of the remediation
determination and design of the Pilot SVE system. The
isoconcentration maps of the PCE and Toluene contamination
in Figures 7 and 9, respectively, support the proposed use
of SVE to extract as much contamination as possible since
the areas of highest'concentrations appear to be at the
building perimeter and to extend under the building
structure. The SVE can be designed to extract the
contamination with minimal disturbance to the building
structure and operations within the building. The location
of the SVE Pilot Study will remain at the northeast corner
of the Greif Bros. main building. The contingency for soil
excavation and treatment at the northeast and northwest
corners of the Greif Brothers main building in the event the
SVE Pilot Study does not determine the system to be
technically feasible remains as part of the Selected Remedy.
2. Greif has commented that they believe the existing
ground water remediation efforts instituted by GE (General
Electric) are adequate to contain and remove VOCs from the
Strother Field Site without the addition of an extraction
well and air stripping unit at the GGP-2 location. They
state that this position agrees with computer modeling
studies reported on by Woodward-Clyde Consultants in a
38
-------
report to EPA dated July 31, 1987, as well as a KDHE study
in March of 1984. They refer to section 6.0, page 8, .
Figures 31 and 32 of the Woodward-Clyde Report and to pages
1 and, 2 of the KDHE report. They state that they believe
that the excavation of the PCE hot spot at the northeast
corner of their facility and the capping of the impacted
soil areas will help assure the continued effectiveness of
SW-8 to remediate ground water contamination on the south
end of Strother Field. They also state that the RI and FS
reports suggest that the primary source of the ground water
contaminants at the south end is related to the soil
contamination at Greif's facility. They feel that the AEC
data and Greif's historical use of VOCs refute the
implication that Greif's facility is the primary source of
TeE in the ground water.
EPA Response: EPA has reviewed the RIfFS and the referenced
Woodward-Clyde and KDHE reports. Greif's reference to the
1987 Woodward-Clyde report included only to one section of
that report and to only Figures 31 and 32. Greif also
referenced to only the first two pages of the 1984 KDHE
report. The 1984 KDHE Report stated that, based on the
available information, the migration of the contamination
from the GE Test Cell area was caused by the continued
pumping of the Strother Water Supply Wells rather than a
sec?nd pollution source.
The recommendations on page 3 of the KDHE 1984 Report were
that the Strother Field Commission should continue to pump
PWS #8 until such time as a final pollution management
system is implemented. On page 7 of section 6.0 of the 1987
Woodward-Clyde Report the assumptions were stated.
Assumption number 3 was as follows: "Assuming the sources of
ground water. Gontamination have been removed in 1986.". All
of the scenarios that were run for that report included that
assumption. Scenario H represents the current locations of
extraction wells. Scenario J represents an additional
extraction well very close to the proposed GGP-2 extraction
well location but without the' DM-14 and DM-5 pumping
locations.
The RI and FS have taken into consideration all previous
reports as well as information gathered during those
investigations. Additional modeling utilizing the most
recent data has been completed and reviewed by both KDHE and
EPA. ~he results of the latest modeling indicate that VOC
contamination will be contained and treated as described in
the FS, the Proposed Plan and the Selected Remedy of this
ROD. The Selected Ground Water Remedy closely resembles
Scenario J of the Woodward-Clyde Report with implementation
of the SVE at the three locations of soil contamination will
serve as the "Assumption number 3 that the sources of ground
water contamination have been removed" and the conversion of
monitoring wells DM-14 and DM-5 will enhance the removal of
contaminants from the ground water that were not as evident
39
-------
during the time that the modeling runs were made for that
report in 1987. The results of the Greif Brothers sampling
of Monitoring Well lOA in 1993 submitted with their comment
letter reinforces the need for monitoring well GGP-2 to be
converted to an extraction well and treated to ensure that
the ground water contamination does not migrate to the
drinking water wells immediately downgradient of the site.
The EPA has determined that the Ground Water Remedy as was
described in the Proposed Plan will be implemented as
described above in the Selected Remedy.
40
-------
ATTACHMENTS
. .
-------
ARARS
BLRA
AR File
CERCLA
FS
KAL
KDHE
MCL
NPDES
NCP
NPL
OU
- -
ATTACHMENT I
Giossary of Terms
Applicable or Relevant and Appropriate
Requirements - Clean up standards, standards of
control or other environmental protection
requirements.
Baseline Risk Assessment - Provide an evaluation
of the potential threat to human health and the
environment in the absence of remedial action.
Administrative Record File - includes all
pertinent documents and site information which
forms the basis and rationale for selection of a
remedial alternative. .
Comprehensive Environmental Response, Compensation
and Liability Act of 1980. The federal
"Superfund" law.
Feasibility Study. The study used to evaluate
various alternatives to clean up contamination.
Kansas Action Level is a concentration that could-
produce chronic health- effects aft~r long term
consumption of water. If a contaminant is
detected at or above the KAL in a public water
supply, the well must not be used for drinking
water purposes.
Kansas Department of Health and Environment.
lead government agency for the Strother Field
site.
The
Maximum contaminant Level - The maximum amount of .
contaminant allowed in groundwater by USEPA.
National Pollutant Discharge Elimination System -
a permit that sets standards for the discharge of
potentially contaminated water.
National oil and Hazardous Substances Pollution
contingency Plan. The procedures used to address
the response powers and responsibilities created-
by the federal Superfund law.
National Priorities List. A list of most
contaminated sites as determined pursuant to
section 105 of CERCLA.
Operable unit - An action taken as part of an
overall site clean-up. A number of operable units
can be incorporated in the overall plans for a
site clean-up.
-------
PRP
Potentially Responsible Party - The party
identified by the U.S. EPA which is potentially
responsible for contamination.
RI
Remedial Investigation - The report which
identifies site conditions, extent of
contamination, and site risks.
ROD
Record of Decision - The official document by u.S.
EPA which selects the remedy to clean up a
Superfund site.
SARA
superfund Amendments and Reauthorization Act of
1986. The federal law which amended and extended
authorization of the original Superfund law
(CERCLA) .
USEPA
United States Environmental Protection Agency -
The support government agency for the Strother
Field site.
VOCs
Volatile Organic compounds - Man-made chemicals
(normally) that are found in many household,
commercial, and industrial products. They are
used widely in industrial processes. VOCs in
groundwater are a concern due to the~r potential-
health effects.
-------
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AREA LOCATION MAP
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II DATE
I Augusr 1982
1983
Mav-June 1983
I .
