GROUNDWATER REMEDIATION/STABILIZATION
CONFERENCE MANUAL
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ATLANTA, GEORGIA
DECEMBER 1-3,1993
Sponsored by
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
Presenters:
AZS Chemical Corporation
David Kreamer
Beazer East, Inc.
Lockheed Aeronautical Systems Co.
Berkeley Mills, Kimberly-Clark Corp.
Martin Marietta Energy Systems, Inc.
BF Goodrich Company
Miles, Inc.
CERCLA Groundwater Remediation Project
Monsanto Chemical Co.
John A. Cherry, Ph.D.
Morton International, Inc.
Chevron, USA, Inc.
NASA, Kennedy Space Center
Ciba-Geigy
North Carolina State University
CYTEC Industries
Occidental Chemical Corp.
First Chemical Corp.
Olin Corporation
Geraghty & Miller, Inc.
Radiator Specialty Co.
GNB Battery Technologies
Sanders Lead Company, Inc.
Gold Coast - Superfund
Stephen G. Sehmelling, Ph.D., Kerr Lab, EPA
GTC Communications Systems Corp.
State of North Carolina Department of
IBM
Environment, Health & Natural Resources
Intranational Paper
Thermal KEM
Kaiser Aluminum & Chemical Corp.
Torrington Company
Douglas M. Mackay, Ph.D.
Westinghouse Savannah River Company
Kerr-McGee Chemical Corp.
John T. Wilson, Ph.D., Kerr Lab, EPA
Coordinated by:
Douglas C. McCurry, Chief, RCRA Permits Section
Margaret Meares, Training Coordinator, State Programs Section
of

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Groundwater Remediation/Stabilization Conference
December 1-3,1993
Atlanta, GA
r
Wednesday
1 1:
Eoom
Facility/Presenter
Speaker
j 8:00-9:00 A.M.
!
Ballroom
Welcome and Introduction:
Douglas C. McCurry, Chief, RCRA Permits Section
James Kutzman, Associate Director, Office of RCRA and Federal Facilities
Joseph Franzmathes, Director, Waste Management Division
Margaret Meares - Logistics
Leo Romanowski - Moderator
nn dj -'i 3
Ballroom
Geraghty & Miller, Inc. — FL
Gregory Rorech, P.E.
f;.-3L 10:00
11
GTE Communications Systems Corp. — AL
Harch S. Gill, Ph.D.
1:00-1015

Break


-
Kaiser Aluminum & Chemical Corp. — FL
Paul Maasen
10:45-11:15

NASA, Kennedy Space Center — FL
John Ryan
-1.I5..I-

Berkeley Mills, Kimberly-Clark Corp — NC
Steve McFadden
~ ^' A . . y-/ A .Ivii .
fl

Lunch


it
Martin Marietta Energy Systc ns, Inc. DOE) — KY
BF Goodrich Company — K t
Torrington Company — SC
Jeff W. Douthitt
Christian J. Orsborn
David Carl Cromwell

it
Kerr-McGee Chemical Corp. — MS
Nicholas Bock
'.1t: 'M':

International Paper — MS
Michael Simms
1 *.. A*?* 1L)

Occidental Chemical Corp. — AL
Linda McConnell, P.E.
4:15-4:45

CYTEC Industries — FL
William McElroy, P.E.
Neale Sharitz

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Groundwater Remediation/Stabilization Conference
December 1-3,1993
Atlanta, GA
Thursday
Dec. 2
Room
Facility/Presenter
Speaker
A.M.
8:00-9:30
Ballroom
Nonaqueous Phase Liquids (NAPLS)
David Kreamer

Session 1 - Ballroom North;
Wesley Hardegree - Moderator
Session 2 - Ballroom South;
Lael Butler - Moderator

Facility/Presenter
Speaker
Facility/Presenter
Speaker
iO-00-i
T ockheed Aeronautical
Systems Co. — SC
Rochelle Routman, P.G.
Ciba-Geigy — AL
Thomas F. Siple
Patrick D. Hallett

'^.lermalKEM
— SC
Alice B. Clark
GNB Battery Technologies
— GA
Tom Minner
Ray Graves
Frank Barnett
1:00-11 "I
Radiator Specialty Co. —
Richard L. Harmon, P.C
Christopher C. Cutler
Chevron, USA, Inc. — GA
H. James Reisinger
Perry Hubbard, Jr.
Stewart A. Mountain
Charles W. Brigham
' :30- J
Westinghouse Savannah
River Company (DOE) —
SC
Chris Bergren
Gold Coast - Superfund —
FL
Brad Jackson
P.M.





,2:00-1:00
.Luiadi


Lunch

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Groundwater Remediation/Stabilization Conference
December 1=3,1993
Atlanta, GA
»- - . . .
j -i.
®©©m»
Facility/Presenter
Speaker
| " "*>y
i
Session 1 - Ballroom North;
Wesley Hardegree - Moderator
Session 2 - Ballroom South;
Lael Butler - Moderator
i
Facility/Presenter
Speaker
Facility/Presenter
Speaker

Beazer Erst, Inc. — SC
William D. Wood, Jr.
Mitchell D. Brourman
North Carolina State
University (UST) — NC
Robert C. Borden
VW "Tl
I
^jjrHers Lead Company, Inc
— AL
E. Roy Baggett, M.S.
Mark Hobbs
Chris Rutherford, P.G.
State of North Carolina
Department of
Environment, Health &
Natural Resources (UST) —
NC
Burrie vD. Boshoff
j 2:00-2:30
AZS Chemical Corporation
— GA
Tushar E. Talele
CERCLA Groundwater
Remediation Project — NC
Ken Mallary
Glenn Boylan
J 2:30-?,.45
]§re-ak


Break

2:45-3-IS
IBM — NC

AnaRita Eason
Olin Corporation — AL
Jim Brown
1 - ... r .
. ^ w
First Chemical Corp. — MS
Donald Scharr, P.E.
Miles, Inc. — SC
Martin Healy
Dave Willis
3:45-4:15
Morton International, Inc.
— MS
Joseph J. Magazzu
Monsanto Chemical Co. —
AL
Leslie L. Herd, P.G.



Adjourn


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Groundwater Remediation/S^bilization Conference
December 1 \ 1993
Atlanta, vj A
| Friday
3
Room
Facility/Presenter
Speaker
*
3:00 , .M.
Ballroom
Welcome and Introduction
Douglas C. McCurry - Moderator
8:15-9:45
"
Groundwater Remediation: Past Performance and
Alternative Approaches
Douglas M. Mackay, Ph.D.
John A. Cherry, Ph.D.
9:45-10-00
Break


10:00-11:00
n
Subsurface Cleanup and Mobilization Processes Research at
RSKERL
Stephen G. Schmelling, Ph.D.
11:00-12:00
11
In-situ Bioremediation Field Research
John T. Wilson, Ph.D

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NOTEBOOK INDEX BY ORDER
OF PRESENTATION
1
Day/a.m.
or p.m.
Facility/Topic
Speaker
Index
Tab 1
Wed/a.m.
Geraghty & Miller, Inc.
Gregory Rorech, P.E.
8

GTE Communications
Systems Corp.
Harch S. Gill, Ph.D.
10

Kaiser Aluminum &
Chemical Corp.
Paul Maasen
13

NASA, Kennedy Space
Center
John Ryan
20

Berkeley Mills, Kimberly
Clark Corp.
Steve McFadden
3
Wed/p.m.
Martin Marietta Energy
Systems, Inc. (DOE)
Jeff W. Douthitt
Bruce E. Phillips
16

BFGoodrich Company
Christian J. Orsborn
4

Torrington Company
David Carl Cromwell
26

Kerr-McGee Chemical Corp.
Nicholas Bock
14

International Paper
Michael Simms
12

Occidental Chemical Corp.
inda McConnell, P.E.
21

CYTEC Industries
William McElroy, P.E.
Neale Sharitz
6
Thurs/a.m.
Non-Aqueous Phase Liquids
David Kreamer
36
rhurs/a.m.
Session 1
Lockheed Aeronautical
Systems Co.
Rochelle Routman, "P.G.
15

ThermalKEM
Alice B. Clark
25

Radiator Specialty Co.
Richard Harmon, P.G.
Christopher C. Cutler
23

Westinghouse Savannah
River Company (DOE)
Chris Bergren
27
Thurs/p.m.
Session 1
Beazer East, Inc.
William D. Wood, Jr.
Mitchell D. Brourman
2

Sanders Lead Company,
Inc.
E. Roy Baggett, M.S.
Mark Hobbs
Chris Rutherford, P.G.
24

AZS Chemical Corroration
Tushar E. Talele
1

IBM
AnaRi"~ Eason
11

First Chemical C
Hona' ~ S-harr, P.E.
7

Morton International,
Inc.
"os3j. J Magazzu
1
19

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NOTEBOOK INDEX BY ORDER OF PRESENTATION
Day/a.m.
or p.m.
Facility/Topic
Speaker
Index
Tab
Thurs/a.m.
Session 2
Ciba-Geigy
Thomas F. Siple
Patrick K. Hallett
31
GNB Battery Technologies
Tom Minner
Ray Graves
Frank Barnett
9
Chevron, USA, Inc.
H. James Reisinger
Perry Hubbard, Jr.
Stewart A. Mountain
Charles W. Brigham
5
Gold Coast (CERCLA)
Brad Jackson
33
Thurs/p.m.
Session 2
North Carolina State
University (UST)
Robert C. Borden
28
State of North Carolina
Department of
Environment, Health &
Natural Resources
(UST)
Burrie vD. Bophcff
29
CERCLA Groundwater
Remediation
Ken Mallary
Glenn Boylan
32
Olin Corporation
Jim Brown
22 v
Miles, Inc.
Martin Healy
Dave Willis
17
Monsanto Chemical Co.
Leslie L. Herd, P.G.
18
Fri/a.m.
Groundwater Remediation:
-Past Performances and
Alternative Approaches
Douglas M. Mackay
John A. Cherry
30
Subsurface Cleanup and
Mobilization Processes
Research at RSKERL
Stephen 0. Schmelling,
Ph.D.
34
In-situ Bioremediation
Field Research
John T. Wilson, Ph.D.

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TECHNICAL REFERENCES
STABILIZATION CONFERENCE COURSE NOTEBOOK
.'A 904/6-88-001
October 1988
EPA/540/G-88/003
December 1988
EPA/540/2-89/054
February 1989
EPA/5402-89/054
February 19 89
EPA/540/2-89/054
February 1989
"-PA/540/4-89/004
yjgust 1989
fc.t'A/ 540/4-90/053
EPA/540/4-89/003
August 1989
EPA/540/4-89/005
October 1989
EPA/625/6-90/016a
September 1990
EPA/540/2-90/018
November 1990
EPA/600/M-90/023
/ember 1990
Application of Dye-Tracing Techniques for Determining
Solute-Transport Characteristics of Ground Water in Karst
Terranes
Guidance on Remedial Actions for Contaminated Ground
Water at Superfund Sites
Evaluation of Ground Water Extraction Remedies, Vol 1.
Summary Report
Evaluation of Ground Water Extraction Remedies, Vol 2.
Case Studies
Evaluation of Ground Water Extraction Remedies, Vol 3.
General Data Survey Reports
EPA Superfund Ground Water Issue: Contaminant
Transport in Fractured Media: Models for
Decision Makers
EPA Ground Water: Basic Concepts of Contaminant
Sorption at Hazardous Waste Sites
Superfund Ground Water Issue: Facilitated Transport
EPA Ground Water Issue: Performance Evaluations of Pump
and Treat Remediations
Handbook Ground Water, Volume 1: Ground Water and
Contamination
EPA-Issue: A Guide to Pump and Treat Groundwater
Remediation Technology
EPA Environmental Research Brief: Colloidal-Facilitated
Tr nsport of Inorganic Contaminants in Ground Water:

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Page Two
Reference List
Stabilization Conference Notebook
EPA/540/4-91/002
March 1991
EPA/625/6-90/016b
July 1991
EPA/600/M- 91/040
July 1991
EPA/540/8-91/014
November 1992
EPA/540/S-92/017
Jan. 1992
EPA/540/S-92/002
Jan. 1992
EPA/540/S-92/001
Jan. 1992
EPA/540/S-92/003
Feb. 1992
EPA/600/R-92/030
Feb. 1992
EPA530B-92-003
April 1992
EPA530-B-92-001
June 1992
EPA Ground Water: Dense Nonaqueous Phase Liquids
Handbook Ground Water, Volume 2: Methodology
EPA Environmental Research Brief: Colloidal-Facilitated
Transport of Inorganic Contaminants in Ground Water:
Part I. Colloidal Transport
Compendium of Superfund Program Publications, 1992
EPA Summary Paper: In-Situ Bioremediation of Ground
Water.
EPA Ground Water Issue: TCE Removal from Contaminated
Soil and Ground Water.
EPA Ground Water Issue: Chemical Enhancements to
Pump-&-Treat Remediation
EPA Ground Water Issue: In-Situ Bioremediation of
Ground Water.
Dense Nonaqueous Phase Liquids - - A Workshop Summary
Dallas, Texas [April 16-18, 1991]
Compendium of ORD and OSWER Documents Relevant to
RCRA Corrective Action
Catalogue of Hazardous and Solid Waste Publications,
Sixth Edition
EPA 9902.3-la
July 1992

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-¦age Three
Reference List
abilization Conference N#£ebook
EPA/540/S-92/019 EPA Guidance: Potential Sources of Error in
August 1992	Groundwater Sampling at Hazardous Waste Sites
Publication 9200.7-021	Superfund and Enforcement Program Publications
PR881-A, August 1992	Update
EPA/600/K-93/003 Seminar on Characterizing and Remediating Dense
May 1993	Nonaqueous Phase Liquids at Hazardous Waste Sites
Kruseman, G.P.	Analysis and Evaluation of Pumping Test Data
DeRidder, N.A.
William C. Walton Practical Aspects of Groundwater Modeling
Consultant
VWA	Geophysical Techniques for Sensing Buried Wastes and Waste
Migration, 1988, Benson, R., Galccum, R. A., and Noel, M. R.,
Technos, Inc.
Mackay, Douglas M., Roberts, Paul V., Cherry, John A., "Transport of Organic
Contaminants in Groundwater: Distribution and fate of chemical in sand and
gravel aquifers," Environmental Science and Technology. Vol 19, No. 5, 1985,
pp. 384-392.
Mackay, Douglas M., Cherry, John A., "Groundwater Contamination: Pump and
Treat Remediation," Environmental Science and Technology. Vol 23, No. 6,
1989, pp. 630-636.
Spreizer, G. M., Maxim, D., Valkenbury, N., and Hauptmann, M., "How Flat is
Flat? - Termination of Remedial Groundwater Pumping," Ground Water and Vadose
Zone Monitoring. ASTM STP 1053, D.M. Nielsen and A.I. Johnson, Eds,.,
American Society for Testing and Materials, Philadelphia, 1990, pp. 247-255.
Hasbach, Anne, "Moving Beyond Pump-and-Treat," Pollution Engineering. March
15, 1990, pp. 36-39.
v»ey, Jennifer L.; Hanson, Bill; Enfield, Carl and Glass, John, "Evaluating
"Tne Effectiveness of Ground Water Extraction Systems, " Groundwater Monitoring

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Page Four
Reference List
Stabilization Conference Notebook
Hoffman, F. 1993. Ground-water remediation using "smart pump and treat."
Ground Water, vol. 31, no. 1:98-106.
Wekhof, A., E. N. Folsom, Jr., and Y. Halpern. 1992. Treatment of groundwater
with UV flashlamps: the third generation UV systems. Hazardous Materials

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An Overview of the Groundwater Remediation Program at
the A2S Chemical Corporation Site in Atlanta, Fulton County, Georgia
Maurizio F. Giabbai, President
TllShar E. Talele, Senior Engineer
Stephen Marks, Professional Geologist
HazLabs Incorporated
A Division of HazWaste Industries Inc.
Marietta, Georgia
November 1993
Site Background
The AZS Chemical Corporation Site, located in Atlanta, Fulton County, Georgia, is the site of a former
specialty organic chemical manufacturer, operating from the early 1900's to the mid-1980's. The types of
chemicals produced have varied throughout the history of the plant. The site consists of five former
processing waste ponds, which have been closed as two hazardous waste management units (HWMUs),
which are associated wiith an ongoing onsite groundwater remediation program.
Groundwater monitoring wells were installed during a remedial investigation, and during closure and post
closure of the two HWMUs to monitor the regulated compounds found in the underlying aquifer.
Uncontaminated, upgradient wells were installed for each of the HWMUs to establish background
concentrations. The other wells were placed at strategic locations and installed at varying depths to insure
that the extent of the groundwater contamination could be determined and monitored. Some locations
contain a single well, while other locations contain clusters of two of three monitoring wells. Typically, when
a location contains a cluster of Vvells, one was installed in the overlying soil jurden, one was installed in
the weathered bedrock, and the other, if three are present, was installed at the interface of the two zones.
A plume configuration based on the groundwater quality data collected during the remedial investigation was
constructed utilizing three indicator compounds: 1,2-dichloroethene, methyl isobutyl ketone, and xylene.
Figure 1 depicts all three compound plumes as they were positioned on site in 1988.
The site, located in the Piedmont Province is relatively steep and exhibits a considerable hydraulic gradient
that provides the energy for groundwater flow. The material is underlain by an impermeable bedrock of
granitic gneiss and biotitic gneiss. The upper aquifer of the AZS site consists of both soil and weathered
bedrock zones which range in depth from very thin to approximately fifty (50) feet. Permeability tests
conducted on selected monitoring wells revealed that permeability varies considerably within the
unconsolidated portion of the aquifer. The permeability of the soils is in the range of 1 x 10"6 cm/sec to 1
x 10"6 cm/sec. The permeability of weathered bedrock ranges from 1 x 10'3 cm/sec to 1 x 10"4 cm/sec. This
considerable difference in permeability means that groundwater flows more easily along the weathered
bedrock interface than it flows in the overlying soils. Figure 2 depicts the direction and nature of the
apparent groundwater flow (potentiometric surface) across the site.
Groundwater Remediation Program
AZS Corporation in Atlanta, Georgia was issued a hazardous waste facility permit from the Georgia
Environmental Protection Division (GAEPD) on September 30, 1987 for post-closure care and corrective
action of the HWMUs which included the remediation of the associated groundwater. The groundwater
corrective action program at the AZS site consists of four groundwater recovery wells, screened into the
weathered bedrock, and a groundwater treatment plant (GWTP). A single recovery well is located at the
smaller of the HWMUs, while three recovery wells are located downgradient from the larger HWMU area.