Jur.e 2. : 983
I J . - . 083
i W1e 1.:. l.,
Seprember 1983
I Januarv 1984
I .
I
I' .
I
March 1984
May 16. 1984
May 18, 1984
May 24. 1984
A IT ACHMENT IV
Chronology of E'r'ems Leading to the Rl/fS
I EVE~T
.
!/
II
I
I
KDHE derecred volatile organic compounds in samples from warer
succiv weils ar Srrother Field Industrial Park as Dart of U.S. EPA's
S~ri{etic Organic Chemical Survey. ~26) -
KDHE conciucred a warer quality assessment of Posey Creek warershed.
They round low DO,high nutrientS, high BOD, and derecrable levels of
TCE. 7C~ and DCE. They concluded thar warer quality had
deteriorated since 1969 due to ,discharges from the Site and runoff from I
the Counry Landfill and that the grearesr effecrs were from conventional
pollura:
-------
A'ITACIIMENT TV (cont.1
Chronology of Events L~ading to the RI/F.S
I
: DATE
I October 3. 1985
i OctoDer 9, 1985
,
i
'1
:1 :--JovemDer 1985
:1 January 17. 1986
!
I EVENT
I KDHE approved GE's revised plan. :39.45)
i In accordance "vith the Consent Order of April 9, 1985. GE submiaed a
document entitled "Long-Tem Remedial Program at the GE Engine Test
Cell" to KDHE.(45)
,. GE began operating !'NO air stripping columns at wells SFW-2 and
REM-I. (39.45.48) .
II
I
KDHE issued additional Administrative Orders (86-E-4. 86-E-6, and 86-
E-7) to ?RPs (GE, Cessna Aircrait:, Greif Brothers, and Gordon-Piaa
Energy Group, Inc.). These orders addressed constiruentS found at .the. .
southern end of the Site. ..ill of the orders were appealed: however. GE I
installed a ~1ird air smDDins: column (SFW-B) as a result of the draft: .
I Order 86-£-4. ~47) :-he ~rher- three PRPs conducted a limited ground-
. water invesrigation at the south end of the Site. (46)
,
i ~1arcn 1986 J The Saother Field Commission installed rwo new water supply weils I
i (SFvV-I0 and SFvV-l1) in a portion of the Field where g!ound \';ater I
i I
I had not been impacted by organic solvents. (98) I
:1 , Saother Field was officially added to the NPL. (5~) I
:I May 1986
; , I
, July-August 1986 Tracer Research Corporarion perfonned a soil gas survey of the Site for
i KDHE. They obtained and analyzed 75 samples. The results indicated
:\ tWo distinct plumes: iIl LtJ,e cenrral and southern pOrDons of the Site.
.1 VOC concenaations in the viciniry of the north test ceil were ail below
! I
! 0.01 ppb. (62)
i GE signed a consent order (86-E-4) with KDHE to pump and rre~t I
: December 22.
! 1956 ground water nom weils REM-I. SFvV-2, and SFW-8 for a period or ten
! years. (.m . I
., The Strbther Field Commission installed a new water suppiy well (SFW-
; ~lav 1987
:I - 12) in a portion of the Field where ground water had not been
il impacted by organic solventS. (25)
,
! June 8. 1987 KDHE released a report entitled "Preliminary Assessment for Potential
j Hazardous Waste Site" to EPA. The report described the presence of
,
! VOC constiruentS in grounci warer 'and cited Greif Brothers. Gordon-
:1 Piatt. and GE as PRPs. (67)
.;
-------
..\TTACIl~tENT IV (cont.'
Chronology of Events L~adiDg to the RIIF?
1/ DATE I EVENT I
I
I
I July 26. 1984 GE submirred a G&M report to KDHE, entitled "Ground Water Qualiry
i Conditions ar the Scromer Field Industrial Park." The report proposed
monitoring weils MW-1 L'lrough MW-6 and DM-1 through DM-l4.
Well clusters DM-1/DM-S. DM-6/DM-7, DM-IO/DM-ll, and DM-
13/DM-14 were installed at the top and bottom of the aquifer to
derermine the vertical exrem of the constitUents. G&M concluded that
the rwo old lancifill sires were the major sources and thar constiruents
were confined ro the' upper portions of the aquifer. (23)
i KDHE unofficially rejecred the G&M report. KDHE was nor in complere
! .-\ugust 1984
i agreement with G&M's f...r.ciings. KDHE sunnised that the data indicate
a JP-4 fuel spill in 1981 may have contribUted ro ground-water
., ! conditions ar the norm resr ceil. (48)
, : KDHE conducreci a seco::ci survey to identify users or chlorinared I
i ~1ay 20-31. 1984
; OcroDer 25. 1984 solvems ar Srromer Fie~ci. :illHE identified four companies who used I
;/ chlorinared solve!lrs: C=ssna. GE. Peabody Gordon-Piarr Inc.. .:.nd Greif
Brothers Coroorarion.:: ~::) !
I
i January 29. 1985 KDHE issued two Adminiscrative Orders (85-E-11 and 85-E-12) to GE. I
, Order 85-E-11 required GE ro consrrucr a series of monirori,ng weils
I
I sufficiem ro delineare the areal extent of the ground-warer plume.
,
I Order 85-E-12 direcred GE ro revise the plan submitted pursuant ro
I Adminiscrarive Order 84-£-21 to include soil sampling, consrruction of I
I ground-warer wimdrawal wells. a pumping program. and rrearmenr and
!
, disposal of the withdrawn r1uids. (43)
I ! GE appealed orders BS-E-11 and 85-E-12. (39.43) I
Februarv 1985
'1 ~larch 9. 1985 ! G&M complered a site assessmem for GE of properry leased by Cessna. I
I G&M concluded L".at no major comamination exists on the property,
I
although they detecred TCE at a conc.enrration of 2,400 ug/l in one well
(CMW-4) and low levels oi.VOCs in four other wells.(36)
March 13. 1985 During a hearing regarding GE's appeal of the adminisrrarive orders, GE
agreed to develop a localized ground-warer flow model to establish the
location and consrruction or withdrawal wells to address the plume at
the north test cell. GE was ordered to develop a remedial action plan
and a ground-warer monirorin~ ~lan to include monthly monitoring of
water supply wells ar the Sire. ,43
, April 9. 1985 KDHE finalized the Adminisrrative Orders (84-E-21, 85-E-11. 85-E-12).
They combined the three previous orders into a sin~le document which
limited the investigation ro the north test cell area. 42.43.44)
July 18. 1985 GE sent a revised work plan to KDHE in response to the Adminisrrative
Order. The plan called for the installation of tWo recovery wells (SFW-
2 and REM-I) with air stripping columns. (39)
-------
.-\'ITACII:\IENT IV (cont.,
Chronology of Events Leading to the RI/F~
II DATE I EVENT I
I' July 31. 1987 Woodward-Clyde consultants submirred a documem to E?A entitled I
I "Report on Hydrogeologic and Ground-Water Comamination
I
Investigation for Strother Field." The report included the results or a I
I
i solute transport model and concluded that the air-stripping columns
I were successfully removing the VOCs from the ground water in the
i northern and central areas. However, further investigation was
suggested for the southern portion or the Site. (25)
January 19,1989 I The Office of Health Assessment complered its report to EPA, I
' "Prelimi~ary HealLh Assessment. Strother Field Industrial Park."(68)
I
I I " I,
Seprember 1989 The Srrother Field Commission insralled a new water supply weil (SFW- I
; I
113) in a portion or Strother Field where ground water had nor been !
: i
I impacred by or~i!nic solvents.:m I
I
:! I
I i KDHE released a cirair Adminisu-ative Order calling for a Tormal RI.:FS
;1 February 6. 1990
I of the Srrother Field Sire. ::3) -:-he Order was presented ro GE. Greii
! Brothers. Gordon-Piatt. and ~10ntgomery Elevaror in a meeting "..rith
I EPA and KDHE [Cessna and Range Oil were nor asked to arrend the
meeting]. The order called for the PRPs to jointly conducr a RIfFS.
i After consulting ,,\rith the PRPs. GE elected to proceed as sole signatory 'I
to the Order. ;:;r0vided the other PRPs agreed to cooperate in the ,
investigation. ,40)
March. 28. 1990 i KDHE and GE sign~.d a Consent Agreemenr to conducr a RIfFS ar the I
I
I Scrother Field Sire. ,03)
I I I
~1arci129. 1990 'GE signed a Settlemenr Agreemem: ,,\rith Greif Brothers. Gordon-Piatt.
i and Momgomery Elevaror. GE a'ZI'eed ro conducr the RI/FS and rhe I
;1 1
orner parries agreed ro proride i..-riormation and access to the Sire.' -;..1) i
i
I July 1. 1990 I GE submitted its draft RI work plan ,to KDHE for review. (:9) I
" KDHE approved the RI work plan. I
November 15. The work plan objectives were m:
1990 1) determine the narure and eXtent of constituents detected in ground
water. surface warer, soil, and sediment; 2) characterize the ground.
warer r10w regime; 3) idenrify and delineate the sources of the
constiruents; 4) model the fate of these constiruenrs in the ground
warer: and 5) prepare a risk assessment. (29)
February 28. I KDHE and EPA conducred a Public Meeting and established an I
1991 Administrative Record for theSrrother Field Superfund Sire. (65)
Aprii 1991 I Field acti\iries for the RI commenced. (66) I
-------
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-------
ATI'ACIIMENT VII
Maximum (:onccntratiuns Uctcctccl in the (;mllllll Water in Elich Arcil
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1,I.nCA
Mtlhylelle 1,2.I)CA
C.hlorlde
1.'1 53
116 630
Nonh 4900 73000
Cenlml 130000 6600
Scullh 7400 26000
I MaxilllulII ] 130000 I 73000
lI..ckn"y' NI> I ND
.
.:;~J ";; ~~m :-~ -'::: .;~ 32 .,
Q7001 - _"00-1 ISm" 1----- i,-, -"""O_~--':~-~-~-_I=-_O;O~-_I
N'I:-=r Nil L_~~J_1.j'=r=~--Ni~ NI> I Nil C 0.0
AIU0\ Chinn.. Unll"n. ";;;;;'~-r-""_i''''J--';;-'':-iCAI-----i-:O'';;:;:- m ---hih:«J .,0,,,, j--C;;'';;;;:T---,;o;;,; C]
fn,m fo,m dih..nI110-' h.-IIlrUt dhllne "cnl~II"
. ...r.hunt
---+ .. . . --.. _.n...
Nonh 180 50 1300 15 5.0 NI> 1'1000 49200 66 5000
C.enlral 64 30 470 126 60 25 2200 8100 50 890
South '-. .--~~ --
8.4 36 100 II 60 1.3 2.3 NI> NI>
- -_. .
I M..ximum I 180 I 50 I 1300 [ 15 1 6.0 I 25 J 11000 J 49200 I 66 I 5000 ~
Ilackney' I 8.4 I NJ> I rID I NI> NJ> NJ> I 0.'1 NJ> NJ> I 1.1 I
The lI..ckr.u~y ..,,~.. is 1101 pari of Su 01 11<:. I.kld
-------
ATntr:IIMENT VIII
SI:UHlanls, (:..ilcria nl1d (;..i.lclincs rur (:unslilncnls
BeIcelcd in Snil and (;ruund Wntcr al Strother Ficlcl(IJO)
-
COMI'(HlNn ST/\NI>AlmS, CItlTEIti/\ /\Nn/Oit mllnm.lNES
- --.- ._-------- --~-------r---
MCr. 1'.1\1<:1. 1.11/\ "'Qc wQc Rm Carcinogenic
("Wi.) (11':11.) (IIWI.) Fn~sl"v;111T Freshwilier (mWkwday) SloJle Fllclor
/\('nh~ (:hl"lInic (t 'Slo')
(nwl.) (uwl.) (lIIwkgfday)'
III'n".I'n~ 5 .. 0.7 -~,~oo - .- " .- 221'.2-
Itu ""u'-o..n .. .. .. :ll'.:l 7 'IF :I
--.-----.
I'lhvll,,'n1.l'ru~ -- 700 -- 32,000 .- 1);.1 ..
Car hon '~'rachl()fide 5 .. -. 1~200 -- 71'-4 131'..1
(:hlllmhc.nzc,1I' -- .. 3,150 '2~0 50 21'-2 .'
(:hlnmfmlll .. -- 200 ~II,C}OO 1,2"0 11'.2 () 11'.:1
(:I,hmulihrnll1l1l11e' hane .. .. 11.QQQ .. :l1'-2 8.41'.-2
Chlnme.h,lOe .. " " .. 11'.,1'"
.