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HAZARDOUS WASTE
MANAGEMENT unit
(POLYMER POND)
legend
EXISTINC UONITORINC WEL
| j XYLENE
UETHYl ISOBU7YL KETONE

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in March 1990 and the estimated plume of contamination, it appears that the recovery system as designed
effectively contains the contaminated groundwater.
The process train of the GWTP consists of: 1) An equalization tank for blending the groundwater pumped
from each recovery well, 2) Chemical precipitation operations for trace metals (eg. nickel) removal, 3)
Physical filtration for suspended solids removal, 4) Carbon adsorption for organic contaminant removal, and
5) Sludge dewatering via filter press operations. The treated groundwater is discharged to the City of
Atlanta sewer system under a permit with the City of Atlanta. The spent carbon and dewatered chemical
sludge are disposed of at an EPA-approved hazardous waste landfill. The groundwater recovery and
treatment system has been in operation continuously to effectively control the plume of contamination and
potentially accelerate clean-up of the subsurface and groundwater. The present flow capacity of the GWTP
(30 gpm) is sufficient to meet additional flow requirements from the recovery wells.
Current Status of the Groundwater Remediation Program
Figure 3 presents the plume for the three indicator compunds that remain within the site boundary. The
effects of gravity (ie. topographic effects) and the pumping have significantly reduced the size of the three
indicator plumes on site. In the area of the smaller HWMU, the subsurface rock forms a bowl in the center
of which the recovery well is situated. This recovery well appears to adequately drain the groundwater
reservoir associated with this HWMU. Recent groundwater monitoring data in the vicinity of this HWMU
indicates that contaminant concentration levels are approaching the detection limits, and that there is very
little groundwater contamination remaining. Additionally, analytical data from wells downgradient of this area
have indicated no detectable groundwater contaminant levels.
Groundwater quality data for the vicinity of the other HWMU and results of groundwater flow and solute
transport modeling effort indicate a possible tendency for contaminated groundwater flow to concentrate
in the weathered bedrock zone. This HWMU is situated within these natural drainage pathways. Recovery
wells were installed along the boundary of the site so that the cone of depressions created by pumping from
these locations captured any groundwater contamination before potentially migrating away from the site.
HazLabs is currently working with mathematical models and evaluating the possibility that the cones of
depression are indeed not concentric but rather semi-conal in shape and therefore possibly leaky. The
models seem reasonable given the steep surface and subsurface topography situated along the western
boundary of the site.
Future Activities
Based on current groundwater monitoring data and groundwater modeling results, a three-phased program
for placement of off-site groundwater monitoring wells has been developed in order to verify any off-site
groundwater impacts. In order to optimize the locations of these wells, a geostatistical approach was utilized
which integrated all the necessary mathematical model data for analysis of the known data. The primary
objective for the geostatistical analysis was to determine whether the proposed locations of the off-site
monitoring wells would give good representation and coverage to facilitate the monitoring and
documentation of the migration of potential groundwater contaminant plumes. The results of the analysis
indicated that the proposed off-site Jccations would provide a good coverage of the area, and an
approximately equal confidence level for each monitoring well. Upon regulatory approval of the Off-site
investigation plan, HazLabs will initiate the installation of the new proposed off-site wells.
A three-dimensional groundwater modelling effort is currently underway to develop a predictive tool for
current contaminant flow characteristic:,. Ti e results of this modelling effort will be combined with a risk

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Tushar E. Talele
Mr. Tushar Talele is a Biochemical Engineer with HazLabs Incorporated, a division of
HazWaste Industries, located in Marietta, Georgia. As the Project Manager, Mr. Talele
directs all activities associated with the AZS Chemical Corporation Site remediation
program, With degrees In both Microbiology and Chemical Engineering, Mr. Talele
currently serves as a Senior Remediation Engineer responsible for the research,
development, and commercialization of Innovative remedial technologies with an
emphasis on biotechnology applications. His experience includes evaluating the fate
and transport of subsurface contaminants, development and Implementation of bench
and pilot-scale treatability and feasibility evaluations, detailed design and
implementation of pilot and full-scale comprehensive site restoration strategies, and
direction of quality assurance programs, Experience with specific key technologies
include in situ bloremedlation, air sparging, bioventing, biological and physicochemical
wastewater treatment, and above-ground soil biotreatment. Projects which Mr. Talele
has directed include soil and groundwater remediation projects under both RCRA and

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LIST OF ATTACHMENTS
AND ASSOCIATED INFORMATION
Presentation Title:	Hydraulic Containment of Groundwater at an Active
Wood Treating Facility, South Carolina, Operation and
Maintenance Considerations or the Twice a Week
Tweak
Presenters:	William D. Wood Jr., Chester Environmental
Mitchell D. Brourman, Beazer East, Inc.
Presentation Abstract
Presentation Summary
Qualification Statements For:	William D. Wood Jr.
Mitchell D. Brourman
CHESTER

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ABSTRACT
Case Study: Hydraulic Containment of Groundwater at an Active Wood Treating
Facility, South Carolina, Operation and Maintenance Considerations or the Twice
a Week Tweak
Koppers Industries, Inc. operates an active wood treating facility in Florence, South
Carolina. The Florence facility is located within the Atlantic Coastal Plain
physiographic province approximately 75 miles northeast of Columbia, South
Carolina. Wood products have been treated with creosote, pentachlorophenol, and
copper chromated arsenic at the facility for over forty years. Groundwater beneath
the facility has been impacted by wood treating operations and is being addressed as
part of an ongoing RCRA Facility Investigation/Corrective Measures Study
(RFI/CMS). Additionally, an interim measures (IM) groundwater containment
system was placed in operation at the facility in April 1988. The system consists of
14 groundwater pumping wells designed to prevent the off-site migration of
constituents in the upper-most water bearing unit. Decreased specific capacity of
the containment wells, evidence of biological growth and scale on the system
hardware and corrsosion of the hardware indicated that the system required
maintenance and repairs. During late 1992 and early 1993, the containment wells
were both physically and chemically redeveloped, mechanical repairs and
modifications were performed, system testing was performed and the systems'
operation and maintenance manual was ammended. System testing served two
objectives: 1) it was used to evaluate the effectiveness of the redevelopment and
mechanical modification program and 2) it was used to develope a set of baseline
data with which to compare the results of future testing. The results of the testing

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CASE STUDY:
HYDRAULIC CONTAINMENT OF GROUNDWATER AT AN ACTIVE
WOOD TREATING FACILITY, SOUTH CAROLINA; OPERATION AND
MAINTENANCE CONSIDERATIONS OR THE TWICE A WEEK TWEAK
By: William D. Wood, Jr., Rhonda Hakundy-Jones, Mitchell D. Brourman and
Dale Foster.
1.0 BACKGROUND
Koppers Industries, Inc. is presently operating a wood treating facility in Florence,
South Carolina approximately 60 miles northwest of Myrtle Beach, South Carolina and
75 miles northeast of Columbia, South Carolina (Figure 1). The facility produces
pressure treated utility poles, railroad ties, and dimensional materials for the utilities,
railroad and construction industries. The poles, ties and lumber are treated with
pentachlorophenol, creosote and copper chromated arsenic for wood preservation. The
facility has been in operation since 1946. In December 1988, Koppers Company, Inc.
sold the Florence, South Carolina wood treating facility to Koppers Industries, Inc.
Pursuant to this transition, Koppers Company, Inc. retained certain environmental
liabilities at this wood treating facility. In 1990, Koppers Company, Inc. changed its
name to Beazer East, Inc.
The Florence facility is situated in the Atlantic Coastal Plain physiographic province.
Hence, the site topography is relatively flat with a total of approximately five feet of
relief. This facility is surrounded by a combination of industrial, commercial,
agricultural, residential, and transportation land uses, along with undeveloped areas.
As a result of facility operations, the groundwater beneath the facility has been
impacted with constituents associated with wood treating. The groundwater is being
addressed as part of an ongoing RCRA Facility Investigation/Corrective Measures
Study (RFI/CMS) pursuant to a Resource Conservation and Recovery Act (RCRA)
3008(h) Consent Order. To mitigate the migration of constituents off-site, an Interim
Measures (IM) groundwater containment system was placed in operation in April 1988.
Florence
vJi'MO-iu) CB/DCC.rM0139 10/V3
CHESTER

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PARfilS
ISLAM
45 30

CHESTER
ENVIRONMENTAL
FIGURE 1
REGIONAL LOCATION MAP
K0PP£flS INDUSTRIES, INC.
FLORENCE. SOUTH CAROLINA

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The system consists of 14 pumping wells situated along the downgradient property
boundaries (Figure 2). Groundwater recovered from the wells is treated at an onsite
treatment facility and discharged to the local Publicly Owned Treatment Works
(POTW).
2.0 SITE HYDROGEOLOGY
The facility is underlain (in descending order) by the Black Creek and Middendorf
Formations. Four lithologic zones and two water-bearing zones have been identified
beneath the Florence Facility (Figure 3). These zones or units are defined as follows:
Upper Water-Bearing Unit - The uppermost soil is a clayey silt unit which is
approximately 20 feet thick across the site. Locally this unit grades to clayey fine sand
or silty clay. This unit is continuous across the site and can be recognized by its
characteristic yellowish orange, red, and grey mottling. Thin clay or fine sand lenses
occur locally.
Beneath the clayey silt unit is an interval of fine to coarse sand 30 to 40 feet thick.
This unit generally coarsens downward. In several areas of the facility, large lenses of
plastic grey clay to sandy clay extend from approximately 20 to 40 feet below ground
surface. The occurrence of the grey clay lenses is most pronounced in the western to
northwestern sections and in the east and southeast sections of the facility. These clay
lenses become thin or are absent in the central and south central area of the facility. In
localized areas, these clay lenses act as a confining unit.
Confining Unit - Immediately underlying the sand unit is a laterally continuous unit of
dense, dark grey to black clayey silt or silty clay. This unit is approximately 10 to 20
feet thick beneath the facility. This unit is organic rich and may contain thin sand or
silt lenses locally.
Lower Water-Bearing Unit - The confining clay unit overlies a fine sand to silt unit
with occasional lenses of coarse sand. Dense black clay lenses of variable thickness
occur at several locations where this unit has been examined. The clay lenses are
similar in appearance to the overlying confabs black clay. Occasional lignitized wood
Florence
QHMO-100 CB/DCCm0139 10/93
CHESTER

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B
WEST
ISO —
z
o
Sir
14 0 —
130 —
120 —
110 ¦
100 —
90 —
30 ¦
B04-1D
B91-30
P-4B
P-5B
B'
EAST
P-6B
- -iptes TAKEN BETKEEH SO' ANO -¦10' DEPTHS
r'vrcATE ALTE/vurms la/ebs of sam) aw
CLAY IN VAAIA3LE THICKNESSES,
CLAf AMI SAND
-50 —
-uO —
-70 .
SANO
CLAY
SAW
B91-4B
o	200	400
VERTICAL EXAGSERAT1 OH 20*
-N CROSS SECTION LOCATION
\
'.V
NOTES:
B91-2B - HELL DESIGNATION
II - SCREENED INTERVAL
61.5' - TOTAL DEPTH OF BORING
THIS CROSS SECTION DEPICTS SUBSURFACE CONDITIONS AT LOCATIONS
SMHN BASED ON SITE INVESTISATIONS. SUBSURFACE CONDITIONS AT
OTHER LOCATIONS HAY DIFFER FROM CONDITIONS OCCURINS AT THESE
SITES.
CHESTER
ENVIRONMENTAL
FIGURE 3
GEOLOGIC CROSS SECTION
EAST-WEST
KOPPERS INDUSTRIES. INC.
FLORENCE. SOUTH CAROLINA

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fragments, several centimeters in diameter, have been recovered in soil samples
collected from this interval. This unit is approximately 75 feet thick, extending to an
approximate depth of 150 feet below the ground surface.
Groundwater flow in the upper water-bearing unit is influenced by a topographic and
potentiometric high in the central and northern portion of the facility and primarily
flows to the southwest and southeast away from a groundwater divide (Figure 4).
Groundwater flow in the lower water-bearing unit is primarily to the west.
3.0 GROUNDWATER CONTAINMENT SYSTEM
Objectives and Installation:
The purpose of the groundwater containment system at the Florence facility is to
prevent potentially impacted groundwater in the uppermost water-bearing unit from
migrating off-site.
As a result of design studies, it was determined that groundwater containment or
hydraulic gradient control could be accomplished by lowering the water table
immediately upgradient of the facility boundaries by approximately one foot. To
produce the required water table drawdown, 14 pumping wells were installed along the
downgradient facility boundaries in a stepwise manner. Each well was installed and
then subjected to a short term pumping test. Distance drawdown projections, based on
the pumping tests, were then used to determine the location of the next adjacent well
or wells. The pumping tests also indicated that an approximate pumping rate of five
gallons per minute (gpm) would produce the required drawdown. In this way, actual
field conditions were used to determine the system configuration and pumping rates.
Containment Well Construction and Operation:
The containment wells were constructed with four-inch stainless steel screens which
were installed from approximately five feet below the ground surface (bgs) to the upper
surface of the confining unit. The surface of the confining unit varies from
approximately 40 to 60 feet bgs ^ oss f-; facility. Chree-foot long sumps extend
Florence

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APPROXIMATE LOCATION
APPROXIMATE
PROPERTY BOUNDARY
legend
+ - MONITORING WELL
O " PIEZOMETER NEST
(ABO.) - AB4NOONEO MONITORING HELL
•DIRECTION OF GROUNDWATER FLOW
B84-2A
FIGURE 4
GENERALIZED GROUNDWATER
FLOW CHARACTERISTICS
KOPPEflS INDUSTRIES. INC.
FLORENCE. SOUTH CAROLINA

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below the screened portions of the wells into the confining unit and were installed to
collect sediment and to potentially collect dense fluids (Figure 5).
Groundwater is recovered from each of the wells using a shallow well centrifugal
pump. Piping at each wellhead is equipped with a flow sensor, an analog gauge, and a
flow totalizer (Figure 6). Additionally, the wellhead piping is fitted with several
testing pons to allow for the collection of pressure and vacuum data. Recovered
groundwater is conveyed to the onsite biological wastewater treatment plant through
underground piping.
The groundwater containment system includes a series of piezometers and monitoring
wells used to monitor groundwater elevations and conditions in the vicinity of the
containment wells (Figure 2).
Operation and Maintenance
After nearly five years of continual operation, system monitoring suggested that a more
aggressive system evaluation was necessary. Well performance data indicated that the
specific capacity of several of the wells had declined resulting in greater than desired
drawdown. During repair activities, globs of slimy biological growth were removed
from inside the suction and wellhead piping. Additionally, during regular wellhead
piping inspections, corrosion was observed on the exterior of the piping and iron
encrustation on the interior of the piping.
During late 1992 and early 1993, several tasks were undertaken to improve the
efficiency of the containment system. These included:
¦ The wells were physically and chemically redeveloped to remove the
biological growth, iron encrustations and sediment which were limiting
the effective inside diameters of the suction pipes and may have led to
clogging of the well screens, the adjacent filter packs and the native
formation surrounding the wells.
Florence
QHMO-lOO CB/DCCn IC '¦ '	4-	-4 HESTEF

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TO GROUNDWATER PUMP
UPPER
WATER
BEARING
ZONE
CONFINING
LAYER

BENTONITE SEAL
4" STEEL RISER
•4" DIA. STAINLESS STEEL SCREEN
-SAND PACK
STAINLEES STEEL SUCTION PIPE
4" DIA. STEEL SUMP
BENTONITE SEAL
FNV' ^ N/1E' TAL
FIGURE 5
TYPICAL WELL CONSTRUCTION
GROUNDWATER CONTAINMENT SYSTEM

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WARNING
LIGHT
a
1" GALVANIZED
V5
r r.
¦T7ED
,--1/., RED:
I
1-1/4" STEEL-
liJOT TO SCALE)
LEGEND

W
1-1/4" BALL VALVE
W
1/2* BALL VALVE
—
1" PLUG
Q
1/4" QUICK DISCONNECT
M
1" BUTTERFLY VALVE

1" CHECK VALVE
I ¦ : : l NORMAL FLOW PATH
1-1/4" SS HELL SUCTION PIPE
SUCTION PIPE SUPPORT FLANGE (STEEL)
4" STEEL CASING
FIGURE 6
TYPICAL WELLHEAD PIPING DETAILS
CHESTER
ENVIRONMENTAL
FLORENCE. SC
5/26/93

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¦ The original, corroded black steel wellhead piping was replaced with
galvanized steel piping which is expected to resist corrosion and iron
precipitation.
¦
Testing ports were added to the new wellhead piping to provide a means
of performing pressure and vacuum testing.
The Operation and Maintenance Manual was amended to include
specifications for the newly installed system hardware, newly developed
maintenance procedures and testing protocols.
The redevelopment, chemical treatment, and mechanical modifications involved
approximately six weeks of field work. These procedures are further described in the
following sections.
4.0 PHYSICAL REDEVELOPMENT
Physical redevelopment was intended to remove the fme sediment, biological growth
and iron precipitate which had accumulated in the wells screens and filter packs and
included:
The initial step in the physical redevelopment process involved bailing the sediment
from the sumps at the base of the wells. A large bottom-filling bailer was lowered into
the sumps, allowed to fill with sediment and water, and pulled back to the surface.
The check valve on the bottom of a bottom-filling bailer allows fluids to flow into the
bailer but prevents outflow.
Total well depth measurements taken before and after bailing indicated that sediment
had accumulated to thd -sses of between one and two feet in the majority of the
¦
¦
~
Bailing,
surging and swabbing,
high pressure jetting, and
pumping.
Florence

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sumps. Examination of the recovered sediment indicated, that it included varying
amounts of a scaley iron oxide precipitate. The majority of the precipitate was most
likely rust and scale dislodged from the suction piping and upper well casing.
Following bailing, the well screens were cleaned with a swabbing tool designed to
remove heavy biological growth and mineral encrustations. The swabbing tool was
made up of wire brushes and rubber discs with a pumping intake port located midway
between the rubber discs (Figure 7). The wire brushes were intended to remove any
mineral deposits or heavy biological growth whereas the rubber discs were intended to
produce a surging action by forcing water in and out of the well screen and adjacent
filter pack. Additionally, the discs acted as an isolation mechanism to concentrate flow
through limited sections of the well screen during pumping. Pumping was
accomplished by attaching the suction line of an auxiliary pump to the upper end of the
piping used to raise and lower the swabbing tool. During the physical redevelopment
procedures, the swabbing tool was repeatedly raised and lowered inside each well to
loosen and remove the foreign matter attached to the interior of the well screen. When
the swabbing tool was removed from the wells, gobs of white and orange translucent
matter was observed clinging to the tool.
Swabbing was followed by high pressure horizontal jetting of the well screens. Jetting
was intended to remove deposits from the well screens and sediment fines from the
adjacent filter packs and native formation by spraying pressurized water horizontally
into the screens. The water jetted into the wells was forced back to the surface and
discharged to a tank through a "T" fitting attached to the top of each well casing.
Initially, the return water was very turbid; containing fine sediment (very fine sand,
silt, and clay) and iron scale particles. The jetting of each well was continued until the
return waters contained only small amounts of sediment. Generally, several thousand
gallons of potable water were required to jet each well.
At the conclusion of jetting, a suction line was lowered into each of the sumps and
water containing sediment and scale was pumped from the wells.
Florence
QHMO-100 CB/DCC?M0139 10/93
-6-
CHESTER

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i
4" DIA.	A' DIA.
(NOT TO SCALE)
OWN BY:
CHK'D BY.
APPfl BY:


FIGURE 7
~HS NO.
AMA
NOW


CHESTER
WELL REDEVELOPMENT SWABBING TOOL
C69791
file name
SCALE
~ATE
10/14/93

ENVIRONMENTAL

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5.0 CHEMICAL TREATMENT
Chemical treatment was performed to dislodge the persistent biological growth and iron
precipitate which remained following the physical redevelopment process. Chemical
redevelopment involved treating the wells with hydroxyacetic acid to reduce the
accumulated iron oxides in the wells and to break down and kill the biological growth
in and adjacent to the wells. Biological growth had been observed in a number of the
wells and samples of the same growth was collected and analyzed microscopically by
Chester. The analyses indicated that the growth consisted of iron bacteria and a
filamentous fungi. Both iron oxide precipitation and biological growth (bacterial and
fungal) are commonly associated with reduced groundwater recovery rates from water
wells in the southeastern United States.
Chemical treatment was initiated by adding 70 percent hydroxyacetic acid to each well
until the pH of the standing water in the wells was approximately 2.0 standard units
(SU). The available literature indicates that this pH is necessary to breakdown and kill
organic growth and prevent the dissolved iron from reprecipitating. After between 12
and 24 hours, the screened intervals in each of the wells were swabbed by slowly
raising and lowering the swabbing tool. Simultaneous swabbing and pumping was
initiated at the bottom of each well. The swabbing tool was moved upward at 10-foot
increments until the water recovered from each swabbed increment was clear,
sediment-free^ and the pH of the water was raised to between 3.0 and 4.0 SUs. The
groundwater pumps were then reconnected and allowed to pump at their maximum
rates for approximately 24 hours to ensure that the pH stabilized to the normal range of
between 4.0 and 5.0 SUs.
6.0 MECHANICAL REPAIRS AND MODIFICATIONS
Following well redevelopment, the original black steel well head piping and suction
piping were replaced with galvanized and stainless steel piping, respectively.
Because the exterior of the original black steel wellhead piping was corroded and the
interior was encrusted with iron precipitate, it was replaced with galvanized steel pipe.
Additionally, three quick-conne ~ - ttings were incorporated into the piping design to
Florence
QHMO-100 CB/DCC#M0i:
¦* CHESTER

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allow for periodic pressure and vacuum testing. A one inch butterfly-type flow control
valve was also installed on the wellhead discharge piping to regulate the groundwater
recovery rate. The resulting typical wellhead piping arrangement is presented in
Figure 6.
Because the removal and evaluation of several of the original black steel suction pipes
indicated that pitting and iron encrustation had begun to occur, the suction pipes and
associated footvalves were replaced with new stainless steel piping and valves.
Additionally, because there were indications that dense fluids had collected in several
of the well sumps, the replacement suction pipes were lengthened to extend into the
sumps, thus allowing enhanced dense fluid recovery.
7.0 SYSTEM TESTING
The containment system was tested following the completion of the redevelopment and
mechanical modification tasks to meet two objectives:
¦	to determine the effectiveness of the redevelopment and mechanical
modification program, and
¦	to establish a set of baseline data with which to compare the results of
future testing events.
The specific types of tests performed on the containment well system included specific
capacity testing and pressure/vacuum testing.
Tre specific capacity of a well is a measure of the well's efficiency to produce water.
The specific capacity of a well is defined as the pumping rate of the well divided by the
drawdown (or change in the groundwater elevation in the we!1) which occurs as a result
of pumping at the given rate. Specific capacity is most conmonly expressed as gpm
per foot of drawdown (gpm/foot). Specific capacity testing was performed by
measuring the groundwater elevations in each of the containment wells during both
pumping and nonpumping conditions to determine the amount of drawdown due to
pumping.
Florence
QHMO-lOO CE,DCC^:0!39 10/',
JpV CHESTER

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Pressure and vacuum testing were accomplished by isolating specific components of the
wellhead piping and the conveyance piping system to determine whether any blockage
or leakage was occurring (Figure 6). Pressure testing was performed for the evaluation
of both the conveyance piping and for each groundwater pump. Conveyance piping
pressure testing was intended to identify potential problems related to: 1) pipeline
blockage (higher than baseline pressures) caused by mineral precipitation or physical
damage to the piping and 2) pipeline leakage (lower than baseline pressures) caused by
pipeline damage. Additionally, vacuum testing measurements from the groundwater
pump suction line were compared to groundwater levels in the wells and to the suction
lift required to raise the water in the suction pipes to the pumps. High or low vacuum
readings relative to the required suction lift indicates potential suction pipe blockage or
leakage of air into the suction piping. The vacuum determinations provide a method to
evaluate the suction piping and associated footvalve without removing the suction
piping from the well for inspection.
The results of the testing indicated that the redevelopment, chemical treatment, and
mechanical improvements to the system were effective and that the system is
functioning as designed. The redevelopment and chemical treatment procedures
resulted in increases in the specific capacities of the wells relative to specific capacity
determinations performed prior to the redevelopment program. Piping replacement
reduced the__total dynamic operating pressures within the pumps and piping. The
installation of butterfly-type flow control valves has allowed enhanced flow rate
adjustment.
8.0 DEVELOPMENT OF SYSTEM MONITORING PROCEDURES
Having established a set of baseline data for the containment system, a regular
monitoring and testing program was developed. Table 1 presents a list of the routine
inspection and testing activities which are part of this program.
As indicated on Table 1, to ensure the proper functioning of the containment system on
a daily basis an onsite operator records the flow rates and totalizer readings at each of
the wells several times a week. At the time of making these recordings, the operator
Florence
QHMO-100 CB/DCC#M0139 10/93
-9-
Sfo CHESTER

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1
OPERATION AND MAINTENANCE PROCEDURES
SCHEDULE AND RATIONALE
GROUNDWATER CONTAINMENT SYSTEM
FLORENCE, SOUTH CAROLINA

Maintenance and
Testing Activity
Approximate
Frequency
Rationale

Pro imitation Measuremenls
Daily
Allows correlation of precipitation data
with water levels, pumping rates, and
drawdown

Fk)\v Rate and Totalizer Readings
Biweekly
Assures proper system function

Pump Inspection
Weekly
Assures proper pump operation and allows
timely maintenance

Water Level Measurements
Bimonthly
Identifies potentially excessive drawdown

Flow Meter Testing
Bimonthly
Assures accurate flow determination

Conveyance Piping Inspection
Monthly
Evaluates pipe integrity

Well Specific Capacity Testing
Quarterly
Identifies and quantifies potential
decreases in well efficiency

T ' 1 /ell Depth Measurements
Quarterly
Quantifies sediment accumulation

NAPL Product Thickness Measurements
Quarterly
Identifies potential NAPL presence

Pressure/Vacuum Testing
Quarterly
Identifies and isolates potential pump and
piping problems

Pump Overflow Boxes and Pick-up Screen
Annually
Prevents introduction of debris to pump
and piping

Groundwater Sample Collection
Annually
Quantifies groundwater chemistry

Conveyance Piping Hydrostatic Pressure Testing
Annual (or as Needed)
Evaluates pipe integrity
ix
a m
Well Redevelopment/Chemical Treatment
As Indicated
Improves well efficiency
153
5 H
5m
Electrical Testing
As Indicated
Identifies potential electrical problems
Florence

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also frequently: 1) adjusts the groundwater recovery rates to account for equipment
performance and water table fluctuations, and 2) cleans the flow sensors to ensure
accurate flow determination.
In the near term, newly-acquired test data will be compared to the baseline data and
maintenance operations will be performed when variances from the baseline data
indicate that it is necessary. It is anticipated that after a period of time a routine
preventative maintenance program can be established. A routine preventative
maintenance program will ultimately be less costly than performing maintenance and
repairs on an as needed basis.
9.0 OPERATION AND MAINTENANCE MANUAL REVISION
Following modifications to a groundwater containment system, revisions to existing
operation and maintenance manuals or associated documentation must be prepared. In
this case, an Operation and Maintenance Manual Amendment (O&M Amendment) was
prepared as a revision to the existing Manual. The O&M Amendment included new
equipment specifications, maintenance procedures, and the newly developed system
monitoring and testing procedures for the groundwater containment wells and
conveyance piping system (Table 1). In addition to maintenance and testing
procedures, the O&M Amendment contains baseline performance standards for the
wells, the groundwater recovery pumps, and the piping system. The baseline
performance standards are intended as a standard for comparison with periodic system
monitoring and testing data and as an aid in determining whether the system is
operating as designed. Detailed well redevelopment and chemical treatment procedures
were also included as an Appendix to the O&M Amendment.
10.0 SUMMARY
The groundwater containment system at the Florence wood treating facility is
functioning as designed more than five years following the beginning of operation.
During this time pe .od over 200 million gallons of groundwater have been recovered
by the containment wel:s and treated at the onsite wastewater facility. The system
requires :'reqr mc-- tori i and regular maintenance and testing to ensure continued
Florence
QHMO-;
ffo CHESTER

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performance. In addition to routine maintenance and testing over this time period, the
system also required one more aggressive maintenance project. Routine testing and
maintenance allow for cost-effective day-to-day operation and timely scheduling of
major repairs at maximum time intervals.
Acknowledgements:
The writers would like to acknowledge the significant contributions of personnel from
Koppers Industries, Inc., Florence, SC, Law Engineering, Birmingham, AL and
Commercial and Industrial Piping, Inc., Effingham, SC.
Florence
QKMO-lOO :B/ CC ' !0 10/93

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William D. Wood Jr.
Senior Hydrogeologist
Chester Environmental
Pittsburgh, PA
Mr. Wood has eight years of experience in various areas of the geologic field
including experience in the environmental field and experience with both state and
federal government agencies. Mr. Wood received a Bachelor of Science from
Pennsylvania State University and has completed extensive graduate work at the
University of Pittsburgh. Mr. Wood has been involved in the investigation of
numerous wood treating and coal tar manufacturing facilities and has played key
roles in the design, installation, start up, operation, or maintenance of groundwater

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Mitchell D. Brourman
Project Manager - Environmental Group
Beazer East, Inc.
Mr. Brourman is a corporate Environmental Project Manager for Beazer East, Inc.
In this capacity, Mr. Brourman is responsible for corporate management of various
types of environmental remediation projects at wood treating facilities, coal tar
refineries and coke production facilities. Recent project work includes RCRA
closure of surface impoundments and storage facilities, design and pilot operation of
enhanced fuel product recovery systems, construction and start-up of groundwater
containment systems and pre-treatment plants, and tank farm reconstruction. Mr.
Brourman is also involved with several bioremediation projects. Prior to joining
Beazer East, Inc., Mr. Brourman spent 5 years as a consulting hydrogeologist on

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p
Cardinal,

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GROUNDWATER REMEDIATION FOR VOCs
KIMBERLY-CLARK BERKELEY MILLS
HENDERSONVILLE, NORTH CAROLINA
Kimberly-Clark Corporation has operated the Berkeley Mills facility in Hendersonville,
North Carolina since 1946. The facility manufactures a variety of products, primarily
nonwoven fabric. In the early 1970's, waste solvents were disposed of in drums in a waste
pit, which were later discovered to have leaked into the groundwater. The waste pit drums
and surrounding affected soils were excavated in 1985. A total of 29 monitoring wells were
installed at the site. The results of well sampling and aquifer testing have been used to
define the constituents of the plume, the extent of the plume, and the factors affecting
groundwater flow and contaminant migration. The plume has migrated approximately 500
feet downgradient of the waste pit to Mud Creek, the downgradient property boundary.
Contaminant migration is controlled by groundwater flow, bedrock topography, bedrock
fracture distribution and orientation, and contaminant characteristics. A groundwater
extraction and treatment system consisting of four pumping wells and an air stripping tank
has been in operation since 1987. The system has resulted in reduction in the extent and
concentration of the plume in the overburden. Certain site hydrogeologic factors which
contibuted to the relatively rapid migration of the contaminants may also accelerate
groundwater remediation at the site.
Steve McFadden, Applied Engineering and Science. Atlanta. Georgia
Steve McFadden has been Manager of Hydrogeologic Services at AES for the past five
years. He has 14 years of experience in groundwater remediation projects; evaluation of
groundwater resources and aquifers, geophysical applications to groundwater problems, and

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GROUNDWATER REMEDIATION FOR VOCs
KIMBERLY-CLARK BERKELEY MILLS
HENDERSONVILLE, NORTH CAROLINA
Steve McFadden
Applied Engineering and Science
I. INTRODUCTION
Kimberly-Clark Corporation has operated a manufacturing facility at Berkeley Mills in
Hendersonvilie, North Carolina since 1946. The location of the facility is shown in Figure
1, a site location map. The principal products manufactured at the plant are nonwoven
textile fabrics which are sold as finished products and used as an intermediate component
in consumer products.
Since 1946, two waste disposal areas on the northern section of the Berkeley Mills property
were used to dispose of mainly nonhazardous solid wastes. The two waste disposal areas,
the North Landfill and the Waste Pit, are shown on the topographic site plan, Figure 2.
Liquid chemical wastes, primarily volatile organic c^npounds (VOCs), were poured on the
ground and allowed to volatilize at the North Landfill, and were buried in drums in the
Waste Pit. The North Landfill was closed in the 1970's. The Waste Pit was used for four
or five years in the 1970's, and was closed in the late 1970's.
The land use surrounding Berkeley Mills is primarily residential and light industrial. The
nearest residential area is approximately 500 feet east of the facility boundary, or about 1000
feet from theiVaste Pit. The property covers approximately 168 acres. Topographically,
the property slopes southeastward to Mud Creek, which forms the eastern property
boundary.
A. Summary of Site Investigations and Remediations
In an internal environmental audit, Kimberly-Clark personnel noted seeps emanating from
the Waste Pit area and determined that the buried drums were leaking.
In 1985, the drums buried in the Waste Pit were excavated along with contaminated soils.
A network of-18 monitoring well& was installed from 1985 to 1987 to determine the extent
of groundwater contamination. A groundwater extraction and treatment system has been
in operation since July, 1987. The system consisted of two pumping wells (MW-14 and 17)
and an air stripping unit. These initial site investigative and remedial activities were
completed voluntarily with the approval of State of North Carolina regulatory agencies.

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^^¦LlXu
KIMBERLY-CLARK, ^
BERKELEY MILLS
I Pump
/
Lrrc"-T\-N
/> rv -'-ov0^ i ¦¦.. ^
^ (y )'J *\»-vov \.¦ \ *r>-
vVt—-' ™	"lW
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. \\ /9>j^X " \W%%Xr a?
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.theater \

v
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f
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s" l/ir—£j all •	• •\W \ r»„-__ (I
(FROM USGS TOPOGRAPHIC QUADRANGLE, UENDERSONVILLE, NC, 1978)
_A_
SCALE 1:24000
o
1 MILL
1000
1000 2000 3000 4000 5000 6000 7000 FEET
1 KILOMETER
*
i
SCALE			
	Noted ,
OWN. BY KMK j
CHKHBYTRH j
CONTOUR INTERVAL 20 FEET
FIGURF 1
APPR. BY TRH
" *5jf'flu®,
1	''••mi"'
I
SITE LOCATION MAP
KIM3ERLY - CLARK, BERKELEY
MILLS
3A' -our NC^H C, p 0! INA
"Birr
OCT, 1993
DUG. WO.
4060F
SHEET WO.

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PAGE NOT
AVAILABLE

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On April 18, 1989, Kimberly-Clark Corporation signed an Administrative Consent Order
with the U. S. Environmental Protection Agency (EPA) to conduct a RCRA Facility
Investigation (RFI) and Corrective Measure Study (CMS) at the Berkeley Mills Facility.
During the period from October 1989 to April 1990, an additional eight monitoring wells
were installed (one was plugged and abandoned), an aquifer test was completed to
determine aquifer hydraulic properties, and additional groundwater, surface water and
sediment sampling (including Appendix IX sampling of groundwater) was completed.
This first phase of the RFI resolved most of the technical issues regarding the constituents,
extent, and migration of groundwater contamination at the site. However, the downgradient
extent of the plume was not completely defined, particularly the possibility that in this
hydrogeologic setting the contaminants might cross Mud Creek (an apparent downgradient
discharge boundary). Therefore, in 1992 a geophysical survey was completed and two
additional monitoring wells were installed, including a well on the opposite (east) side of
the creek. These investigations completed the RFI and the CMS is currently in progress.
Beginning in January 1991, the groundwater treatment system was expanded with two
additional pumping wells (MW-22 and 27). This increased the withdrawal rate from an
average of approximately 1.5 gpm to nearly 5 gpm.
II. RESULTS OF THE RFI
A. Geology
1.	Regional Geology
The Berkeley Mills property, approximately 168 acres in size, lies within the Inner Piedmont
geologic province of North Carolina (North Carolina Geological Survey, 1985). The Mill
and surrounding area are underlain by the Henderson Gneiss in a six to eight mile wide belt
that extends southwest-northeast through Henderson County. The topography in this part
of North Carolina is characterized by mountain ranges, isolated peaks, large rolling
intermountain plateaus or valleys, and stream floodplains. Topographically, the Mill
property slopes towards Mud Creek which forms the property's eastern boundary.
2.	Site Geology
The upper geologic materials at the Berkeley Mills site are composed of shallow alluvial
deposits which overlie Cambrian metamorphic bedrock; the Henderson Gneiss. The geology
of the site is illustrated in a cross section of the North Landfill/Waste Pit area (Figure 3).
The alluvial deposits consist of unconsolidated gravel, poorly sorted sand, silt and clay
varying in thickness from about 3 to 21 feet in MW-10 and MW-25, respectively. Underlying
these deposits is a layer of highly weathered bedrock (saprolite), which varies in thickness

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from less than 1 to approximately 97 feet in MW-21 and MW-25, respectively. MW-29 also
shows a continuation of the trend of deeply weathered and fractured bedrock along the east
side of Mud Creek. The relationship of the shallow materials to Mud Creek is also
illustrated in Figure 3. The shallow sands of apparent alluvial origin continue across Mud
Creek and under the bed of the creek. However, a silty clay present on the west side of the
creek apparently terminates and is not present east of Mud Creek. For hydrologic reasons
which will be discussed in a following section, the alluvium and saprolite are considered
together in this report and are referred to as overburden.
The saprolite stratum commonly grades into a relatively fresh light gray to yellowish gneiss,
weathered along fractures, and into unweathered medium-gray to medium bluish-gray augen
gneiss, generally massive, homogeneous, and well foliated. All contacts are gradational and
variable in depth due to degree of weathering. Figure 4, a structure contour map of the top
of the bedrock surface, illustrates the nature of the saprolite-bedrock contact. Much of the
northern part of the Berkeley Mills property is underlain by a bedrock topographic high
area. This includes the area of the abandoned quarry and the location of the remediated
Waste Pit. The bedrock surface slopes toward Mud Creek, which occupies a topographically
low area of the bedrock surface.
3. Fracture Orientation
The gneiss bedrock itself has a very low permeability and does not present any pathways for
groundwater flow or contaminant migration. Secondary features such as fractures control
fluid movement through the rock. For this reason, the orientation of fractures onsite and
in the surrounding area were mapped.
There are basically two sets of fractures in the gneiss bedrock underlying the area. One set
consists of nearly vertical fractures of varying strike direction. Virtually all of these fractures
dip at angles ranging from 70 to 90 degrees. Fractures in this set are hairline cracks and
generally haveno macroscopically measureable openings.
The second fracture set contains low-angle fractures which tend to follow foliation in the
gneiss bedrock. These fractures most commonly strike north 45 degrees east and dip to the
southeast. Dip angles most commonly range from 10 to 25 degrees. These are pressure
relief fractures, which form as overburden to the bedrock is erosionally removed over time.
The rock breaks along zones of weakness which in the Henderson Gneiss is parallel to
foliation. The strike and dip, direction of the foliation, and therefore the fractures in this
set, are apparently consistent throughout the area of the Berkeley Mills facility. These
fractures have variable openings ranging in size from hairline cracks up to two feet. The
larger fractures are visible in the Mill quarry and are represented in the subsurface as the
water-producing fractures in MW-22 and the OMW.