1 I.Dichlnroc'lhane (lX:A) -- .. " .. .. .. 911:.-2
1 2.Dichlomclhanc 5 .. .. 118000 20 000 .. 9.11-:.2
-1.J .()irhlllro(',lwn~ (DCI') 7 .. 0.015 I!,~ -- 91'.3 61'.1
1 ,2.()ic-hlnml',hen~ -- .. 350 11,600 -- 21~.2 ..
Mc'lhvkn~ rhillrid~ 5 " .. 11,000 .. 61'.2 751'. :1
~e'.!k)' elhy' kellinI' -- .. 860 .. -- 51'-2 ..
ME . ---L---
T,'lra,:hlnrllt'lhvh'nc (PCI'.) .. 5 0.7 5,290 840 11'..2 5.11-:2
Tllhll'l\(~ .. 2,000 10,100 17500 -- 21'.' ..
_J...:.._-
_I~!OI(K'lhyl('n(' (TCE) S 21\ .I~, ono __~L~ .. ---_.!.! L~ - --
------ -._-.----- --. ---- __I...-.~--
I \ I \ 1:1"1 ichlomdhanc 200 .. 200 .. .. 9E.2
( 1./\)
-112 T,i.-hl"I"I...lhalll: .. ~~ -_!!!.!!!!!!_. 9,400 41:.3 571: 2
Villyl ('hl... i,l,' 2 - " 0015 .. .. 2)1: I 0
_~I"II" .. I Q.!!OO 2,200 .. 2.01: f 0 .'
MC!. = Maximllm Conlaminanll.cvcl (50 "'Cderall:f~~n 4(,I\HO)j. I'.MU. = "f(I[l0SCt! Mnxi'JllI1II Cnillalllillall" eve-! (I !I I ice of Dlinking Waler 1 '11110111', 12.15.HH); 1.11/\ = l.ilclilllc Ilealih
/\.Ivisnry (IJSE!'/\ 1988); IUD,.. Itcfcrencc 1J0se : ';-198H); \vQC ~ Walcr I}nnlily Clilcria .
. V;III1C rcrrc5cII'~ Hdercnce Concentl'alion (RIC) for d"'lIIit-al via inhalalinn.
.. The MU. for IlIlallrihalnmclhnn"-~ is 1111' IIg/I..
-------
ATIACHMENT IX
Target Levels for Remedial Action Objectives
I CHEMICAL I lSOIL I 2GROUNDWATER I
mglkg ug/L
Trichloroethylene (TCE) 6.0 5
1,1,1 Trichloroethane 260 200
(TCA)
perchloroethylene (PCE) 20 5
Benzene 1.0 5
1,1 Dichloroethane 100 35
1,2 Dichloroethane 0.50 5
1,1 Dichloroethylene 0.2 7
cis 1,2 Dichloroethylene 1600 70
trans 1,2 Dichloroethylene 3100 100
Methyl Ethyl Ketone . . 900 3170
Toluene 150 1000
Vinyl Chloride 0.1 2
Ethylbenzene 650 700
1. Risk based levels - see "Risk Assessment Guidance for Superfund: Volume I - Human
Health Evaluation Manual (Part B, Development of Risk-based Preliminary .
Remediation Goals) - section 3.2, equations 6' and 7'.
2. Maximum Contaminant Levels except as noted.
3. Kansas Action Levels.
-------
ATIACHMENT X
Preliminary Remedial Action Alternatives
for Groundwater
GENERAL PROCESS ALTERNATIVE IDENTIfiCATION
RESPONSE OPTION
ACTION 1 2 3 4 5 6 7 8
No Action No Action .
Institutional Controls Land Title CovenantS . . . . . . .
Signs .
Groundwater Monitoring . . . . . . .
Removal Install Liquid or Blower Pumps . . . . .
in New Recovery Wells
Treatment Air Stripping . . '
. . . . .
Carbon Adsorption . .
UV Photolysis .
Disposal Actions Reinjection .
Discharge to Surface Water . . . . . .
1 Includes the addition of a process heat exchanger to the air-stripping system
-------
A ITACHMENT XI
Preliminary Remedial Action Alternatives
for Soil
GENERAL PROCESS ALTERNATIVE IDENTIFICATION
RESPONSE OPTION
ACTION 9 10 11 12 13 14 15 16 17
No Action No Action .
Institutional Controls Land Title Covenants . . . . . . .
Signs and Alarms . . . . . . .
Monitoring by Site . . . . . . .
Personnel
Soil Monitoring . . . . . . .
Containment Clay, Pavement, or . .
Multi-Media Caps
Grading .
Stonn Sewer .
Modifications
Stabilization .
Removal Soil Removal . . . .
Treatment Soil Venting . . .
Carbon Adsorption .
Thermal Drying . .
Disposal RCRA TSD F~ciliry. .
-------
ATTACIIMENT XII
Screening of Preliminary Groundwater Alternatives
ALTERNATIVES. EFFECTIVENESS IMPLEMENTABILl1Y COST STATUS
Alternative t: no action Would not protect human Not a factor No cost Retain as required by
health and the environment the NCP to compare
from future risk; mobility and against other
volume would increase Alternatives
Alternative 2: limited action; Limited protection for on-site Easy; requires installation of Capital -- $13,000 Reject; ineffective
implement institutional workers only; mobility and signs and continued 0 & M -- $70,000
controls, continue existing volume would increase operation of existing Present Worth .0
groundwater monitoring groundwater monitoring $707,037
system, but discontinue system
existing groundwater
recovery system
Alternative 3: implement Potentially effective over long Easy to moderate; requires Capi~al -. $13,000 Reject; inability to
institutional controls and time periods for north, north- continued operation of 0 & M -- $145,000 achieve Remedial
maintain existing central, and central plumes; existing groundwater Present Worth -- Action Objectives in
groundwater monitoring may not prevent off-site monitoring and recovery $1,430,962 reasonable time
and recovery system migration of southern plume system frames
Alternative 4: implement - Effective for all plumes Moderate; requires *Capital -- $312,000 Retain; effective and
institutional controls and installation of well-pumping 0 & M -- $220,000 proven capacity to I
expand existing systems, construction of air. Present Worth -. implement
groundwater recovery stripping towers, and $2,184,984
system by adding new application for State
recovery wells with air- discharge permit(s)
stripping towers discharging
to Posey Creek
-------
ATfACHMENT XII (cont.)
Screening of Preliminary Groundwater Alternatives
AI,TI~RNA l'IVI~S EFI<'ECTIVENESS 1M I)I.EM ENTA II II.lTY COST STATUS
Alternative 5: implement Effective for all plumes Moderate; requires *Capital -- $1,092,000 Retain; improved
institutional controls and installation of well-pumping 0 & M -- $430,000 effectiveness over
expand existing systems, installation of Present Worth -- Alternative 4; could
groundwater recovery carbon adsorption units, $4,752,832 be used in
system by adding new construction of air-stripping conjunction with
recovery wells with air- towers, application for State other measures
stripping towers and carbon discharge pennit(s), and
adsorption units discharging hazardous waste -
to Posey Creek management of treatment
residues
Alternative 6: implement Effective for all plumes; would Moderate to difficult; *Capital -- $1,222,000 Reject; difficulty in
institutional controls and improve/secure efficiency of requires installation of well- 0 & M -- $430,000 implementing not
expand existing recovery systems pumping systems, Present Worth -- offset by improved
groundwater recovery installation. of carbon $4,882,832 effectiveness
system by adding new adsorption units,
recovery wells with air- construction of air-stripping
stripping towers and carbc-n towers, construction of
adsorption units, reinjecting reinjection system, hazardous .
treated effluent back into waste management of
aquifer treatment residues, and
careful coordination with
State and Federal regulatory
agencies
Alternative 7: implement Effective for all plumes Moderate; requires *Capital -- $687,000 Retain; improved
institutional controls and installation of well pumping 0 & M -- $440,000 effectiveness over
expand existing systems, installation of UV Present Worth -- Alternative 4; could
groundwater recovery photolysis units, construction $4,432,968 be used in
system by adding new of air-stripping towers, and conjunction with
recovery wells with UV application for State other measures
photolysis units and air- discharge permit(s)
stripping towers discharging
to Posey Creek
-------
ATIACHMENT XII (cont.)
Screening of Preliminary Groundwater Alternatives
ALTERNATIVES EFFECTIVENESS IMPLEMENTARIUTY COST STATUS
Altemntlve 8: implement Effective for all plumes Moderate to difficult; .Capital -- $387,000 Retain; increased
institUtional controls and requires Installation of well- 0 & M -- $235,000 effectiveness with
expand existing pumping systems, Present Worth -- similar costs to
groundwater recovery construction of air-stripping $2,387,687 Alternative 4; limited
system by adding new towers, construction of heat- to areas with process
recovery wells, preheat exchanger system, and cooling water needs
water, and remove VOCs via application for State (e.g., central plume)
air-stripping towers discharge permit(s)
discharging to Posey Creek
. Capital costs for these Alternatives assume that a pennit will not be required under Title V of the Clean Air Act Amendments
-------
ATTACHMENT XIII
Scr~ening of Preliminary Soil Alternatives
AI,TERNATIVE EFFECTIVENESS IMPLEMENTA81UlY COST STATUS
Alternative 9: no action Based on RI data, may not Not a factor No cost Retain as required by
protect human health and the NCP to compare
environment at two locations against other
on Greif Brothers' proper-ty; may Alternatives
not prevent migration into
groundwater; relatively slow
cleanup via natural processes
Alternative to: implement Would provide limited Easy; many critical areas are Capital -- $115.200 Retain; particularly
institutional controls and protection against accidental already paved; requires 0 & M -- $37,100 suitable in areas where
construct an asphalt cap exposure and discourage installation of signs and Present Worth -- access constraints limit
migration into groundwater; implementation of a soil $431,053 treatment options, such
relatively slow cleanup via monitoring program as GE building 5
natural proc~sses
Alternative 11: excavate soil Would be effective to the extent Moderate; may not be possible Capital -. $1,430,000 Reject; high relative
above cleanup levels and that soil containing VOCs above to excavate all contaminated 0 & M -- $0 cost compared to on-
transport to an off-site TSD cleanup levels is accessible and soil; possible new liabilities Present Worth -- site Alternatives; risk of
facility can be excavated during transportation and off- $1,430,000 contaminating new
site management areas
Alternative 12: implement Would be effective to the extent Difficult; may not be possible * Capital -- Reject; difficulty to
institutional controls, that soil containing VOCs above to excavate all contaminated $1,070.200 implement not offset by
excavate soil above cleanup cleanup levels is accessible and soil; may require RCRA land 0 & M -~ $68,100 improved effectiveness
levels, treat on-site by soil can be excavated disposal or treatment permit Present Worth -- compared to other
venting, return treated soil for waste pile $1.239.555 Alternatives
to excavation
Alternative 13: implement Potentially effective but Moderate; technology is easy * Capital -- $850,200 Retain; useful in areas
institutional controls and unreliable under certain to implement but may require 0 & M -- $53,100 where excavation is not
treat in-situ by soil venting conditions; more time required pilot studies or additional field Present Worth -- practical (e.g., GE
to complete remedy than some work during remedial design $1,051,491 building 5); higher cost
other Alternatives. unless phase partially offset by
natural attenuation is natural anenuatfon
significant mechanisms
-
-------
ATfACHMENT XIII (cont.)