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B. Groundwater Flow
1.	Steady-State Conditions
Figure 5 is a map of the potentiometric surface of the overburden in the North
Landfill/Waste Pit area prepared using water level measurements taken in September 1992.
During drilling, sampling and logging of monitoring wells in this area, the sandy permeable
alluvium and the upper weathered, fractured bedrock (saprolite) were observed to be
hydrologically continuous. They are therefore considered as one hydrologic unit and are
referred to as the overburden. The potentiometric surface of the overburden slopes to the
southeast, toward Mud Creek with an average gradient of about 0.063 toward the southeast.
The influence of bedrock topography on groundwater flow in this area is apparent. It is
more typical for groundwater to flow toward a surface discharge such as a stream in a
downstream direction. At this site, this would result in a groundwater gradient toward the
northeast. However, groundwater flow is following bedrock topography (compare Figures 4
and 5).
Potentiometric levels in bedrock wells are mapped in Figure 6. These levels were not
contoured because groundwater flow in fractures does not necessarily follow gradient. It
is apparent in a general sense, however, that groundwater flow in the fractures is also
generally from the bedrock topographic high beneath the site toward Mud Creek.
2.	Aquifer Test Analysis
The aquifer test data for MW-27 pumping were analyzed using a method developed by
Papadopulos (1965) for anisotropic aquifers. The direction of highest transmissivity in the
overburden is north 3 degrees east (T = 9800 feet squared per day). This parallels the
direction of bedrock contour and probably indicates the highest transmissivity in the
overburden is in the zone of highly fractured saprolite which Mud Creek also follows. The
lowest transmissivity, 170 feet squared per day, is at right angles to this, or parallel to the
bedrock slope. This is consistent with thinning overburden in the direction of high bedrock
topography.
Transmissivity and storativity, both in the overburden and in the bedrock wells which
responded to MW-27 pumping, were also calculated using the Jacob straight-line method
(Lohman, 1972, p. 23). This gives the range of transmissivity and storativity which because
of aquifer anisotropy vary with direction. Transmissivity ranges from 510 to 9,100 feet
squared per day, while storativity ranges from 0.080 to 0.00021. Storativity of overburden
wells only (MW-18 and MW-19) is in the range of 0.002. This indicates leaky confined
condition in the overburden. Although no obvious confining unit is present in the
overburden, it is apparent that there is some layering which results in semi-confined

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3. Summary of Groundwater Flow
Groundwater movement at the Berkeley Mills is complex and controlled by bedrock
topography, fracture distribution and orientation, horizontal and vertical hydraulic
properties, and the presence of a groundwater discharge zone. It is apparent qualitatively
that groundwater moves vertically downward to the water table as rainfall recharge in the
upslope areas of the site. In this area where the bedrock is topographically high, the low-
angle fractures are also recharged. Moving downslope and downgradient, the low-angle
fractures are variably interconnected with the overburden by means of the high-angle
hairline fracture set. Dependent on vertical gradients and hydraulic conductivity, water may
migrate vertically between the two zones along the steep flow pathways toward Mud Creek.
A strong vertically upward gradient in the overburden near Mud Creek indicates that the
creek is a discharge area for groundwater in the overburden. The vertical gradient in the
bedrock, also slightly upward near Mud Creek, may also indicate discharge of this
groundwater into Mud Creek.
C. Contaminant Plume
1.	Contaminant Characteristics
As part of the RFI, an Appendix IX analysis of groundwater from MW-17 was performed
to ensure that no other contaminants are present. MW-17 has historically been one of the
more highly contaminated wells and is used as an extraction point for plume remediation.
The only constituents of concern are four volatile organic compounds which were known to
be in the Berkeley Mills groundwater plume: 1,1,1 trichloroethane, 1,1 dichloroethane,
1,1 dichloroethene, and chloroethane. Three of the four contaminants most commonly
found in the Berkeley Mills groundwater plume (1,1,1 trichloroethane, 1,1 dichloroethane,
1,1 dichloroethene) are volatile compounds of relatively low solubility and specific gravity
greater than one.
2.	Factors Affecting Plume Migration
Groundwater contaminant plume migration at the Berkeley Mills facility is controlled by the
following factors:
1.	Groundwater gradient - Contaminants in the groundwater will migrate
downgradient with the groundwater flow. In both the overburden and
bedrock, this is from bedrock high areas southeast toward Mud Creek;
2.	Bedrock topography - Bedrock topography is a controlling factor for both
groundwater flow and contaminant movement. At both the South and North
Landfill areas, the top of bedrock slopes toward the southeast, toward Mud

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3.	Fracture distribution and orientation - Groundwater flow and contaminant
migration in the bedrock occurs through the pathway of bedrock fractures.
Two fracture sets have been mapped at the facility. One set consists of small,
nearly vertical hairline cracks. The second set follows bedrock foliation which
strikes roughly north 45 degrees east and dips to the southeast, generally at
angles near 20 degrees.
4.	Contaminant characteristics - Most of the contaminants in the Berkeley Mills
plume have a relatively low solubility and are more dense than water.
3.	Plume Extent
Figures 7 and 8 are maps of the distribution of those four contaminants in the overburden
and bedrock, respectively, for analyses in September 1992. As can be seen, the plume
extends southeast from the source (Waste Pit) to Mud Creek, a distance of 500 feet.
Maximum width of the plume is approximately 300 feet. The plume extends into the
bedrock a maximum depth of 140 feet (see also cross section, Figure 3).
Laterally, the plume in the overburden is well defined (Figure 7). Upgradient wells MW-1,
MW-8 and MW-9 are all clean. Side gradient wells MW-11 and MW-5 are clean, while
MW-3 and 4 contain low levels of contaminants. Downgradient, the plume extends to Mud
Creek at the facility boundary, where relatively high concentrations are present in MW-27
at a depth of over 80 feet. MW-28, the monitoring well farthest south on the west side of
Mud Creek, and MW-29 on the east side of Mud Creek both have no detectable
concentrations of VOCs.
Figure 8 maps the contaminant distribution in the bedrock wells. Again, the trend is clearly
from the Waste Pit toward Mud Creek through MWs 14, 17, 22, 26 and 27 (although
technically in the overburden, MW-27 is interconnected with the fractures in MW-14, 17,
and 22). It is "apparent that the contaminants entered the bedrock near the Waste Pit,
migrated through bedrock fractures in MW-14, MW-17, MW-22, and downgradient to MW-
26 and MW-27. The limits of the plume laterally are well defined. Side gradient wells
MW-15 and the OMW appear to be near the fringes of the plume with relatively low levels
of contamination. MW-21, the abandoned hole near MW-3, encountered no fractures to a
depth of 170 feet, clearly indicating that there are no pathways for contaminant migration
in the bedrock in this area.
4.	Presence of a Nonaqueous Phase
Of critical importance to the design of an effective remediation system at this site is the
absence of a nonaqueous phase of the contaminants. A nonaqueous phase is not believed
to be present in the subsurface for the following two reasons:
1. During the excavation of the Waste Pit materials, installation of 29 monitoring

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wells, and sampling of wells for eight years, no nonaqueous phase liquids have
ever been observed at the site.
2. With eight years of groundwater analyses, concentrations have never exceeded
the solubility of the constituents.
III. GROUNDWATER REMEDIATION SYSTEM
The groundwater remediation system at Berkeley Mills consists of four extraction wells
(MW-14,17,22, and 27) pumping to a 50,000 gallon air stripping tank. Total extraction rate
from the four wells averages about 5 gpm. Water is treated in the air stripping tank in
batch fashion and then discharged to the City of Hendersonville POTW, located adjacent
to the Berkeley Mills property. Sampling of the tank has demonstrated that the system is
100% effective in removal of the four volatile compounds found in the plume.
The system began operation in July 1987 by pumping MW-14 and 17 at a combined rate of
about 1.5 gpm. The withdrawal rate was increased in January 1991 by adding MW-22 and
27, increasing the withdrawal rate an average of about 5 gpm. Groundwater analytical data
are now available for eight years. The effect on the groundwater contaminants is illustrated
in selected graphs of contaminant concentrations, included in Appendix A.
Maximum historical concentrations at the siie were approximately 40,000 ug/L in wells close
to the Waste Pit source before groundwater extraction and treatment began in 1987.
Maximum concentrations in the past year have been approximately 2,000 ug/1, still in wells
close to the Waste Pit. It is apparent from studying the concentrations and areal and
vertical distribution over time that the extent and concentration of the plume in the shallow
overburden is decreasing while staying relatively constant in the highly fractured upper
section of the bedrock downgradient of the source. Concentrations over time have
decreased, by more than an order of magnitude in some wells, in MW-7, 10, 13,14, 15,16,
and 17. All of these wells are in the overburden or very shallow bedrock near the Waste
Pit. However, in MW-22, 26, and 27, concentrations have remained relatively unchanged.
These three wells are all screened deeper in the weathered bedrock and are farther from
the Waste Pit (note that these three wells are also newer and have a shorter sampling
history). This migration of the plume is due to the effects of pumping the four extraction
wells in this unit, natural migration of the groundwater to and through this more permeable
unit, or, in all probability, a combination of both. Typical concentrations in the unit being
pumped by the extraction wells are 200 to 300 ug/L.
No serious effort has beenmade to predict the amount of time required for the groundwater
treatment system at Berkeley Mills to achieve cleanup standards. It is worth noting,
however, the appropri?^ sness of pump-and-treat technology at this site in light of the
disappointing performan : of this remediation technique at other sites. It is generally
accepted that the tw leading auses for the failure of pump-and-treat are

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sorption/desorption of contaminants in the geologic media and the presence of a
nonaqueous phase liquid. As stated above, there is no evidence of the presence of a
nonaqueous phase at Berkeley Mills. Furthermore, the aquifer materials consist of a
relatively sandy alluvium/residuum overlying a fractured bedrock, materials not known for
their ability to affect contaminant concentrations.
It is apparent that the hydrogeology of the site contributed to relatively rapid spread of the
contaminant plume. A permeable overburden and fractured bedrock with relatively high
groundwater flow rates did little to attenuate the spread of the plume. It is also apparent
that these same factors could assist in the remediation. Pump-and-treat should be more
effective as a remediation technology at a site such as Berkeley Mills where desorption of
contaminants is less of a factor and no nonaqueous phase liquids are present.

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CHLOROETHANE
BERKELEY MILLS, MW-10
nt nt nt nt nt nt nt nt

TEST DATES
n — not detected

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200
1,1 -DICHLOROETHANE
BERKELEY MILLS. MW-13
150 -
PQ
CL400
50 b
TEST DATES
n - not detected

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350
300
250
200 (-
I
150
100
50
1,1 -DICHLOROETHENE
	BERKELEY MILLS, MW-14
ri n nt nt nt nt n n nt n n
n
n — not detected
nt — not tested
^^8^/8fA&/8TlAWAh/8i'H/9Fyfef^b/9l2)yi/9i,/H/9^

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11
10
9
8
7
t/i
•a
c 6
CS °
w
P
° 5
4
3
2
1
0
- not
1,1 -DICHLOROETHANE
	BERKELEY MILLS, MW-14	
letected
tested
J/8?'"'4/88'ul'l/8S"i/9F/y-//9l

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CHLOROETHANE

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CHLOROETHANE
BERKELEY MILLS, MW-16
TEST DATES
n — not detected

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1,1,1 -TRICHLOROETHANE

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600
1,1 -DICHLOROETHENE
BERKELEY MILLS, MW-17
500 -
400 -
PQ
Ph300
Ph
200 -
100 -
nt nt nt nt n n n n n nt
0
1	W9l2^j/9
TEST DATES
n — not detected

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1,1 -DICHLOROETHANE
3000
2500
2000
PQ
P4500
Plh
1000
500
0
TEST DATES
n - not detected

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150
1,1 -DICHLOROETHANE
BERKELEY MILLS, MW-22
CQ
Cn
Ph
0 	5^0—rftfo—3M	5$1	9^1—rffal—3fc"
TEST DATES
~5fc	9fc—TOT
n — not detected

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1,1,1 -TRICHLOROETHANE
BERKELEY MILLS, MW-26
n - not detected

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• ,i,i i niUHLORO ETHANE
TEST DATES
n - not detected

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1,1 -DICHLOROETHENE
BERKELEY MILLS, MW-27
n
0 3$D
n - not detected
nt — not tested
3$I 5&1 5$I ri&I jfc 5$2 5Pi IW

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TEST DATES
n - not detected

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CHLOROETHANE

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suamB
PLANTWIDE
CORRECTIVE ACTION
PROGRAM

,	-V	T-
Catvert City, Kentucky
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PLANTWIDE CORRECTIVE ACTION PROGRAM (PCAP)
BFGOODRICH COMPANY - CALVERT CITY, KENTUCKY
ABSTRACT
The BFGoodrich Company has implemented a plant-wide corrective action program
(PCAP) for remediation of groundwater contamination at its Calvert City, Kentucky facility.
The PCAP, consisting of a groundwater extraction and treatment system, was designed and
implemented following a comprehensive site characterization program that led to a detailed
understanding of geologic and hydrologic conditions at the site, the nature and extent of
contamination in the uppermost aquifer beneath the facility, and the physical controls on
contaminant distribution and plume migration beneath the facility. Performance goals for the
PCAP system include plume containment, on-site groundwater quality restoration, and off-site
groundwater quality restoration. Other factors considered in the system design included the
hydrogeologic characteristics of the aquifer, groundwater chemistry, and an assessment of the
monitoring data requirements necessary to evaluate the effectiveness of the system. The PCAP
system operates at between 800 and 900 gpm, effectively treating and removing organic
contaminants from the groundwater. Groundwater extraction has resulted in a large cone of
depression across the northern portion of the site that is effective in containment of the plume,
thereby minimizing continued migration off-site and to the Tennessee River. Contaminated
groundwater is treated by a 1,000 gallon per minute (gpm) capacity steam stripper, and the
treated water is discharged to the Tennessee River via the facility's permitted outfall. Despite
being in operation for a period of less than three years, the PCAP system affected a significant

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(Slide 1)
PLANTWIDE CORRECTIVE ACTION PROGRAM (PCAP)
BFGOODRICH COMPANY - CALVERT CITY, KENTUCKY
1.0 INTRODUCTION
This presentation summarizes background information, design considerations,
implementation, and effectiveness of the ongoing plantwide corrective action program, or
PCAP, at the BFGoodrich Company's Calvert City, Kentucky chemical manufacturing
facility. BFGoodrich operates the corrective action program pursuant to its hazardous
waste permit A corrective action program was initiated in 1986 to comply with an Agreed
Order with the Kentucky Natural Resource and Environmental Protection Cabinet
(KNREPC), following closure of RCRA-regulated surface impoundments and prior to
permit issuance. Since that time, BFGoodrich has voluntarily expanded the program to its
present plantwide configuration.
(Slide 2)
2.0 FACILITY DESCRIPTION
BFGoodrich's Calvert City, Kentucky facility is situated on the southern bank of
the Tennessee River in Marshall County Kentucky, approximately 18 miles upstream of the
confluence of the Tennessee and Ohio rivers at Paducah, Kentucky. The facility is located
in a major industrial complex, the principal products of which include chemicals and allied
products (primarily metals).
(Slide 3)
The facility lies on a broad, flat terrace above the 100-year floodplain of the
Tennessee River at an elevation of approximately 345 feet above mean sea level (feet, msl).
Topography near the river drops rapidly from the terrace area to the narrow floodplain area
along the river's edge (normal pool elevation of 302 feet, msl). This accounts for nearly all
of the approximately 40 to 45 feet of local relief.
The operational portion of the BFGoodrich property occupies approximately 330
acres of land, and is bounded to the north by the Tennessee River. Additional non-
industrial acreage held by BFGoodrich is located immediately to the south of the operating
facility. The eastern portion of the facility is borrierec by the BFGoodrich/AIRCO
CERCLA site. The areas to the west and southwest of the facility are occupied by a variety
of major industrial facilities.

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Three groundwater supply wellfields are located within 2 miles to the southwest of
the site. These include two industrial groundwater supplies and the Calvert City municipal
wellfield. The three wellfields combine for a total groundwater withdrawal of
approximately 2.7 million gallons per day. Groundwater withdrawal from these locations
plays a significant role in the BFGoodrich corrective action program, as we will discuss
later in the presentation.
(Slide 4)
Operations at the facility began in 1953. Historically, vinyl chloride monomer,
acrylonitrile, and Carbopol® were the principal products at the plant Carbopol® is a
registered trade name for a thickening agent used in a variety of gel products. Starting in
1963, 1,2-dichloroethane (EDC) was used as an intermediate in the production of vinyl
chloride monomer. BFGoodrich currently operates three processing plants: Carbopol®,
ethylene, and chlorine. Since March 1990, the EDC/vinyl chloride monomer production
facilities have been owned and operated by Westlake Monomers, Inc.
(Slide 5)
3.0 HYDROGEOLOGIC SETTING
BFGoodrich initiate j. own geologic, hydrogeologic, and contamination
assessment investigations at the facility both before and after promulgation of the RCRA
Hazardous and Solid Waste Amendments of 1984. Over the years, these investigations
focused on specific problems in various areas of the facility, such as the CERCLA sites,
the RCRA closure impoundments, various release investigations, and an environmental site
assessment, performed prior to the sale of the vinyl chloride production facilities to
Westlake Monomers. These investigations provided a great deal of site-specific
hydrogeologic information as well as information about releases from specific units or
areas of the facility. Despite the abundance of data, the rather narrow focus of the
individual investigations was not especially conducive to developing an understanding of
site-wide conditions.
Beginning in 1990, BFGoodrich seized the initiative and began a comprehensive
groundwater study designed to develop a thorough understanding of the site-wide
subsurface hydrogeologic characteristics and to assess the total extent of groundwater
contamination beneath the site and surrounding properties. This so-called "Remedial
Environmental Investigation" (REI) w ..s also designed to provide sufficient information to
support the selection cf a corrective ~ iasu;?s approach. As a result of the REI and prior
investigations, the facility currently aainiains in excess of 200 monitoring wells and

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piezometers (approximately one monitoring well or piezometer for every 1.5 acres of the
operational part of the facility). Most of the locations presented here consist of multiple
well clusters, with wells screened at varying depths in the aquifer.
(Slide 6)
Subsurface conditions beneath the BFGoodrich facility can best be understood by
examining a south to north geologic cross section. Bedrock beneath the facility is
comprised of Mississippian limestone (the Warsaw Formation and the underlying Fort
Payne Formation). These limestone formations are not viable aquifers in the vicinity of the
BFGoodrich facility. Bedrock rises from south to north, from an elevation of
approximately 220 feet, msl near Highway 1523 to over 260 feet, msl beneath the northern
portions of the BFGoodrich plant A bedrock high rises to an elevation in excess of 270
feet, msl beneath the northern-most portion of the site.
Unconsolidated sediments beneath the site consist of three main stratigraphic units:
a 5- to 35-foot thick silty clay surface layer, a 30- to 60-foot thick unit composed of clayey,
silty sand that grades downward to fine to medium sand, and a lower 30- to 60-foot thick
sand and gravel unit. The proportion of clay present in the strata increases towards the
Tennessee River.
The lower two units comprise the uppermost aquifer beneath the site, and it is the
sand and gravel unit that serves as the principal water supply source for the industrial and
municipal wellfields located to the southwest of BFGoodrich. The saturated thickness of
the aquifer decreases from nearly 100 feet south of the plant to between 30 and 50 feet
along the northern portion of the plant beneath the floodplain. This decrease is due to a
combination of the sloping water table towards the Tennessee River, the change in the
topography near the river, and the bedrock high.
(Slide 7)
Pre-corrective action groundwater flow is generally from the upland recharge areas
toward eventual discharge to the Tennessee River. However, a southwest to northeast
trending groundwater divide is present across the southern portion of the plant. A
computer simulated groundwater flow model illustrates that the combined effects of
pumping at industrial and municipal water supply wells located to the southwest of
BFGoodrich are capable of exerting sufficient stress on the aquifer to produce the observed
divide. Piezometric data collected during a shutdown of the largest of the industrial
rcpbi^-;1

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wellfields and repeated field measurements of groundwater elevations verified the presence
of the divide.
Groundwater on the south side of the divide flows toward the withdrawal centers
under very low hydraulic gradients. Pre-PCAP groundwater flow directions suggest that
the large industrial wellfield exerted the greatest influence on groundwater flow patterns
beneath the BFGoodrich facility. Groundwater flow north of the divide is toward the
Tennessee River.
(Slide 8)
This slide illustrates a cross-sectional representation of pre-PCAP groundwater
flow. The dominant flow characteristic south of the divide shown here is a downward
vertical gradient induced by pumping at the nearby industrial and municipal groundwater
supply wellfields. Upward vertical hydraulic gradients are shown within approximately
1,200 feet of the river. This is indicative of groundwater discharge to the river.
(Slide 9)
4.0 SOURCE CHARACTERIZATION
Characterization of the nature of contamination at the site revealed that the principal
contaminants in groundwater beneath the facility include the volatile organic compounds
EDC and benzene. These compounds were chosen as indicator parameters for the site-
wide studies because of the relatively high concentrations identified in groundwater
samples at The site, as compared to other constituents. In addition, each parameter is
associated with identifiable storage and handling practices and processes that are located in
specific areas of the plant The latter criteria allows for identification of potential source
areas.
As we shall see in the next few slides, characterization of the extent of
contamination at the site, outside of individual SWMU investigations, revealed a picture of
a sitewide groundwater contamination problem not necessarily identified with SWMU-
related sources. Rather, it appears that the major sources for contamination, besides the
former wastewater treatment surface impoundments and the CERCLA site, include the
facility's process and storage areas, particularly the EDC and enzene process and storage
areas.