. Screening of Preliminary Soil Alternatives
ALTERNATIVE EFFECTIVENESS IMPLEMENTAIULilY COST STATUS
Alternative 14: implement Would be effective to the extent Moderate; may not be possible * Capital -- $640,200. Retain; useful in areas
institutional controls, that soil containing VOCs above to excavate all contaminated 0 & M -- $52,100 with good access (e.g.,
excavate soil above cleanup cleanup levels is accessible and soil; may require RCRA permit Present Worth -- Greif Brothers) if
levels, treat on-site by can be excavated for treatment process $730,621 permitting can be
thermal drying, return avoided
treated soil to excavation
Alternative 15: implement Potentially effective to prevent Difficult; technology is . Capital -- $925,200 Reject; less effective
institutional controls and migration and reduce exposure available from experienced 0 & M n $44,100 than other Alternatives
treat in-situ by stabilization risks, but leaves waste in place contractors, but access Present Worth --
and inhibits natural attenuation constraints limit utility in $1,034,870
through biodegradation most" areas of the Site
Alternative 16: implement Potentially effective if properly Moderate; may not be possible * Capital u $292,200 Retain; good overall
institutional controls, designed; access .constraints to excavate all contaminated 0 & M -. $56,100 effectiveness at a
implement surface controls, may require leaving some waste soil; may require RCRA permit Present Worth -- reasonable cost if
excavate hot spots and treat in place above cleanup levels to for treatment process $504,863 permitting can be
on-site by thermal drying, be treated through natural avoided
and construct an asphalt biodegradation
,
cap
Alternative 17: implement Potentially effective but Moderate; technology is easy * Capital -- Reject; use limited to
institutional controls, treat unreliable under certain to implement but may require $1,370,200 areas with poor access;
in-situ by soil venting, conditions; more time required pilot studies or additional field 0 & M -. 166,100 higher cost not offset
recover VOCs by carbon to complete remedy than some work during remedial design Present Worth -- by increased efficiency
adsorption other Alternatives phase $1,999,850 over Alternative 13
* Capital costs for these Alternatives assume that a permit wi1\ not be required under Title V of the Clean Air Act Amendments
-------
Srrother Field. Kansas
?easibiliry Srudy
?reliminary Alternative Screening
ATTACHMENT XIV
Present: Worth Analysis at 7% Discount Rate
I ALTERNATIVE DURATION CAPITAL ANNUAL I PRESENT I
(YeDrs) COSTS O&M COSTS WORTH
I Ground Water: 1 50 $0 SO I SO
2 50 13,000 70,000 979,052
3 40 13,000 145,000 1,946,097
4 20 312,000 220,000 2,642,683
5 20 1,092,000 430,000 I 5,647,426
i 6 20 1,222,000 430,000 I 5,777.426
I I
I i I
il i 20 687,000 440,000 I 5,348.366 I
I
II 8 I 20 I 387,000 235,000 i :::.876.593
q
I Soil: 9 20 ° 01 01
I
I
I 10 20 115,200 37,100 508.238
I 11 1 1,430,000 °1 1,430,000
I I 68,100 I
I 12 3 1,070,200 :,248.915
i 53,100 I :,067,920 I
I 13 . 5 850,200
I
I I
I 14 2 640,200 52,100 I 734.398 I
, I
I I
.1 15 .3 I 925,200 .44,100 I :.040,932 I
56,100 I 522,221
I 16 5 292,200
17 5 1,370,200 166,100 I 2.051,242
C-1
-------
ATTACHMENT XV
D.l.
Assumptions
Costs for eacn Final Si~e-Wide Alternative were determined using EPA's Cost of Remedial
Actions (COM n.1) soml/are, except as noted [the costs for Alternative I were supplied by
rhe authors as discussed in sections 0.2 and 0.3]. The following rable lists the input
parameters for Alternarives II, III, and rv.
I VARIABLE -, VALUE I SOURCEIRATIONALE I
Common Assumptions I
Duration of Ground-Water 10 yrs calculated by MOCIM ground-
Removal and Treatment water model; average value
using re~ardation factors
berween 2. and 5.5 for TCE
Average Te:!1perarure 850f worst-case assumption from I
the CORA TM user's manual; all I
. field work to be compieted
during the summer I
Personai Protection Le':e;s action-specific from CORA ,,-j User's Manual I
(exampies); personal
experience
Confidence Leveis medium personal experience
Asphalt Cap (Alternath.es II. III, and IV)
Affected Area 0.32 acres (14,000 fiZ) approximate size of soil-gas
plume at the northeast comer
of Greif Brothers (the oniy .
location where soil target
cleanup levels are exceeded)
Soil Excavation (Alternati~.es II. III. and IV)
Soil Type silry clay Rl report, section 3.2
Depth of E.xcavation Alternative iI = 20 feet for Alternative II, assumes
Alternatives III and IV = 2 feet excavation to water table,
based on soil sampling and soil
vapor readings; for Alternatives
III and IV, assumes excavation
of upper rwo feet as described
in Section 9.0 of the FS report
Steel Sheering or Side S:o?e side slope personal judgement based on
site conditions
Horizonral Components 1:1 slope CORA TM default value I
0-1
-------
ATTACHMENT XV (CONT . )
~ 1 I I I
il VARIABLE VALUE SOURCE/RATIONALE
II
:1 Length of Excavation 200 feet approximate size of soil-gas
I plume at the northeast corner
I of .Greif Brothers (the only
I location where soil target
, cleanup levels are exceeded)
j Width of Excavation 70 feet approximare size of soil.gas
plume at the northeast corner
of Greif Brothers (the only
I location where soil target
cleanup levels are exceeded)
I Depth of Cover Above None excavarion under Alternatives
Contaminared Materials II, III, and IV begins ar the soil
I surface
i Depth of Cominuous Sa:npiing A.ltemat,ive II = 20 feet for Alternative II, assumes
q to Characterize Excava;:e:: Soil .~rernarives ill and IV = 2 feer sam piing from the surface to
I I the warer table, based on Rl
ii soil sampiing and soil vapor
'I readings; for Alternatives III
'I and IV, assu.-nes sampling
j within the upper !\'JO feet as
I
I described in Section 9.0 of the
FS report
,
I
Thickness of Lifts Alternative II = 24" professionai judgemenr
Alternarives III and IV = 12"
Base Air Monitoring Re~'.:ired Yes air monitoring recommended
I to ensure safe working
I conditions
Percenr of Backf1l1 AvaJJa;,ie 100% treated soil to be used as
I On-Site backfill
I
SoH Vapor EXtraction (Alternative IV)
Soil Type silty clay Rl report. secrion 3.2
Affected Area 0.32 acres (14,000 ft2)/area approximate size of soil-gas
(three areas rotal) plume at the northeast comer
of Greif Brothers (same size
area assumed for ocher !\vo
locations)
Well Spacing 20 feet CORA ~ default value
Average Length of Well Screen 15 feet depth ro warer table, less five
feet to prevent shorr-circuiting
Vapor Flow per Well pe:- 1 scfm/ ft CORA ~ default value
Length of Well Screen
0-2
-------
A TTACHMENT XV ( CONT. )
11 VARIABLE I VALUE I SOURCEfRATIO~ALE I
, I
I Quamiry or VOCs in Soil On- rough calcularion, based on
I 5,800 Ibs.
I Sire I soil gas and PID dara from RJ
I
, Ground-Water Extraction (Alternatives 11. III & IV)
Number or Wells I ~ weils to be installed see Section 9.1 of the FS report
PlUr.ping Rate per Well I 100 gpm see Section 9.1 of the FS report
Well Diameter I 10' from CORA nI recommendations
I for pumping rares b~rween 100
and 499 gpm
Wii! Wells be Gravel Packed I yes acceptable practice for wells
, constrUcted in aquifer
I ! materials founci on-site
I Average Weil Depth i 30 feet based on average depth to
1 I
I I " water table and thickness of
! r
I I aquifer from Rl :epor.