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(Slide 10)
5.0 CONTAMINATION CHARACTERIZATION
The geometry of the EDC contaminant plume corresponds with the locations of
process/storage areas as well as with the CERCLA site, as shown by the locations of the
most concentrated portions of the shallow plume.
Although the alluvial aquifer is a single saturated unit, it is often convenient to
discuss the distribution of contamination in terms of "shallow" and "deep". As shown
here, a portion of the EDC plume has migrated from the shallow portion of the aquifer to
the deep aquifer zone. The geometry of the "deep plume" closely resembles that of the
"shallow plume" across much of the site. However, a portion of the "deep plume" has
moved to the west-southwest under the influence of pumping at nearby industrial water
supply wellfields. The shape and position of the "deep plume" in this portion of the site
closely follows groundwater flow directions observed south of the flow divide, as
previously discussed.
(Slide 11)
The distribution of the EDC plume in the subsurface can be better understood by
examining a cross sectional view. As shown in this slide, the plume has migrated
downward and to the south under the apparent influence of groundwater withdrawal from
the nearby water supply wells. As discussed previously, the distribution of the
contaminant plume closely follows the observed groundwater flow directions.
(Slide 12)
Benzene contamination is restricted to the northern portion of the site; specifically,
the CERCLA site, the east-central portion of the plant near the ethylene process area, the
former wastewater treatment ponds, and along the Tennessee River. Along the river, the
benzene plume extends westward beyond the property boundary, to a distance
approximately the same as that observed for the EDC plume.
As we can see from a comparison of the relative extent of the EDC and benzene
plumes, the EDC plume is considerably more widespread than the benzene plume, and it is
also characterized by significantly higher concentrations. Therefore, discussions that will
follow regarding the effectiveness of the PCAP s stem, will focus primarily on EDC.

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(Slide 13)
One of the most important aspects to any corrective action program is the
establishment of technically sound, attainable groundwater protection standards. For the
BFGoodrich facility, onsite groundwater protection standards have been established
through an Alternate Concentration Limit, or ACL, demonstration. Risk-based ACLs have
been set for a total of 53 organic and inorganic constituents, including EDC and benzene,
as a part of BFGoodrich's post closure permit. The ACLs developed for the BFGoodrich
facility are protective to human health and the environment in that the allowable point of
compliance concentrations (the ACLs) will not cause an exceedance of acceptable standards
at the point of exposure (in this case, the Tennessee River). For the indicator parameters
EDC and Benzene, the ACLs have been set at 0.86 mg/L and 0.61 mg/L, respectively.
For the offsite portion of the plume, the acceptable groundwater protection
standards remain either MCLs or background. These groundwater protection standards
serve as the clean-up goals for the corrective action program.
(Slide 14)
6.0 PCAP DESIGN AND IMPLEMENTATION
Design considerations tor the PCAP included an evaluation of the performance
goals to be met by the system, the hydrogeologic characteristics of the aquifer,
groundwater chemistry (in terms of general chemistry as well as contamination), and an
assessment of the monitoring data requirements necessary to evaluate the effectiveness of
the PCAP system in achieving its performance goals. The following discussion details
each of the design considerations.
(Slide 15)
Perhaps the most important consideration in the design of the PCAP system was the
establishment of clearly-defined corrective action goals designed to address the full extent
of groundwater contamination at the facility. In order to determine the overall nature and
physical configuration of the PCAP system, the extent of contamination was evaluated with
respect to potential future plume migration and potential effects on human health and the
environment The thorough understanding of subsurface geologic, hydrologic, and extent
of contamination lead to the establishment of several performance goals: plume
containment, on-site groundwater quality res tor a" on, ar.d off-site groundwater quality
restoration.

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(Slide 16)
The corrective action performance goals lead to the establishment of a PCAP system
comprised of three distinct networks of groundwater extraction wells and subsequent onsite
treatment of the extracted groundwater by steam stripping. These well networks can be
distinguished by the performance goals they serve:
•	Tennessee River Blocking System: This system senses to contain the
groundwater contamination plume by minimizing groundwater discharge to the
Tennessee River. This goal is designed to be accomplished through creation of
a hydraulic barrier between the source areas and the river. The blocking
network also serves to meet the groundwater quality restoration performance
goal by removing contaminated groundwater as the plume is captured by the
well network.
•	Source Area Remediation System: This system serves to meet the on-site
groundwater quality restoration performance goal. Extraction wells in this
network are located in, and adjacent to, the most concentrated portions of the
contaminant plume. These areas include the EDC process and storage areas and
the CERCLA site.
•	Off-site Plume Remediation System: This system is designed to prevent further
off-site migration of contamination while restoring groundwater quality in the
areas to the west and southwest of the site.
(Slide 17)
Preliminary, design considerations for the extraction well networks included a
determination of well spacing requirements. The locations of the extraction wells were
selected based on optimal spacing to fully capture targeted groundwater without excessive
inflow of uncontaminated groundwater. The optimization utilizes a method of predicting
the area of influence of a pumping well under uniform groundwater flow conditions. The
method is known as the Dupuit radial flow equation. The goal of this evaluation is to
determine appropriate spacing of extraction wells to ensure "capture" of contaminated
groundwater by creating overlapping "capture zones".
This simple, yet effective, evaluation requires a thorough understanding of aquifer
conditions, including: hydraulic conductivity, aquifer thickness, and natural hydraulic
gradients. Each of these parameters is highly variable across the site. Because of this,
published estimates and "educated guess" approximations are inadequate for design
purposes. This variability further highlights the need for a thorough understanding of site-
specific hydrogeologic conditions prior to implementation of corrective measures at any
site.
rcpbfg-l1

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(Slide 18)
A three-dimensional computer model was used to evaluate the influence of pumping
along the Tennessee River Barrier Well network, and to provide a means to predict the
extent of the influence of pumping on the surrounding aquifer and the time-frame required
for establishment of a hydraulic barrier. MODFLOW, a three-dimensional finite-difference
groundwater flow model developed by the U.S. Geological Survey was used to simulate
groundwater flow patterns.
The model was first run in the steady-state mode, without the PCAP extraction
wells pumping, to calculate the starting head values for the transient modeling runs. The
modeled gradients and flow directions were consistent with historical groundwater flow
conditions observed at the site. The actual discharge values for the extraction wells were
then added. Transient model runs were performed to compute head values after 30 days
and 180 days. Finally, the model was run to calculate the steady-state head values, as
shown on this slide. The discharge rate for these model runs was 855 gpm, a value that is
representative of actual total discharge rates for the PCAP system over recent reporting
periods. The computer simulated piezometric surface presented here is for the shallow
portion of the aquifer. As a result, the effects of pumping at the deep wells, located in the
southwestern EDC plume area, are not readily evident Modeling indicated that steady-state
conditions would be achieved at a time in excess of 180 days, provided pumping rates were
maintained and modeling assumptions were correct.
(Slide 19)
Chemical considerations in the design of the PCAP system included basic
groundwater chemistry as well as the nature of the groundwater contamination.
Groundwater beneath the facility is characterized by high naturally-occurring iron
concentrations. Construction and operational considerations were carefully selected to
minimize the potential for iron precipitation that could result in a progressive reduction of
well yields. These considerations include well construction materials, screened interval
placement relative to anticipated drawdown in the wells, and pump placement. The
treatment system, a 1,000 gpm-capacity steam stripper, is constructed of titanium, which
also serves to minimize the precipitation o: ran inside the stripper column.
The nature of contamination was t ic prm ; consideration in the selection of a
treatment technology. Following an eva: ^auon , . . ernadve treatment technologies

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including air stripping and carbon adsorption, it was determined that steam stripping is the
best available technology for treatment of the volatile organic constituents present in the
groundwater. The selection of steam stripping as a treatment technology was also based, in
part, on a history of successful treatment of process wastewaters using steam stripping.
Contaminated groundwater is first pre-treated with acid to reduce the feed pH to the 4-5
range. This reduces calcium carbonate precipitation in the column and associated
equipment. The acidified feed is distributed across the top of the stripping column. Low
pressure steam is introduced to the bottom of the column and flows countercurrent through
the falling groundwater, thereby effectively removing organic constituents.
The organic condensate from the stripping process is returned to Westlake's
EDC/VCM process. The non-condensed steam is treated by carbon vapor adsorption.
Treated groundwater is discharged to the Tennessee River via a diffuser outfall permitted
under the Kentucky Pollutant Discharge and Elimination System.
(Slide 20)
Finally, the remaining considerations taken into account in the PCAP system design
included the data requirements necessary for evaluating the effectiveness of the PCAP
system over time. The monitoring system makes use of existing monitoring wells and
piezometers to collect data necessary for a piezometric evaluation of the effects of pumping
on groundwater flow patterns beneath the facility. Additional piezometers were installed at
locations between the Tennessee River blocking wells to provide additional piezometric
data along the hydraulic barrier.
Groundwater quality data collected from select existing monitoring wells are used in
conjunction with water quality data collected form each of the individual extraction wells to
monitor the effectiveness of groundwater quality restoration.
Finally, Tennessee River monitoring for EDC concentrations is evaluated to further
assess the effectiveness of the blocking network in minimizing the discharge of
contaminated groundwater to the river.

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(Slide 21)
Thus far, the only significant operational difficulties encountered during the nearly
three years of PCAP operation have involved unexpectedly low well yields encountered in
some of the wells upon startup of the system and clogging of some of the extraction well
screens, particularly in those monitoring wells located closest to the river, by iron
precipitation.
The lower than expected well yields encountered in some of the wells following
installation and startup was caused by the presence of fine-grained aquifer materials (very
fine sand with numerous clay layers) along the western-most portion of the Tennessee
River blocking network. Following installation, some of these wells were capable of
yielding no more than 3 to 5 gallons per minute, and these yields decreased with time. A
rigorous well development program was undertaken for each of the wells screened in this
area. Procedures included repeated surging and pumping, and the use of a sodium
hexametaphosphate treatment to disaggregate the clays that were lodging in the filter pack
and screen. These procedures were successful in increasing well yields by two to four
times the yield before treatment
Iron precipitation and clogging of the well screens at some of the wells located
nearest the Tennessee River, mainly those located in the western portion of the blocking
network, has also played a role in reduced well yields over time. The iron precipitation
problem appears to be the result of the introduction of oxygen into the aquifer by the
periodic influx or surface water as the Tennessee River stage rises. Wells screened in the
deep portion of the aquifer, and those away from the influence of bank storage have yet to
be affected by the iron precipitation problem. This problem has been managed by
implementing a well maintenance program in which affected wells are periodically shut
down, treated chemically to dissolve the precipitated iron, and redeveloped mechanically.
This maintenance program has resulted in additional operating expense, but it has allowed
the blocking network to maintain an effective hydraulic barrier along the river.
(Slide 22)
7.0 EVALUATION OF EFFECTIVENESS
The overall effectiveness of the PCAP and the three individual extraction well
networks is assesse primarily through t c ¦ nation of ste-specif:: groundv iter
extraction rates, conuaninaat»mass removal rate: piezometric information, groundwater

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quality data, and surface water quality data. Groundwater extraction rates can be compared
against the hydrologic budget for the site and contaminant mass removal rates can be
evaluated to develop a general sense of the overall efficiency of the extraction system. Site-
specific piezometric data are evaluated to monitor actual effects of pumping on the
piezometric surface. Water quality data, including data obtained from monitoring wells and
extraction wells, are evaluated for trends in concentrations of indicator parameters as a
means of determining whether water quality improves with continued operation of the
corrective action program. The following discussion focuses on each of these important,
inter-related components of the PCAP to demonstrate the effectiveness of the system.
(Slide 23)
The PCAP system has been extracting a total of between 800 to 900 gallons of
groundwater per minute. Approximately two-thirds of this total is extracted by the
Tennessee River blocking network in order to maintain the hydraulic barrier designed to
minimize groundwater discharge to the river, which is the principal short-term performance
goal of the system. One way to determine the efficiency of the barrier network is to
compare the volume of water being extracted against calculated volume of groundwater that
is available to discharge to the river. Prior to implementation of the PCAP, a hydrologic
budget determination was performed for groundwater entering the site from the south and
subsequently discharging to the Tennessee River. This hydrologic budget evaluation
calculated that the total discharge from the site to the Tennessee River (i.e., available water)
was approximately 450 gallons per minute. PCAP discharge data indicates that the
blocking network typically accounts for the extraction of between 500 and 650 gallons per
minute. Therefore, it can be concluded that the blocking network has established an
effective barrier to groundwater discharge to the river. The excess discharge from the
blocking network can be accounted for by influx of water from the river and the portion of
the aquifer beneath the river, downgradient of the line of extraction wells. The offsite
remediation well network and the source remediation network each accounts for between
100 and 200 gallons per minute.
(Slide 24)
An impression of the enormous volume of groundwater being extracted and treated
at the facility can be gained by examining the total discharge on a monthly basis. As shown
by this graph, the PCAP system typically extracts between 35 and 40 million gallons of
groundwater per month. While the majority of the extracted groundwater is removed by
the Tennessee River blocking network, the offsite remediatioif^network and the source
rcpbfg-l 1

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remediation network account for extraction and treatment of up to an additional 15 million
gallons per month.
(Slide 25)
The groundwater extracted by the PCAP system results in the treatment and
removal of in excess of 1,500 pounds of EDC per day from the aquifer. One of the goals
for improving the efficiency of the PCAP system as a whole is to adjust the pumping rates
required for maintaining the hydraulic barrier under various river stages and, at the same
time, adjust discharge at the source remediation network to make better use of available
stripper capacity. For example, as river stage increases, lower pumping rates are required
to maintain the hydraulic barrier. As a result, the source remediation wells, located in the
areas of highest contaminant concentrations, can be pumped at increased rates with a
resulting increase of the treatment efficiency. Once the pumping requirements for
maintaining the hydraulic barrier under various river stages become better quantified, this
approach will result in improved efficiency.
(Slide 26)
Evaluation of the shallow piezometric surface at the site further attests to the
effectiveness of the system in preventing further spread of the plume to the west, as well as
minimizing discharge of contaminated groundwater to the Tennessee River. A large cone
of depression is in evidence across the entire northern two-thirds of the facility. The
piezometric map presented here, based on over 75 groundwater elevation measurements, is
remarkably-similar to the computer simulated piezometric surface at steady-state conditions.
Those off-site plume remediation wells located to the southwest of the site are
screened in the deep part of the aquifer. As a result, the effects of pumping at these wells is
not readily apparent on the "shallow" piezometric map. However, as we will see, these
wells have been effective in meeting the performance goal of offsite groundwater
remediation.
(Slide 27)
A comparison of EDC concentrations observed in the southwest offsite plume
before implementation of the PCAP with those observed from sampling in February 1993
shows a marked improvement in offsite groundwater quality after only slightly more than
two years of PCAP operation. Concentrations in this portion of the plume have been
reduced from up to nearly 300 ug/L at the property line to a maximum of slightly over 20
rcpbfg-ll

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Hg/L. The area bounded by the 5 |ig/L isoconcentration line has been reduced from over
18 acres to approximately 4.5 acres in size. The reduction in contaminant concentrations
and plume size is a strong indicator of the effectiveness of the offsite plume remediation
network.
(Slide 28)
The overall goal of the blocking well network is to minimize the discharge of
contaminated groundwater to the Tennessee River. River water quality data collected from
prior to closure of the pond system to the present show that the average EDC concentration
has steadily declined as a result of corrective measures implemented at the facility. The
highest rate of decline occurred immediately following closure of the former RCRA
wastewater impoundments. Since that time, surface water quality continued to improve
due to the source removal and the ongoing corrective action program. Further decreases in
EDC concentration have been observed since implementation of the PCAP to an average
concentration of less than 0.1 (Ig/L. The continuing trend in the improvement in surface
water quality is a strong indicator of the overall effectiveness of the PCAP system as a
whole and the blocking network, in particular.
(Slide 29)
In summary, the BFGoodrich Company's aggressive, environmentally sound
approach to corrective action has resulted in the successful development of a plantwide
solution to groundwater contamination at the site. Despite being in operation for a period
of less than three years, the PCAP system has resulted in a significant improvement in
offsite groundwater quality as well as surface water quality observed in the Tennessee
River. The success of the BFGoodrich system has been the result of not only determining
the extent of contamination at the site, but through the development of a thorough
understanding of the sitewide hydrogeology and its effect on contaminant distribution and
plume migration. Continued operation of the system, coupled with BFGoodrich's ongoing
commitment to improving the efficiency of the system, will serve to further groundwater
remediation efforts at the facility.

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PLANTWIDE
CORRECTIVE ACTION
PROGRAM (PCAP)
B F'.5?q -"UpD-Ktl
Calvert City, Kentucky
Prepared by
- &
Hrj®aansB & Mm®®
SLIDE 1
SLIDE 2

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SLIDE 5
Geologic Cross Section
SOUTH	NORTH
0	HO
Hortzcmtal Scalr
.. (Feat)
SLIDE 6

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Pre-Corrective Action Groundwater Flow (Model Results)
LEGEND:
WATER SUPPLY
WELL LOCATION
EQUt POTENTIAL
LINE (FEET, USU
GROUNDWATER
FLOW DIRECTION
GROUNDWATER
DIVIDE
THUC
NORTH
CALVERT
CITY
APPROXIMATE SCALE IN FEET
SLIDE 7
Pre-Corrective Action G< ounowater Row Pattern
NORTH
350
200
200
Hortzontf Seal#
; (Fat
SLIDE 8

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\
\
LEGEND;
_ EOC SOURCE
¦ AREA
¦BENZENE
SOURCEAREA
„ EOC AND
B BENZENE
SOURCE AREA
X	Vx
Contaminant Source Areas
\
/
/
T
/
/
/
SLIDE 9
\
\
EDC Plume Relative to SourcevA*sas
SLIDE 1C

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Pre-Corrective Action Subsurface EDC
Distribution (p.g/L)
SOUTH
350-1
£
2
tr300
Ul
Horizontal Scats
(Feat)
Ttnaaiee
River
NORTH
350
-J
CO
2
300 £
ui
<¦200
SLIDE 11

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Groundwater Protection
Standards
•	Plantwide ACLs
•	Off-site Standards
-	MCLs
-	Background
SLIDE 13
PCAP Design Considerations
•	Performance Criteria
•	»/• Hydrogeclcgy ¦
•	Chemistr
I # Mdnito
I		• - ¦' • 	 ~ 			
SLIDE 14

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PCAP Performance Goals
Plume Containment
On-site Groundwater Quality Restoration
Off-site Groundwater Quality Restoration
SLIDE 15
LEGEND:
. TENNESSEE RIVER
* BLOCKING SYSTEM
_ SOURCE AREA
° REMEDIATION SYSTEM
O OFF-SITE PLUME
REMEDIATION SYSTEM
5= 8HALLOW
J-- Ofcfi*
PCAP IsXtcaeiton Well Networks	\y
x v *s\
V MOWTH H

N
APPUGXiMXHE SOti ** P«ET
/
iDE 16
~>C=2V cr=J
nv.

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sue "=1?
BF

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SLIDE 19: Steam Stripper Photograph
Monitoring Considerations
•	Piezometric Monitoring System
•	Groundwater Monitoring System
•	Tennessee River Monitoring (ORSANCO
Data)
SLIDE .u

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Operational Difficulties
•	Well Yields
•	Iron Precipitation
SLIDE 21
Evaluation Effectiveness
•	Groundwater Extraction Rates
•	Contaminant Mass Removal Rates
•	Groundwater Flow Gharacteristics
. ; •	a '	•J.*.'.' •	„ -* " ' ht ' J' V/J , *'
•	Groundwater G uality Data
•	Surface Water Quaff / Data
SLIDE 22

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SLIDE 23
PCAP Discharge Data (Millions of Gallons)
December 1992 - May 1993
E3 Source Wells
¦, Blocking Wells
O? Off-Site Wells
¦ All Wells
Decemb er Janua ^ruary V' rt April May
SLJDE 2-

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PCAP EDC Mass Removal Rate (Pounds Per Day)
2500
2000 -
1500
1000 -
~	Source Wells
¦	Blocking Wells
~	Off-Site Wells
¦	All Wells
4/92
7/92
2/93
SLIDE 25
SLIDl. 26
Moore
LEGEND:	O
m TseessewvER
• BLOCKING SYSTEM
SOURCEAREA
REMEDIATION SYSTEM
O OFF-SfTE PUJME
REMEDIATION SYSTEM
m _ EOUtPOTCKTlALUNg
(FeET, MSL)
GSOWOWATCRROW
DRECTJON
PLANT
NORTH
Jn:
TRUE
NORTH
Map with PCAP In

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Off-Site EDO Plume:
Pre-PCAP
(October 1991)
^4299
AmCXaMTE 9CAL6 M FSST
Off-Site
Groundwater
Quality
Restoration
LEGEND:
MONITORING
•	WELL
A EXTRACTION
*	WELL
Off-Site EDC Plume:
PCAP Operational
(February 1993)
®<5
5.74#"
,VV<5
	5.47
•<5> gg <54- «$'
®<5
\y
r
k
i
¦muE
NORTH
/
/
V*6
APPnOXMKre 3CAUE i* FEST

SLIDE 27
EDC Concentrations (jxg/L) - Tennessee River
Pond	PCAP
Closure	Implementation
1986 - 88
1983-91
1991 - Present
SLIDE

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^ A-*.- '.
SLIDE 29: Summary

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Christian J. Orsborn
Regional Environmental Manager, The Geon Company
Mr. Orsborn graduated with a Bachelors Degree in Chemical Engineering from
Cleveland State University, Cleveland, Ohio in 1956, and has taken graduate courses at
Murray State University and Southern Illinois University.
He started his career as a design engineer with the BFGoodrich Company in Calvert
City, Kentucky. After two years he was promoted to the Plant Environmental Engineer,
and for the next twenty-six years conducted the environmental affairs for the Calvert City
complex. Mr. Orsborn is presently a Regional Environmental Manager for The Geon
Company, with responsibility for four Geon facilities in three states, including the Calvert
City Site Remediation.
Over the years, Mr. Orsborn has been involved in chlorinated organics waste water
treatment world wide as part of BFGoodrich's licensing program. His major challenges
have been to guide the renewal of the forty year old complex with process modification to
prevent waste generation and the remediation of past operations.
As an Environmental Professional, he has been responsible for all facets of
environmental but chiefly Waste Management: RCRA Interim Facilities, Closures, Post
Closure Part B Permit, Solid Waste Management Units RFA, and CERCLA PRP site
remediation.
Mr. Orsborn has served on committees of Kentucky and National Trade
Associations, Kentucky department of Environmental Protection, and local forums and
boards.
BFGoodrich has honored Mr. Orsborn with two prestigious awards recognizing his

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p
Cardinal.

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CASE HISTORY
Integrated Site Remediation System Using High Vacuum Application to Address
Ground-Water Extraction, Soil Venting, and In Situ Biodegradation
H. James Reisinger1
Perry Hubbard, Jr.1
Stewart A. Mountain1
Charles W. Brigham2
1. Integrated Science & Technology, Inc.
1349 Old Highway 41, Suite 225
Marietta, Georgia 30060
2. Chevron, USA, Inc.
2300 Windy Ridge Parkway, Suite 800
Marietta, Georgia 30067
BACKGROUND
During subsurface assessments conducted in 1989 and 1990 at a Georgia gasoline retail facility,
petroleum hydrocarbons were found in soil and ground water. This resulted in the need to
develop a site remediation system. Further, the presence of community drinking water wells
downgradient of the site dictated development of a system that would eliminate the soil residual
hydrocarbon secondary source, control the migration of dissolved phase hydrocarbons and
remediate ground water. While phase separated hydrocarbon (PSH) had been observed in one
onsite monitoring well sporadically, none has been detected in any site monitoring wells since
initiation of remediation, and therefore, PSH recovery was not included in the remediation
system design. Due to the presence of downgradient receptors, hydraulic control of the
dissolved phase hydrocarbon plume was an integral part of the overall system design. Given
these objectives, it was determined that the optimal approach to remediation of this site was
integration of ground-water extraction, treatment and reinjection, soil venting, and in situ
bioremediation-based techniques.

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This site is situated in the Southern Piedmont Physiographic province. The site soils are
comprised of unconsolidated fine silt and clay-sized material (residuum) to a depth of 6 to 12
feet, underlain by a weathered gneiss (saprolite). The unconfined water table aquifer resides in
the saprolite. Seasonal fluctuations in static depth to ground water are pronounced and range
from approximately 10 feet during wet periods to 25 feet during dry periods. Hydraulic
conductivities calculated from multiple rising head aquifer tests ranged from 0.16 to 0.73 ft/day
(0.45 ft/day average). The ground-water gradient across the site under static conditions (i.e. no
pumping influence) was 0.027 ft/ft toward the east. Ground-water velocity was estimated to
range from 0.04 to 0.20 ft/day during non pumping conditions. Just prior to initiation of
remediation, dissolved phase hydrocarbon concentrations, specifically total benzene, toluene,
ethylbenzene and total xylenes (total BTEX) concentrations, in site monitoring wells ranged from
less than analytical detection limits to 47,800 /xg/L. The centroid of the dissolved phase
hydrocarbon plume is situated near the former tank field and dispenser islands and the plume
covers most of the south and central portions of the site (Figure 1). Dissolved phase plume
migration reflects the local topography and ground-water gradient under non-pumping conditions
(Figure 2).
THEORETICAL CONSIDERATIONS
Mathematical modeling, used to optimize the remediation system design suggested that the
maximum sustainable yield from conventional extraction wells in this formation was about 0.1
gallons/minute/well. Due to the very low yield, it was determined that an excessive number of
conventional extraction wells with down hole pumps would be needed to control and remediate
the dissolved phase plume. An alternative solution involved the use of a construction dewatering
technique to enhance ground-water extraction rates.
Vacuum enhanced ground-water recovery was proposed as a means to increase the vertical and
horizontal dissolved phase plume capture zones and to improve withdrawal rates of the ground
water recovery system. In this approach, a high vacuum (10 to 25 in Hg) is applied to a sealed
well through a drop tube. The vacuum is then used to extract the water and to enhance the rate
of recharge to the well.

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MW—7	MW—6
[0]	[0]
LEGEND
-MONITORING WELLS
[123] -
BENZENE
CONCENTRATION
(ug/0
	123 -
ISO-
CONCENTRATION
CONTOUR (ug/l)
		
PROPERTY
UNES


50
SCALE IN FEET
100
Figure 1
ISO-BENZENE CONCENTRATION
4 DECEMBER 1991
PRE-SYSTEM STARTUP

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M
-^•MW-6
[658.28]
— 658.0
50
SCALE IN FEET
100
Figure 2
STATIC (No Pumping)
WATER TABLE CONTOUR MAP
JULY 1990
LEGEND
-MONITORING WELLS
	nn WATER TABLE
12J.U0 CONTOUR
Asm _ WATER TABLE
Y® FLOW DIRECTION
r 123 001 -WATER TABLE
L1Z3.00J ELEVATION
PROPERTY
' LINES

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Vacuum enhanced ground-water recovery has its basis in the construction industry (Powers,
1981). The earliest evidence of dewatering in construction projects dates back to early Egyptian
and Roman times and was part of aqueduct and water tunnel building. The Dutch Polders are
also examples of activities that involved dewatering. The earliest evidence of the use of vacuum
in dewatering practice dates back to the 1700's when James Watt utilized an above ground
vacuum piston pump to power a bucket conveyor. The practice of construction dewatering
continued to evolve through the Industrial Revolution and into modern time. In the early 1900's,
wellpoints, "small diameter wells, driven into the ground and connected to a common suction
manifold (Powers, 1981), became commonly used tools in the U.S. construction industry.
Modern wellpoint dewatering systems often utilize droptube vacuum systems, in which vacuum
is applied to a tube installed in the well to a depth below the water table. Application of a
strong vacuum (i.e., 25 in Hg) is then used to extract water. In modern dewatering practice,
liquid ring pumps are often used to supply the vacuum because they can accommodate both air
and water flow.
Vacuum enhanced ground-water recovery has been practiced in the environmental field for a
number of years. Blake and Gaites (1986) describe a case study in which ground-water and
hydrocarbon recovery were enhanced significantly as a result of the application of vacuum at the
well head. Blake et al (1990) describe a vacuum enhanced recovery system deployed at a low
permeability site. In this paper, vacuum was used to enhance PSH recovery, ground-water
recovery, and soil vapor recovery. Clodfelter (1990) reports similar enhancement as a result
of vacuum application.
Application of a very large negative pressure (i.e., 10 to 25 in Hg), as is the case in vacuum
enhanced ground-water extraction, reduces the atmospheric pressure exerted on the subsurface
and allows water to rise, effectively increasing the hydraulic gradient to the well and saturated
thickness in the aquifer.
The greater saturated thickness increases ti j tra smissivity of the formation as described in the

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T = Kb
(Equation 1)
Where: T = Transmissivity
K = Hydraulic conductivity
b = Aquifer saturated thickness
As the vacuum is applied and water is simultaneously withdrawn, the total head in the well is
reduced. In a ground-water system, total head (hj is generally considered as the elevation head
(z) plus the pressure head hp. The elevation head component is reduced as water is withdrawn
and the level in the well decreases. This response occurs during pumping of any well, and the
decline in the water level steepens the hydraulic gradient between the well and the surrounding
aquifer, thereby increasing flow.
This relationship is further exemplified by Darcy's Law, where V-KI, and Q=KIA, where V
equals specific discharge, K equals saturated hydraulic conductivity, I equals hydraulic gradient
(dh/dl), and Q equals average cross sectional flow rate, reveals a direct proportional relationship
between specific discharge and flow rate to hydraulic gradient. Greater declines in water level
result in steeper hydraulic gradients and increased discharge rates. Application of vacuum to
the well further lowers the total head in the well by reducing the pressure head component. This
further increases the hydraulic gradient between the aquifer and the well, which results in
ground-water flow to the well at rates that are higher than can be achieved by standard pumping
techniques. As the water table in the aquifer declines, the vacuum is translated through the
dewatered cone of depression, thereby inducing an upconing of the water surface. This
effectively increases the saturated thickness, thereby increasing the transmissivity. As such, use
of a vacuum enhanced system can reduce the number of extraction points necessary for hydraulic
control and treatment of an impacted aquifer.

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fK'*'

SYSTEM DESIGN CONSIDERATIONS
Assuming a hydraulic conductivity of 0.16 ft/day and an average saturated thickness of 10 feet,
the transmissivity for this formation would be 1.6 ft2/day. In the case of the Southern Piedmont
site, if the negative pressure within the well bore is applied to the aquifer at a level of 11-in Hg
(12.463 ft H20), and no water is withdrawn, the rise in saturated thickness at the interface with
the well bore would correspond to this decrease in confining atmospheric pressure. If the
saturated thickness at the well bore is effectively increased by the negative pressure (12.463 ft)
and the hydraulic conductivity is held constant, the transmissivity is 3.594 ft2/day, or a factor
of 2.3, assuming uniform application of vacuum over the affected area.
The vacuum source selected for this site was liquid ring pumps. This type of pump produces
the high negative pressures needed for enhanced water production and is also capable of
pumping considerable quantities of air without damage. By using this equipment, the
remediation system has the capability to extract soil residual hydrocarbons via advective soil
venting and induce flow of atmospheric air containing oxygen to the subsurface, as well as to
withdraw ground-water at higher rates of flow.
Remediation of the soil residual hydrocarbon will eliminate the vadose soils as a secondary
source of contamination to the ground water. The remediation of the vadose soils will, thereby,
serve to enhance the progress of the ground-water cleanup and reduce the duration of the
ground-water remediation.
The two primary mechanisms, volatilization and biodegradation, used in this remediation
approach will also efficiently address any remaining, localized residual PSH trapped in the smear
zone above the water table. Since the application of vacuum also results in aspiration of ambient
air to the subsurface, the concentration of oxygen to support aerobic biodegradation is increased.
The site is outside the Atlanta air quality non-attainment area, and the applicable discharge air
quality standard, according to the Georgia UST °rogram, Air Emissions Permitting and
Monitoring of Soil Remediation Units ( "k'elinos. is u • 550 lbs/day of volatile organic

-------
compound emissions. Experience in similar geologic settings showed that this limit could be
met, and that a radius of influence of approximately 50 feet about each of the extraction points
could be achieved.
The system was designed with the assistance of computerized optimization modeling, which
provided a means by which the efficacy of the approach could be evaluated prior to installation.
The optimized design, based on the mathematical simulations, included ten combination ground-
water and soil vapor extraction points, two liquid ring vacuum pumps, a liquid phase carbon
treatment system, two infiltration trenches, and seven monitoring wells. The overall system
configuration is shown in Figure 3. The extraction points were configured in three separate
zones and interfaced with the pumps through a common manifold. This design provided for
extraction of ground water and soil vapor from discrete areas of the site, and to be controlled
and varied as conditions warranted, thereby rendering the system highly flexible. Figure 4
depicts the system configuration super-imposed on the estimated zone of soil residual
hydrocarbon. The computer model used to optimize the ground-water recovery system was also
used to simulate the infiltration trenches. In this way, the trenches were located and configured
to improve hydraulic control of the dissolved phase plume.
PROCESS CONSIDERATIONS
The system removes ground water from the extraction points via application of a vacuum
through drop tubes. These 2-in polyvinyl chloride (PVC) tubes are set in 4-in PVC wells to a
depth of 25 feet to achieve hydraulic control and to remove dissolved phase hydrocarbon (Figure
5). A vacuum is applied to the extraction points via the two liquid ring pumps. These pumps
have the capacity to move water at a rate of about 50 gallons per minute (gpm) and to develop
a negative pressure of 25 in Hg.
The system installed at this site was not expected to develop extremely high vacuums because
the extraction points were screened above the water table approximately 10 feet into the vadose.
Well head vacuums of approximately 0 in Hg were anticipated during normal operation due to

-------
4/.
->(~
MW-7

MW-6
ITREATMENT
1SYSTEM
•	^ rnuu
h^f). "
50
100
Figure 3
CONFIGURATION OF REMEDIATION SYSTEM
SCALE IN FEET
LEGEND
+
—MONITORING WELLS
4"
-EXTRACTION POINTS

	 -ZONE A

	 -ZONE B

	 -ZONE C

	-DISCHARGE

PROPERTY

LINES

-------
-ZONE A
-ZONE B
-ZONE C
-DISCHARGE
PROPERTY
' LINES
J ESTIMATED ZONE OF
I RESIDUAL HYDROCARBON IN SOIL
100
SCALE IN FEET
Figure 4
ESTIMATED ZONL OF
RESIDUAL HYDROCARBON IN SOIL

-------
Figure 5
REMEDIATION. WELL CONSTRUCTION DIAGRAM

-------
the vadose exposure. Application of the negative pressure lifts the water in the drop tubes and,
coincident with dewatering of the well, aspirates in vadose atmosphere. The vadose air then
becomes entrained in the water, effectively lowering the water column specific gravity, which
allows the water to be drawn back to the pumps. Despite the application of less than 15 feet of
water negative pressure (13.2 in. HG) in the tube, this lifting of the water in the drop tubes can
occur at depths greater than 15 feet because of the air entrainment. The extracted water is
treated by activated carbon adsorption. After the water has been treated, it is allowed to
infiltrate into two trenches located along the upgradient and cross gradient property boundaries.
Water is removed from the extraction point until the ground-water level declines below the drop
tube (Figure 5). The screens within the ground water recovery wells extend above the water
table to within 5 feet of the surface allowing extraction of soil vapors by the liquid ring pumps.
When the extraction point is dewatered, the negative pressure is then applied to the vadose zone.
This results in an increase in the rate of ground water and vadose air flow, and enhances the rate
of volatilization of soil residual hydrocarbons. This design allows both vadose hydrocarbon and
smear zone hydrocarbon to be addressed under dewatered conditions. Seasonal water table
fluctuations expose an even greater portion of the smear zone, thereby further enhancing
secondary source removal.
Upon initiation of system operation, the zone of negative pressure influence in the vadose and
smear zone is at its minimum as a result of the presence of vadose zone water and water in the
newly exposed smear zone. As the system operates, not only are the hydrocarbons in the vadose
and smear zones volatilized, but the vadose and smear zone water also gravity drains and
volatilizes. Water evaporation and gravity drainage opens the soil pores, which results in
enhanced air flow. Continued operation further desiccates the formation and air flow is further
enhanced.
Assuming a 50-ft zone of vadose influence, coverage of the zone of contaminated soil was
achieved by the design spacing of the extraction wells. This full coverage can be visualized by
examining Figure 4 and considering 50-ft radii around each of the extraction wells. Placement
of some of the wells near the periphery of the contamination ensured complete coverage of the

-------
The applied vacuum induces the aspiration of ambient air to the subsurface. This increases
oxygen concentrations, which in turn increases the rate of hydrocarbon biodegradation. During
the operation of the ground-water extraction system, aquifer drawdown results in exposure of
the hydrocarbon smear zone. This dewatering will increase vapor flow through the smear zone
soil pores and further promote biodegradation of the hydrocarbon that is impacting the ground
water. Utilization of this approach will expedite both ground water cleanup and remediation of
the soil residual hydrocarbon in the vadose.
The extracted water, hydrocarbon, air and vapor are conveyed through the liquid ring pumps
to a water knockout chamber (Figure 6). In this chamber, the water and entrained vapors are
separated by gravity. The vapors are discharged from this chamber through a stack to the
atmosphere and the water falls into a surge tank. The surge tank is equipped with two high
(HH, H) and two low (LL, L) water level sensors. The upper high level sensor (HH)
deactivates the system if an overfill condition is reached in the surge tank. Since a portion of
the extracted water is used as seal water for the liquid ring pumps, it is necessary to have a low
(LL) water level sensor to protect the pumps. The surge tank high level (H) and low level (L)
controls are used to activate/deactivate a high head centrifugal pump which transfers water
through a serial filtration system consisting of a high capacity bag filter and parallel particulate
filters. Pre-filter and post filter gauges measure head losses across the filters, and excessive
pressures indicate the need for a filter change. The filtered ground water continues to a liquid
phase activated carbon system in which the dissolved phase hydrocarbons are removed by
adsorption. The integrity of the carbon canisters is protected by a pressure switch which
monitors canister back pressures and signals fouling of the carbon. Following treatment, the
water is discharged to two infiltration trenches, located along the sides and rear of the facility.
A monitoring program was designed to insure that the system remains operational and that it is
addressing the objectives of remediation. This program specified that the operational aspects
of the system be inspected on a weekly basis through the first month of operation. Additionally,
the influent and effluent to the liquid phase carbon system and off-gas quality are monitored
monthly and the monitoring wells surrounding the extraction points are gauged and sampled on

-------

-------
a quarterly basis. The concentrations of benzene, toluene, ethylbenzene, and xylene (BTEX)
are determined in the influent and effluent water samples, as well as in ground-water samples
collected from the seven monitoring wells. The concentrations of total volatile hydrocarbons,
benzene, toluene, and total aliphatic hydrocarbons are monitored in the off-gas from the system.
These values are reported after they are normalized relative to toluene. Monitoring, as described
above has been carried out since system operation was initiated.
SYSTEM OPERATIONAL SUMMARY
The system was activated in January 1992. Overall system performance during the first year
exceeded expectations. However, several problems did occur and these were addressed with
minor modifications to the design or by operational changes. During the first two weeks of
operation, the silt filters clogged frequently and one of the carbon canisters failed as a result of
excessive pressure. It is normal for some siltation to occur early in the operation of a ground-
water treatment system before the extraction wells are completely developed. The silt filters and
carbon canisters were replaced and the system operated efficiently until March. In mid-March,
the site area received a significant amount of precipitation which caused the siltation problem
to reoccur. It was determined that the partially unpaved rear zone (Zone C) was the primary
source of the siltation (Figure 3). At the end of March, the vacuum to the rear zone was shut
off, one of the vacuum pumps was deactivated, and the siltation problem subsided.
In June 1992 the level switches controlling the operation of the centrifugal transfer pump and
monitoring of available supply of make-up water to the liquid ring pumps began to malfunction
sporadically. The earlier problems with filter plugging and over-pressurization of the carbon
canisters also began to occur more frequently. Both operational problems were the result of
increased ground water yield and silt loading from the aquifer. After a number of unsuccessful
attempts to correct these problems with additional operational changes, it was decided to modify
the system. The modifications were initiated in November 1992 and completed early in 1993.