';
il T:ansier PiDing Length I 200 feer estimated dista::ce berween
I' ! proposed recovery weiis and
I
! i air-saipping ,:owers
I
i
! PUffi?ing Warer Level per Well , 25 feer approximarion :-e?reseming
I 2/3 of difference benveen the
I
I ' ' I borrom of proposed weils and
the average staric water level
Air Stripping (Alternath'es II. I1I & IV)
I Flo.....' Kate I :00 gpm see Section 9.l of the FS report
I I
Disc::arge to paN or S'...lrrace I surface water see Section 9.: 0: the FS report
I I
I Warer
! I
i Cor:raminam Concencrarions I rece::: :::aximum values for quarreriy moniror'.ng' data from
I I each consriruem of concern 1991 and 1992
I (excluc:'''1g shorr-term "spikes")
Vapor Phase Carbon (option for Alternath'es II. III & IV)
Loading :)M-S = 9 Ib/day calculated by CCR..A ~ ;lir-
GGP-2 = 3 lb/day stripping cosr ~odule
JM.14 = 3 lb/day
Air rlow I 1,005 cfIn calculated by COrtA nI .::.ir-
stripping cost module
Discharge to Surface Water (Alternatives II. III & IV)
Transmission gra v:i ry knowiedge of si.e
characteristics and preiirninary
system design
i I
I Flow Race 100 gpm see Section 9.1 of FS reporr
D.3
-------
ATTACHMENT XV (CONT.)
11 I '
n VA Rl-\BLE VALUE SOURCEIRA TIO!'ALE
I! . '. -. 2,000 feet sum of estimated dis,aiices I
: :...engm 0. JJ:?e
I from proposed and existing air-
stripping tower locations ro
I nearest stonn-sewerl receiving
I stream
Depth or T:e!1cn common depth for similar
I 6 feet
sysrems
Is a DiL"'fuser Required no nor a componem of currem
sysrem design; see Section 9.1
of FS report
Is a NPDE5 ?ennit Required yes assumes a single new pennir
I for the emire site
I
I Ground.Water Monitoring (Alternatives II. III & 1\) I
Number or "",'elis to be lnstailed see Section 9.1 of F5 :eport i
! 2 new weils
:! ,
=1 Average Weil Deprn 30 reet based on geotecnnicai GaLa i
ll
from Rl report I
I'
I ~umber of V/ells LO De see Section 9.1 of:5 report I
I 23 (quamriy d:emical analysis) I
I Y1oniro:ed 90 (semi-an~ual water level) I
I
I
I 90 (S-year c::emical analysis) !
I
Moniro:lr:g ;;:equency quarteriy (chemical analysis) see Secrion 9.i of :5 report I
I I
semi-annual (water levels)
5-years (chemical analysis)
Y1onito:ing Tests/Parameters VOA GC/MS adequate to monitor I
I consriruems of cor:ce~ a:: :his
I I
site I
,
D-4
-------
ATTACHMENT XV ( CONT . )
D.2.
User-Supplied Costs
The CORA TI.1 software did nor include modules to calculare rhe cosr for some
componenrs of each Alrernarives. Therefore, rhe following cosrs were supplied by rhe
aurhors, based primarijy on personal experience and informarion supplied by vendors.
I VARIABLE I VALUE I SOURCE/RA TIONALE I
Alternative I
Close 90 yvells I 90 wells x $650/well = S58,500 past experience closing other
wells on-site
Dismantle 3 Towers I 3 towers x 51,SOO/tower = 54,500 personal experience
I
Alternatives II. III & IV
Thermal Dr:.1ng I Alternative II: personal experience and
! 10,000 yd3 soil X 520/yd3 = informacion supplied by vendors
I I 5200,000
Alternatives III & IV:
1,000 yd3 X 520/yd3 =
$20,000
Monitoring by Sire I 3 training sessions/yr @ personal experience
Personnei $1,200/session = 53,600
Signs and Alarms Soil: professional judge:nent
8 signs x S200/sign =
$1,600
4 alarms 'x 51,000/alarm =
$4,000
Ground water:
2 signs x $3,000/sign =
56,000
Annual O&M:
$l~SOO
Land Tide Covenants Soil: professional judgement
2 deeds x $SOO/deed =
$1,000
Ground water:
14 deeds x $SOO/deed =
$7,000
Relocare 1 Tower I $10,000 professional judgement
I
UV Photolysis 3 UV units x 5125,000/unir = information supplied by vendors
$375,000
Annual O&M = S220,000
Moniror 90 Wells Semi. 2 events/yr x $2,800/ event = pasr experience contracting for
Annually for Water $S,600/yr these services at this site
Levels
0-5
-------
ATTACHMENT XV (CON'!'.)
D.3.
Costs for Alternative I
Following are the coSts for Alternative I:
I ACTION I CAPITAL COST , ANNUAL O&M COST I Source I
Close 90 Wells I $58,500 0 user
Dismantle 3 Towers 4,500 () user
I Total Cost -I 63,000 I 01 user I
I Total Present Wortb 63,000 I
. Cost
0-6
-------
ATTACHMENT XV (CONT.)
D.4.
Costs for Alternative II
Following are the costs calculated by the CORA TM software for Alternative II:
COST
COMPONENT DURATION SOURCE
CAPITAL ANNUAL (years)
O&M
Soil Excavation Sl,OOO,OOO 0 N/A CORAnd
Thermal Drying 200,000 0 N/A user
Capping N/A N/A N/A N/A
Soil Vapor Extraction I N/A N/A t-1/A N/A
Monitoring by Site Personnel I ' 3,600 3,600 10 user
! Signs & Alarms I :2,000 1.,500 :0 user
I Land Tide Covenants I 8,000 0 ~/A user
Extracrion Wells:
i 10 I CORA Th1
(4) new exrraction weils 'j 69,000 30,000
(2) eXisting extraction weils 0 15,000 :0 I CORAnd
Air-Stripping Towers:
GGP-2 82,000 31,000 10 CORAnd
DM-S 81,000 31,000 10 CORAnd
DM-14 ! 83,000 32,000 10 CORA nd
relocate (1) tower :0,000 0 N/A user
(3) existing wells I. 0 94,000 . 10 CORAn.!