-------
Modifications to the system made no significant changes to the remediation scheme. Instead,
they were intended to address operational problems created by the fine-grained sediments and
encrusting compounds (e.g. iron) present in the untreated ground water. These changes included
adding a 5 micron high capacity bag filter between the pump leading from the water removal
tank to the carbon canisters. This inline bag filter was installed directly after the transfer pump
to reduce plugging and increase the service life of the 5 micron cartridge filters and carbon
canisters. A third carbon canister was also added to the system. The three canisters are now
operated in parallel rather than in series to reduce back pressures within the canisters which are
rated at only 7.5 psig. This modification further enhanced system efficiency by increasing the
hydraulic retention time and thus, adsorption. The final change to the system involved
replacement of the water tank contact level switches with external non-contact sensors. By
making this change, the earlier failures of the level switches, due to encrustation and fouling,
could be essentially eliminated as a source of system malfunction. A schematic of the modified
system is provided as Figure 6.
A total of 773,294 gallons of ground water was extracted, treated and infiltrated during the first
year of remediation system operation (1992). No water accumulation was observed in any of
the infiltration trench observation points. This would suggest that the trenches were of adequate
size and capable of handling the flow produced by the system. This conclusion is further
supported by the-fact that the first year of operation was coincident with a significant amount
of precipitation. Analysis of the ground-water recovery data showed that the system withdrew
water at an average rate of about 1.47 gallons per minute (gpm). This rate of extraction exceeds
the anticipated ground-water withdrawal of 1 gpm (i.e. 10 wells x 0.1 gpm/well) by 47%. This
increase demonstrates the positive effect that vacuum application can have on well yield. The
improvement over the course of the year would have been even more pronounced had the system
not experienced periodic shutdowns due to fouling of particulate filters and carbon canisters.
A total of 761,669 gallons of ground water was extracted treated and infiltrated through the first
three quarters of the second year of remediation. This translates to an average ground-water

-------
despite an extended lack of precipitation from the beginning of the summer through the fall.
This extended drought condition severely reduced available water for pumping, which in turn
affected the liquid ring pump makeup water supply. Water levels in the monitoring wells nearest
to the onsite pumping wells of primary concern (i.e., MW-1 to EP-10, EP-7; MW-3 to EP-9)
dropped dramatically from approximately 13 feet below top of casing to approximately 21 feet
below top of casing from February to October 1993. Water levels in other onsite wells
responded similarly to the extended drought conditions as evidenced on Figure 7, which
graphically displays the drop in water table in onsite wells through the period.
Pumping efficiency decreased in response to the drop in the water table. However, due to the
increased exposure of the vadose and smear zones, achievable vacuums at the well heads
decreased to less than 8 in Hg on 30 June 1993; This reduced level of vacuum applied to the
drop tubes was insufficient to raise the water from depths exceeding 15 feet.
In July 1993, a determination was made to focus the remedial effort on soil vapor extraction
by raising the drop tubes from 25 feet to 15 feet in the extraction wells in Zones A and B since
these zones contained the vast majority of the residual soil hydrocarbon (Figure 4). Zone C
(Figure 4) was shut down at the extraction manifold. In order to supplement water recovered
from the extraction points, an auxiliary make up water supply system was installed. This system
consisted of two-550 gallon tanks piped in series. These tanks were filled with tap water and
plumbed for gravity feed to the surge tank, the source of make up water to the liquid ring
pumps. Water from the auxiliary tanks was added to the surge tank at a rate greater than that
required by the liquid ring pumps for seal water. The auxiliary water supply tankage was
constructed with an overflow to the infiltration galleries to accommodate surplus water extracted
from the recovery wells. The system functioned in this mode until October 1993.
The rational for the decision to focus the system on venting during the drought period was to
remove exposed smear zone hydrocarbon as aggressively as possible during the extremely low
water table conditions. Smear zone hydrocarbons represent a significant secondary source of
contamination to the ground water, since this area is typically in intimate contact with the upper

-------
FIGURE 7
WELL GAUGING DATA 1993
Depth To Water
DATE
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
2/27/93
12.27
11.1
13.68
11.68
12.06
12.08
9.88
3/29/93
12.73
9.97
15.51
9.67
13.03
7.27
7.1
5/19/93
14.69
12.97
17.51
12.74
15.43
11.08
12.77
7/26/93
16.32
14.92
17.42
15.23
17.41
19.5
18.08
10/20/93
20.33
18.84
21.33
19.08
21.1
23.63
21.98
Monitoring Date
	¦—
MW-1

- MW-2

MW-3
	o—
MW-4
	*—
MW-5
	£s—
MW-6
	•—

-------
saturated zone. As evidenced by information outlined later in this paper relative to removal of
VOC via the various remedial mechanisms, venting and enhanced biodegradation in the vadose
zone removes significantly more VOC mass than ground-water pumping. The other rational for
focusing the system on venting/bioventing during the low water table period was that the ground-
water velocity throughout the site is estimated to be between 0.04 and 0.2 ft/day. A maximum
distance of plume migration of approximately 20 feet was considered acceptable during the
period of focused venting. Using the values of ground-water velocity given above, the distance
of plume migration, during the 100 day period of focused venting, is between 4 and 20 feet.
This migration is not deemed to be significant and was reversed upon reinitiation of pumping.
Pumping from selected extraction points (EP-4, EP-7, and EP-9) was restarted in October 1993.
This was done in anticipation of rising water table conditions and to re-establish hydraulic
control prior to significant migration of dissolved hydrocarbons. The ability to pump during low
ground-water levels was achieved by shutting down Zones B and C, and extracting only from
Zone A. Extraction points EP-4, 7, and 9 (Zone A) were activated and the pumping of air and
ground water was observed from these wells. Improved well head vacuums ranging from 9 to
12 in. Hg were observed with all three wells open to the liquid ring pumps. Significant air
entrainment was occurring as the combined air flow through the stack was 85 SCFM, or on
average, 28.3 SCFM/well. The air entrainment, which lowers the water column specific gravity,
combined with the increase in average well head vacuum to 10.5 in. Hg (12 ft water), allowed
water to be lifted from depths greater than 20 feet.
One of the more important aspects of the extraction and treatment system is achievement of
hydraulic control over the ground-water and hydrocarbon movement beneath the site. A great
deal of this control is achieved via re-injection. In essence, extraction and re-injection render
the liquid mass beneath the site a recirculating system. Re-injection at the margins of the site
creates a mounding effect, thereby containing the dissolved phase hydrocarbon within the site
boundaries so that it can be captured and removed for treatment. Results of historical water
level measurements in site monitoring wells during the period of system operation are shown in
Figures 8, 9, and 10. These are water table contour maps of the site prepared from September

-------
4/.
LEGEND
MW-7 "V
[660.66]
MW-6
[660.76]
661.8"
MW-2
[662.14]
¦h-
-MONITORING WELLS
-123.00 -
WATER TABLE
CONTOUR
WATER TABLE
FLOW DIRECTION
rio^nm - WATER TABLE
J.1/J.UOJ ELEVATION
PROPERTY
' LINES
50
SCALE IN FEET
100
Figure 8
WATER TABLE CONTOUR MAP
SEPTEMBER 1992

-------
Ar-
LEGEND
MW-7"^"
[665.17]
MW-6
[665.02]
+-
-MONITORING WELLS
-123.00 -
WATER TABLE
CONTOUR
WATER TABLE
FLOW DIRECTION
T123 001 -WATER TABLE
L^J.OOJ ELEVATION
PROPERTY
LINES
50
SCALE IN FEET
100
Figure 9
WATER TABLE CONTOUR MAP
DECEMBER 1992

-------

7—
LEGEND
-MONITORING WELLS
WATER TABLE
izj.uu CONTOUR
WATER TABLE
FLOW DIRECTION
PROPERTY
LINES
50
SCALE IN FEET
100
Figure 10
WATER TABLE CONTOUR DURING REMEDIATION
MARCH 1993

-------
and December 1992, and May 1993 gauging data while the system was operating in ground-
water extraction mode. Examination of these figures indicates that the water table has been
depressed in the center of the site (the area with the highest hydrocarbon concentrations) and that
ground-water flow from all hydrocarbon-impacted areas to the extraction system is occurring.
Therefore, it appears that as long as pumping is maintained from the center of the site (EP-4,
EP-7, and EP-9) and that water is re-injected at the margins, hydraulic control of the dissolved
phase plume is maintained.
Ground water was sampled from the seven site monitor wells 4 December 1991 prior to
initiation of system operation. First year remediation ground water samples were collected from
site monitoring wells 7 March 1992, 9 September 1992, and 31 December 1992. Second year
remediation ground water samples were collected 30 March 1993, 20 May 1993, and 28 July
1993. Results of ground-water laboratory analyses covering the first 1.75 years of system
operation are presented in tabular and graphic form in Tables 1 through 5. The concentrations
of benzene, toluene, ethylbenzene, total xylenes, and total BTEX are provided in these tables.
During the first year of operation, concentrations of total BTEX decreased dramatically in
monitoring wells MW-1, MW-3, and MW-5 (the wells that have historically contained the
highest levels of dissolved phase hydrocarbon). Total BTEX concentrations in wells MW-1,
MW-3, and MW-5 decreased 49%, 20%, and 99%, respectively. Hydrocarbon concentrations
in ground water from three of the remaining wells (MW-4, MW-6, and MW-7) remained
constant at less than analytical detection limits. The concentration of total BTEX in well MW-2
increased primarily due to substantial rises in the levels of ethylbenzene and xylene. Benzene
concentrations have decreased in well MW-2 and were less than analytical detection limits in
December 1992. Dissolved phase hydrocarbons had decreased in this well from the first to the
third quarter of 1992, and the increase in the fourth quarter was unexpected. To address this
increase in dissolved hydrocarbon in monitoring well MW-2, pumping rates in Extraction Zone
B were increased in early 1993 and the withdrawal rate from Zone C, toward the upgradient side
of the property, was reduced.

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TABLE 1
Benzene Ground-Water Quality Data Summary (ug/L)
Date
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
12/4/91
10000
14
15000
0
900
0
0
3/7/92
5000
15
11000
0
140
0
0
9/9/92
5700
10
1200
0
6
0
0
12/31/92
5100
0
10780
0
4.5
0
0
3/30/93
4780
0
18300
0
6.7
0
0
5/20/93
3420
0
10900
0
5.3
16
0
7/28/93
2620
0
17600
0
185
42
0
o>
3
LU
z
LU
IM
LU
GO
	>-—
MW-1

- MW-2

MW-3

- MW-4
	*—
MW-5
	is	
MW-6
	0	
MW-7

-------
TABLE 2
Toluene Ground-Water Quality Data Summary (ug/L)
Date
MW-1
MW-2
MW-3
MW4
MW-5
MW-6
MW-7
12/4/91
24000
0
20000
0
440
0
0
3/7/92
11000
45
20000
0
170
0
0
9/9/92
11000
0
18000
0
6
0
0
12/31/92
10850
145
15320
0
4.5
0
0
3/30/93
10600
0
20400
0
2.9
0
0
5/20/93
8290
0
11400
0
1.1
0
0
7/28/93
6310
0
20100
0
44
0
0
25000
20000
3 15000
iu
2
ULI
3
O
H
10000
5000
0 dF
CT3
CN
CN
CT5
cn
—a—
	m	
	s	
	B	
	a
CM

co
CO
CN
CN





CN
CO
in


r—




Date



	m—
MW-1

- MW-2
	•—
MW-3

- MW-4
	4	
MW-5
	6—
MW-6
	O	

-------
TABLE 3
Ethyl-Benzene Ground-Water Quality Data Summary (ug/L)
te
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
¦/91
1800
88
1400
0
58
0
0
'92
1200
100
1500
0
15
0
0
'92
1300
53
1200
0
2
0
0
1/92
1320
1100
1700
0
1
0
0
793
1260
142
1240
0
0
0
0
/93
1380
238
911
0
0
0
0
/93
1570
207
1520
0
9
0
0
0 ®	«=	ft	ft	a	ft	ft
<—	CN	«N	C\l	cn	CO	CO
Oi	05	O)	Oi	a	CD	03
r*	o>	»-	O	O	00
?I	O	55	C2	C2	ES	ES
*-	cn	co	to

MW-1

- MW-2
	»—
MW-3
	o—
MW-4
	*—
MW-5
	6—
MW-6
	»—
MW-7

-------
TABLE 4
Total Xylenes Ground-Water Quality Data Summary (ug/L)
Date
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
12/4/91
12000
500
7600
0
320
0
0
3/7/92
7600
610
8200
0
86
0
0
9/9/92
8400
290
7000
0
8
0
0
12/31/92
7220
5010
7150
0
3.8
0
0
3/30/93
8660
770
6830
2.6
0
0
0
5/20/93
11200
1340
5910
0
307
0
0
7/28/93
10200
1000
8900
0
91
2.7
0
10000 --
CT>
$
CN
CN
OJ
cn
CN
OJ
oS
•—.
03
CM
Ol
n
CM
CO
CT)
o
CO
CO
CO
05
O
CN
in
CO
cn
oo
CN
	¦—
MW-1

- MW-2

MW-3
	o—
MW-4
	*—
MW-5
	£t—
MW-6
	•—
MW-7

-------
TABLE 5
Total BTEX Ground-Water Quality Data Summary (ug/L)
Date
MW-1
MW-2
MW-3 ¦
MW-4
MW-5
MW-6
MW-7
12/4/91
47800
602
44000
0
1718
0
0
3/7/92
24800
770
40700
0
411
0
0
9/9/92
26400
353
38200
0
22
0
0
12/31/92
24490
6255
34950
0
13.8
0
0
3/30/93
25300
912
46770
2.6
9.6
0
0
5/20/93
24290
1578
29121
0
10.1
16
0
7/28/93
20700
1207
48120
0
329
44.7
0
OS
CM
CM
OS
00

	»	

CM
CN
o
o>
Oi
m
cn
f—
o
OJ
cn
n

CN
CO




Date

CO
CT5
O
CN
ID
cn
oj
oo
CN
	a—
MW-1

- MW-2
	~—
MW-3
	o—
MW-4
	*—
MW-5
	6—
MW-6
	9	

-------
During the first two quarters of the second year of operation, concentrations of total BTEX
decreased in monitoring wells MW-1, MW-3, and MW-5 by 1%, 17%, and 27% respectively
(Table 5). Hydrocarbon concentrations in ground water from two of the remaining wells (MW-
4, MW-7) remained at less than analytical detection limits. The concentration of total BTEX
in well MW-2 decreased from December 1992 levels (6,255 /ag/L to 1,578 pig/L) and the
concentration in MW-6 increased to 16 ^g/L from less than detection limits. This observation
of BTEX at extremely low levels in MW-6 is not deemed significant based on the only one
sampling event. However, if the increases in total BTEX concentrations in well MW-6 continue,
the design of the system allows for adjustment of the pumping rate from this zone.
Extraction of ground water was diminished in favor of venting in July 1993 by raising the drop
tubes. Coincident with the cessation of pumping, the levels of total BTEX in the ground water
increased markedly in monitoring wells MW-3, MW-5 and MW-6. The total BTEX
concentrations in MW-1 and MW-2 decreased slightly, while concentrations in MW-4 and MW-
7 remained at less than analytical limits. To address the potential spreading of the dissolved
phase plume, pumping was reinstated in October 1993 in EP-4, EP-7, and EP-9. Pumping of
these wells would create a cone of depression within the center of the site, and reestablish
hydraulic control.
Figure 1 is a dissolved phase benzene isoconcentration map of the site prepared from ground-
water analytical data collected just prior to initiation of remediation (4 December 1991). Figure
11 is a similar map based on ground-water samples collected on 31 December 1992.
Examination of these two figures shows that the area of dissolved phase benzene impact was
substantially reduced during the first year of site remediation. Additionally, the concentrations
of dissolved phase benzene were reduced in all site wells during the initial one-year period.
Pump and treat helps to control migration of benzene and other BTEX compounds in the
subsurface through both advection and increases of promoting dissolved oxygen levels in the
subsurface as non-impacted water is brought into impacted areas. The increase in dissolved
oxygen levels in the subsurface promotes enhanced biodegradation of compounds such as

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50
SCALE IN FEET
100
iaure 11
ISO-BENZENE CONCENTRATION
31 DECEMBER 1992
AFTER 1 YEAR OF SYSTEM OPERATION
J

-------
benzene and reduces their spreading (Newman, et al, 1991.). This observed reduction in total
BTEX and benzene in both area and concentration indicates that the dissolved phase plume is
contained and remediated during active pumping and treatment from the extraction points.
Table 1 tabularizes the results of benzene analyses of ground-water samples from selected
monitoring wells. Examination of the table shows that the trend toward a reduction in dissolved
phase benzene continued until the site water levels dropped to approximately 16-18 feet below
grade by 30 June 1993. At that time, insufficient vacuum (< 8 in. HG) existed at the well heads
to extract ground water. Once the pumping was stopped at the end of the second quarter, the
system focus was shifted exclusively to soil vapor related remediation techniques (i.e. venting
and bioventing). This modification allowed more hydrocarbon to be removed from the
subsurface during the low water level conditions, but with the cessation of pumping, dissolved
phase benzene levels began to rise. In response to this, pumping from the center of the site was
reimplemented in October 1993.
Samples of the ground-water influent to the treatment system and effluent after carbon treatment
were collected on ten occasions during 1992. Table 6 provides both tabularized and graphical
representations of the system influent and effluent data. Examination of the influent data reveals
that the average total BTEX influent concentrations have increased from 586 ^g/L in 1992 to
1,662 jig/L in 1993. This increase in influent concentrations is likely the result of concentrating
the pumping focus in 1993 to the most impacted areas of the site, Zones A and B.
Based on the pumping volumes and average influent concentrations for 1992 and the first three
quarters of 1993, and assuming complete removal of dissolved phase volatile organic compounds
(VOC) by the carbon adsorption system, the mass removed by pump and treat in 1992 was 18.9
lbs or 2.8 gallons as gasoline. The mass of VOC removed by pump and treat in 1993 was 52.8
lbs, or 7.9 gallons as gasoline. The total mass removed by pump and treat over 1.75 years of
system operation is 71.7 lb or 10.7 gallons as gasoline.