Discharge to Surface Water I 176,000 470 :0 I CORA nd
Ground-Water Monitoring:
warer levels in 90 wells semi-annually 0 5,600 :0 user
VOAs in 90 wells @ S-year review 0 31,000 5 (one-time) CORAnd
VOAs in 23 wells quarterly 17,000 36,000 10 CORAnd
Base System Subtotals 1,741,600 280,170 10 N/A
(plus $31,000
@ S-yr
review)
0-7
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ATTACHMENT XV (CONT.)
COST -
COMPONENT . DURATION SOURCE
CAPITAL ANNUAL (years)
O&M
Vapor Phase Carbon Adsorption:
GGP.2 I 78,000 77,000 10 CORA iM
DM-S 78,000 150,000 10 CORAiM
DM-14 78,000 77,000 10 CORA iM
Vapor Phase Carbon SubtotaJs I 234,000 304,000 10 CORAThf
UV photolysis (three wells) 380,000 220,000 10 user
I SYSTEM I TOTAL PRESENT WORTH COST- I
Basic Alternaave II System I 53,700,000
Basic System wi Vapor Phase Carbon Adsorption I 6,100,000
Basic System wi UV Photolysis I 5,700,000
* Present worth costs based a discount rate of 7% (current yield of 30-year T-bonds)
NI A= not appiicable to this component or Alternative
0-8
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ATTACHMENT XV (CONT.)
D.S.
Costs for Alternative III
Following are the costs calculated by the CORA TM software for Alternative III:
COST
COMPONENT DURATION SOURCE
CAPITAL ANNUAL (years)
O&M
Soil Excavarion 340,000 0 N/A CORAThi
Thermal Dry;ng - 20,000 ° N/A user
Capping 51,000 13,000 10 CORAThI
Soil Vapor Exrraction N/A N/A N/A N/A
Monitoring by Site Personnel 3,600 3,600 10 user
Signs & Alanns 12,000 1,500 10 user
Land Title Covenants 8,000 0 N/A user I
Exrraction Wells: I
(4) new exrraction wells 69,000 30,000 10 CORA ThI
(2) existing exttaction wells 0 15,.000 10 CORAThI
Air Stripping Towers:
GGP-2 82,000 31,000 10 CORAThI
DM-S 81,000 31,000 10 CORAT!oI
DM-14 83,000 32,000 10 CORAi>!
relocate (1) tower 10,000 0 N/A user
(3) existing wells 0 94,OOq 10 CORAi>!
Discharge to Surface Water 176,000 470 10 CORAi>!
Ground-Water Monitoring:
water levels in 90 weils semi-annually 0 5,600 10 user:
VOA5 in 90 weils @ 5-year review 0 31,000 5 (one-time) CORATht
VOAs in 23 wells quarterly 17,000 36,000 10 CORAi'M
..
Base System Subtotal 952,600 293,170 10 N/A
(plus 31,000
@ S-yr
review)
0-9
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ATTACHMENT XV (CONT.)
COST - I SOURCE I
COMPONENT I DURATION
CAPITAL ANNUAL ! (YeDrs)
O&M
Vapor Phase Carbon Adsorption:
GGP-2 78,000 77,000 , 10 CORAThI
DM-5 78,000 150,000 I 10 CORA n!
DM-14 78,000 77,000 I 10 CORAn!
Vapor Phase Carbon Subtotals 234,000 304,000 I 10 CORATh! I
UV Photolysis (three wells) 380,000 220,000 I 10 us'er I
I SYSTEM I . TOTAL PRESE~T WORTH COST- II
Basic Alternative III Sys::em 53.000,000
II
Basic System wi Vapor ?hase Carbon Adsorption 5,400,000 .1
Basic System wi tN Photoiysis 5,000,000 I
... Present worth costs based a discount rate of 7% (currem Yield of 30-year T-bonds)
NI A = nor.appiicable to L~is componem or Alternative
4
0-10
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ATTACHMENT XV (CONT.)
,D.6.
Costs for Alternative IV
Following are the costs calculated by the CORA TM software for Alternative N:
COST
COMPONENT DURATION SOURCE
CAPITAL ANNUAL (years)
O&M
Soil Excavation 340,000 0 N/A CORA""
Thermal Drying 20,000 0 N/A user
Capping 51,000 13,000 10 CORATM
Soil Vapor Extraction 1,380,000 180,000 2 CORATM
Monitoring by Site Personnel 3,600 3,600 10 user
I Signs & Alarms I 12,000 1,500 I 10 user
Land Title Covenants 8,000 0 N/A I user
Extraction Wells:
(4) new extraction wells I 69,000 30,000 10 CORATM
I
(2) existing extraction weils, 0 15,000 10 CORATM
Ajr Stripping Towers:
GGP.2 82,000 31,000 10 CORA TM
DM-S 81,000 31,000 10' CORAThI
DM-14 I 83,000 32,000 10 CORATM
relocate (1) tower 10,000 0 N/A user
(3) existing weils I 0 94,000 :0 CORA1M
Discharge to Surface Water 176,000 470 10 CORATM
Ground-Water Monitoring:
water levels in 90 wells semi.annually 0 5,600 10 user
VOAs in 90 wells @ 5-year review 0 31,000 5 (one-time) CORA 1M
VOAs in 23 wells quarterly 17,000 ' 36,000 10 CORAThI
Base System Subtotals 2,332,600 293,170 10 N/A
o 180,000 2 N/A
o 31,000 S.yr review N/A
0-11
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A'l''l'ACBKENT xv (CONT.)
COST -
COMPONENT DURATION SOURCE
CAPITAL ANNUAL (years)
O&M
Vapor Phase Carbon Adsorption:
GGP-2 78,000 77,000 10 CORAiM
DM-5 78,000 150,000 10 CORAiM
DM.14 78,000 77,000 10 CORAPA
Vapor Phase Carbon Subtotals 234,000 304,000 10 CORATM
UV Photolysis (three wells) 380,000 220,000 10 user
~ Bask pJ[emarive IV :::M
Basic System wi Vapor Phase Carbon Adsorption I.
Basic System wi IN Photolysis
TOTAL PRESENT WORTH COST-
$4,700,000
11
I
7,100,000
6,700,000
* Presenr worth cosrsbased a discount rate of 7% (current yield of 3D-year T-bonds)
N/A = .not applicabl~ to chis c;omponem or Alternative
D-12
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