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2000
1800
1600
1400
1200
1000
800
600
400
200
0
Table 6
Summary of Influent and Efluent Water Quality
Former Chevron Facility 43767
Date
influent Total BTEX
ffl/L
Effluent Total BTEX
P9/I-
3-Jan-92
N/S
69
9-Jan-92
N/S
0
23-Jan-92
N/S
5
2-Feb-92
380
0
8-Apr-92
1060
0
5-May-92
365
0
11-Jun-92
273
0
18-Jul-92
521
0
9-Sep-92
234
4
31-Dec-92
1269
0
30-Msr-93
1924
21
20-May-93
1400
1.1
28-Jul-93
N/S
N/S
N/S - No Sample Collected
Concentrations less than the analytical detection limit are reported 89 zero
Summary of Influent and Effluent Oround-Water Quality
Sample Date
" Influent Total BTEX

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Results of vapor flow and off-gas discharge sampling are shown in graphic form in Figure 12.
The discharge over the period of system operation (January 1992-October 1993) ranged from
15 SCFM to 105 SCFM, with an overall average of 80 SCFM. The atmospheric loading,
expressed in terms of total volatile organics as toluene, ranged from < 1 lb/day to 80 lbs/day.
Over the course of the first year of operation, the concentrations of the individual constituents
and of the total volatile organics decreased dramatically. Of the individual constituents
monitored, the aliphatic hydrocarbons made up the bulk of the total. However, all of the
measured constituents appeared to be decreasing at about the same rate as the total. The VOC
atmospheric loading was well below the allowable limit for the site of 550 lb/day. The estimated
total hydrocarbon mass removed over the course of the year, based on a time-weighted average
off-gas loading was 1,925 pounds or approximately 308 gallons of gasoline. Of this amount,
approximately 96 percent of the hydrocarbon vapors were removed in the first quarter of system
operation.
During the second year of operation, a significant mass of VOC (449 lbs) continued to be
removed by venting through the third quarter of 1993. This continuation of significant VOC
removal has been accomplished by focusing the extraction from the more impacted wells and
by reducing system down time. The drop in the water table from 12 feet to over 20 feet below
grade exposed the smear zone to venting which has further enhanced VOC removal. The total
mass of VOC removed by venting through the first 1.75 years of system operation was 2,375
lbs.
Functional aspects of the bioremediation aspects of the remediation system are assessed by
monitoring a number of key parameters including negative pressure in the monitoring wells,
hydrocarbon concentrations in the vadose (as measured through the monitoring wells),
hydrocarbon concentrations in the vapor extracted through each of the withdrawal zones, and
subsurface oxygen and carbon dioxide concentrations in the vadose (as measured through the
monitoring wells). Development of a negative pressure (as measured via magnehelic) greater
than 0.1-in H20 in the monitoring wells indicates that the system is advectively moving
hydrocarbon vapors and air through the vadose, thereby, increasing the rate of hydrocarbon
volatilization and biodegradation.

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FIGURE 12. Cumulative VOCs Removed By Venting

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To examine biodegradation rates, a measurement of subsurface respiration in onsite monitoring
wells was performed as part of a short term stop test. The results of initial measurements
indicated that the oxygen concentrations in the vadose atmosphere were being maintained at
levels greater than 15%. However, since the results of 02, C02 and VOC measurements were
made in monitoring wells, the vertical distribution of oxygen and hydrocarbon in the wells could
not be determined. Despite the short duration of the stop test, the data generated suggested that
biodegradation was a significant mechanism acting to accomplish overall site remediation.
Evidence of biodegradation included oxygen concentrations greater than 15% in MW-3 and MW-
1 where the hydrocarbon levels were relatively high; (at 6,800 ppm and 1,600 ppm,
respectively). Elevated (over background) C02 levels (9%) in MW-1 throughout the short term
test, and increasing C02 levels in MW-3 throughout the test, vacuum influence exceeding 0.1
in. water, which is indicative of air flow, in the monitoring wells prior to, and after the stop
test, and a decrease in oxygen concentration as function of time in wells with the highest
hydrocarbon levels under non-pumping conditions.
Given that the estimated zone of hydrocarbon impacted soil covers an area about 170-ft by 70-ft
and is estimated to be 10-ft thick, the total volume of impacted soil is about 119,000 ft3.
Assuming that the bulk density of the soil is about 1,440 kg/m3, the mass of the impacted soil
is about 4,849,488 kg. Assuming an observed minimum average biodegradation rate of between
0.5 and 2 mg/kg/day throughout the zone of soil residual hydrocarbon impact, the mass of
hydrocarbon degraded to date is estimated at between 2,200 and 8,800 lb or 330 to 1,300 gallons
as gasoline.
Given the mature nature of the hydrocarbon plume and observed biological activity in the vadose
zone, it is likely that there is also biological activity in the saturated zone. Typically, depressed
dissolved oxygen concentrations are found in the vicinity of moderate to high (1 to 10 mg/L)
dissolved phase hydrocarbons (Newman, et al, 1991). At such low concentrations, oxygen
availability usually becomes the limiting factor for biodegradation of the dissolved phase
organics. At dissolved oxygen levels of 2 mg/L or greater, biodegradation of BTEX compounds
should become markedly increased and can play a substantial role in dissolved phase remediation
(Chiang, et al, 1989) . This has been termed intrinsic remediation in the literature.

-------
It is proposed to initiate monitoring of intrinsic bioremediation parameters, such as dissolved
oxygen, iron, sulfate, nitrate, and nitrite concentrations to see if levels (e.g., dissolved oxygen
at 2 mg/L) in the site dissolved phase hydrocarbon plume are available to promote in situ
enhanced ground water restoration. If sufficient dissolved oxygen levels exist in the dissolved
phase plume on the downgradient portion of the site, the migration of the plume will be further
controlled.
SUMMARY AND CONCLUSIONS
An integrated multimedia remediation system has been installed and operated at a retail gasoline
marketing facility. The system is comprised of a ground-water extraction and treatment
component, a soil vacuum extraction component, an in situ biodegradation component, and an
intrinsic bioremediation component. The energy to drive the integrated system is supplied by
two above ground liquid ring pumps. These pumps extract water, remove vapor phase
hydrocarbon, and aspirate air (oxygen). As such, the system simultaneously address
hydrocarbon in the ground-water, soil, and soil vapor compartments. Based on nearly two years
of system operation, the following conclusions regarding system efficiency and reliability are
offered:
1.	Dissolved phase hydrocarbon concentrations have been significantly reduced;
2.	Soil residual hydrocarbon concentrations have been significantly reduced;
3.	System operation has stimulated in situ biodegradation;
4.	71.7 lb of hydrocarbon were removed via ground-water extraction and treatment;
5.	2,375 lb of hydrocarbon were removed via vapor extraction;
6.	2,200 lb of hydrocarbon were removed via in situ biodegradation;
7.	The system was highly reliable after several initial mechanical problems were overcome
(i.e., siltation); and
8.	Ground-water extraction was enhanced by a factor of 47% as a result of vacuum
application.

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References
Blake, Steven B. and Michael M. Gates. 1986. Vacuum Enhanced Hydrocarbon Recovery: A
Case Study in Proceedings of the NWWA/API Conference on Petroleum Hydrocarbons
and Organic Chemicals in Ground Water - Prevention, Detection, and Restoration. Water
Well Journal Publishing Company, pp 709-721
Chiang, C.Y., et al. 1989. Aerobic Biodegradation of Benzene, Toluene, and Xylene in a
Sandy Aquifer - Data Analysis and Computer Modeling in Ground Water, Volume 27,
Number 6, November-December 1989.
Clodfelter, Chris L. 1990. A Method for Evaluation of the Effectiveness of Vacuum Enhanced
Ground Water Recovery Systems in Proceedings of Fourth National Outdoor Action
Conference on Aquifer Restoration, Ground Water Monitoring and Geophysical Methods.
Water Well Journal Publishing Company, pp 73-82.
Newman, William A., and Greg Ki.noall. 1991. Dissolved Oxygen Mapping: A Powervul
Tool for Site Assessments and Ground-Water Monitoring in Ground Water Management,
The Fifth National Outdoor Action Conference on Aquifer Restoration, Ground Water
Monitoring, and Geophysical Methods, May 13 - 16, 1991, Las Vegas, Nevada, ppl03.
Powers, J.P. 1981. Construction Dewatering. Wiley and Sons, pp 484.

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p
Cardinal.

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EPA Region IV RCRA Groundwater Remediation Conference
December 1-3, 1993
Atlanta, Georgia
An Overview of the RCRA Corrective Action Program at CYTEC
Industries' Santa Rosa Plant, Milton, Florida
A RCRA corrective action groundwater remediation system has been
operating at the facility since early 1990. Several incidents from 1983 to
1986 resulted in discharges of non-hazardous wastewater from a Resource
Conservation and Recovery Act (RCRA) impoundment to groundwater,
which triggered implementation of the corrective action program. This
paper presents an overview of the regulated facility, hydrogeologic
conditions beneath the site, permit requirements, and hydraulic and water
quality effects from program implementation. Problems and concerns
associated with the RCRA corrective action program at this facility are
summarized.
Presenters: William J. McElroy, P.E., is a Senior Groundwater Engineer at CH2M
HILL in Gainesville, Florida. Mr. McElroy is the Program Manager for
CH2M HILL's environmental engineering projects at the Santa Rosa Plant.
-He has more than 18 years of experience in water resources investigations,
contamination assessments, and remedial design. He is a registered
professional engineer in the State of Florida.
Neale Sharitz is the Manager of Environmental and Governmental Affairs
for CYTEC Industries' Santa Rosa Plant. Mr. Sharitz has worked at the
facility for over 33 years and has overseen the design, installation, operation
and monitoring of all pollution control facilities implemented at the facility.
He is a 1959 graduate from the West Virginia Institute of Technology in
Chemical Engineering.
Title:
Abstract:

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An Overview of the RCRA Corrective Action Program
at CYTEC Industries' Santa Rosa Plant, Milton, Florida
Presented at
EPA Region IV RCRA Groundwater Remediation Conference
December 1-3, 1993
Atlanta, Georgia
Presented by
William J. McElroy, P.E.
Senior Grouri3water Engineer
CH2M HILL
P.O. Box 147009
Gainesville, Florida 32614-7009
(904) 331-2442
K.N. Sharitz, Manager
Environmental and Governmental Affairs
CYTEC Industries, Santa Rosa Plant
1801 Cyanamid Road
Milton, Florida 32570

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What Is the Nature of the RCRA-Regulated Facility and Where Is It Located?
CYTEC Industries (a business unit of American Cyanamid Company) operates a synthetic
fiber manufacturing facility in the Santa Rosa Plant near Milton, Florida (see Figure 1).
One of the facility process wastewaters was once denoted as hazardous (D002) because
pH ranges caused it to exhibit corrosivity. This waste stream is discharged to a RCRA-
regulated surface impoundment (see Figure 2) where the flows are equalized, detained and
neutralized. The Resource Conservation and Recovery Act (RCRA) impoundment has a
surface water area of about 1.8 acres, a storage capacity of about 5.8 million gallons and a
double liner and leachate detection system. After a 2 to 5-day detention time, the
wastewater is treated by coagulation, sedimentation and filtration before disposal via a
Class I injection well.
What Triggered RCRA Corrective Actions at the Facility?
From 1983 to 1986, the-following incidents at the plant resulted in discharges to
groundwater:
° Spillage of a non-hazardous process solution containing about 14 percent
sodium thiocyanate (NaSCN) about 250 feet west of the impoundment
(May 1983)
0 Failure of the original single liner, which resulted in the discharge of an
estimated 2.6 million gallons of non-hazardous wastewater to groundwater
(October 1983)
•	Puncture of the new liner system by an impoundment aerator that
overturned (September 1984)
•	Minor spills of NaSCN in the impoundment vicinity (1985)
° Failure of transmission piping north of the impoundment, which resulted in
discharge of non-hazardous wastewater to groundwater (July 1986)
GNV/I00152AF.WP5

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After these releases, hazardous constituents and indicator parameters were detected in
groundwater samples from monitor wells in the impoundment-vicinity (see Figure 2). To
comply with conditions in the Florida Department of Environmental Protection (FDEP)
permit to operate the impoundment, substantial field investigations were completed and a
revised Corrective Action Plan for the RCRA impoundment area was prepared. The plan
was approved in April 1990.
What Are the Hydrogeologic Conditions beneath the Area?
Figure 3 shows the hydrogeologic cross-section just south of the impoundment area. The
main aquifer of interest beneath the site is called the sand and gravel aquifer and is the
primary source of drinking water in this part of northwest Florida. The aquifer is about
400 feet thick at the plant site and is comprised predominantly of sands with interbedded
lenses of gravel, silts and clays. The aquifer is separated into an upper unconfined zone
and a lower confined zone.
The upper unconfined zone extends from the water table (averaging about 30 feet in
national geodetic vertical datum [NGVD] elevation) to the top of a zone of low
permeability that occurs at about -50 feet NGVD. Site testing indicates a transmissivity
of about 22,000 gallons per day per foot (gpd/ft) for this portion of the aquifer.
The relatively shallow clayey sand stratum that occurs about 10 feet beneath the site can
temporarily p"5rch infiltrating rainwater during wet periods. Data indicate that about 20
feet of unsaturated sediment is present between the layer bottom and the water table of the
unconfined zone. Monitor well MW-20S (Figure 2) was installed to monitor the perched
zone, but this well is dry most of the time.
A confining bed in encountered between -50 and -80 feet NGVD. This laterally extensive
stratum is about 40 to 80 feet thick and confines groundwater in the lower portion of the
sand and gravel aquifer.
The lower confined zone is encountered at about -100 feet NGVD. This zone is
comprised largely of sand and gravel. Site testing indicates a transmissivity of about
38,000 gpd/ft for this portion of the aquifer. Plant water supply production wells are
located in this portion of the aquifer.
GNV/100152AF.WP5

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Site testing concluded that a poor hydraulic connection exists between the upper and
lower zones of the aquifer. Leakage was assessed to be about 2.75 x 10 3/day.
Past measurements indicate that groundwater in the upper unconfined zone generally flows
in a southerly to southeasterly direction through the waste management area (WMA).
There is a downward vertical gradient in the upper unconfined zone. The plant production
wells have caused a local reversal of groundwater flows in the lower confined zone from
southerly to northwesterly in the WMA vicinity.
What Are the RCRA Permit Requirements?
FDEP administers applicable portions of the federal RCRA program, which regulates the
impoundment. The FDEP operations permit defines the WMA as the surface
impoundment. The point of compliance (POC) is defined as an imaginary vertical surface
at the boundary of the WMA that extends down into the uppermost aquifer.
The required groundwater monitor wells (Figure 2) are completed at various depths,
mostly in the upper unconfined zone of the aquifer beneath the site as summarized in
Table 1. The permit defines monitor well MW-19 as the background well for the WMA
and monitor wells MW-21, MW-21D, MW-22, MW-25 and MW-30 as the POC wells.
The groundwater constituents of concern and the associated protection standards are
summarized in~Table 2. These and indicator constituents (that is, pH, temperature,
conductivity and turbidity) must be monitored quarterly.
The approved RCRA Corrective Action Program also included installation and operation
of a groundwater recovery system. The system includes recovery wells RW-2 and PW-4
(Figure 2). Well RW-2 is about 140 feet deep and pumps from the upper unconfined
portion of the aquifer. Well PW-4 is about 276 feet deep and pumps from the lower
confined portion of the aquifer.
The system was started up in April 1990. The flow rate for RW-2 has averaged about 42
gallons per minute (gpm) since start-up. The average PW-4 flow rate has been about 189
gpm during the period. From previous testing results, it appears that the effects of
operating PW-4 at the average flow rate s limited to a relatively small impact on water
GNV/I00152AF.WP5

-------
levels in monitor well MW-25 and does not significantly affect groundwater levels in the
upper portion of the aquifer.
What Have the Hydraulic Effects of the Recovery System Been?
FDEP has required several recovery system evaluations. Past system testing is
summarized below:
•	April 1990: Effects were monitored over a 10-day period during start-up.
The flow rates maintained during the period for RW-2 and PW-4 were 72
gpm and 188 gpm, respectively.
•	April-July 1991: Effects were monitored over a 90-day period. The RW-2
flow rate was decreased from 65 gpm to 48 gpm to 25 gpm during the
period. The flow rate for PW-4 was maintained at 200 gpm during the
period.
•	March 1992: Effects were monitored over a 10-day period. Flow rates for
RW-2 and PW-4 were maintained at 35 gpm and 200 gpm, respectively.
•	May-June 1993: Effects were monitored over a 30-day period. Flow rates
for RW-2 and PW-4 were maintained at 25 gpm and 150 gpm, respectively.
The RW-2 flow rate was increased to 50 gpm for 7 days after the 30-day
test.
Figure 4 shows the theoretical, steady-state capture zone that resulted from pumping
RW-2 at 25 gpm and 50 gpm during the recent 1993 testing. As in all past evaluations,
the measured transmissivity for the upper aquifer zone was used in the capture zone
calculations. The location of the stagnation points and shape of the capture zones are
determined by the direction and gradient of groundwater flow under non-pumping
conditions.
Recent and historical data indicate that a capture zone created by RW-2 at 25 gpm would
be expected to extend south to or near monitor well MW-28 (depending on the magnitude
of the prevailing gradient). The higher average flow rate (tha|Js, 42 gpm) maintained by
GNV/100152AF.WP5

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RW-2 since start-up is expected to extend the stagnation point and capture zone width to
and beyond MW-28. Available information indicates that the capture zone encompasses
the extent of dissolved groundwater organic contamination in the WMA vicinity.
How Has the Recovery System Impacted Groundwater Quality?
Figure 5 shows the changes in groundwater concentrations in three monitor wells from
March 1988 through August 1993. (The recovery system was started up in April 1990.)
Monitor well MW-22 (Figure 2) is west of the RCRA impoundment near the point of a
former discharge to groundwater and upgradient of recovery well RW-2. Monitor wells
MW-21 and MW-21D (Figure 2) are just upgradient and downgradient of RW-2,
respectively. Monitor wells MW-21 and MW-22 are screened in the middle portion of the
upper, unconfined aquifer while MW-21D is screened in the bottom portion of the upper
aquifer zone (Table 1). The constituents shown are tetrachloroethene, chloroform and
conductivity; these parameters were selected to represent conditions because of their
reported magnitude.
The changes in constituent levels for each well tell a similar story and show the following
groundwater quality trends associated with corrective action program implementation:
Constituent levels in MW-22 (former source area) have declined in a classic
negative exponential decay. The decline began before start-up of the recovery
systern. This exponential decay function is based on the concept that contaminant
concentrations are proportional to the amount present in the contaminated aquifer
zone. The exponential decay suggests that cleaner groundwater flowing through
the contaminated zone has resulted in a dissolution of contaminants that adhere to
the aquifer media. The decay rate might also reflect biological (or other) processes
that remove contamination from the groundwater system.
Constituent levels in MW-21 (just upgradient of RW-2) show a marked increase
following recovery system start-up. After about a year of operation, constituent
levels began to rapidly decrease in a somewhat negative exponential manner. The
changes suggest that the recovery system has effectively captured contamination
from upgradient and downgradient areas. The apparent asymptotic levels observed
GNV/100I52AF.WP5

-------
in the well reflect equilibrium concentrations that are significantly higher than
clean-up criteria.
In MW-21D (just downgradient of RW-2), which is screened in the bottom portion
of the upper aquifer zone, organic constituent concentrations began to increase
after a year or so lag time from recovery system start-up. These constituent
concentrations were below detectable levels before the increase, although
conductivity levels show a prior gradual increasing trend, which indicates some
hydraulic communication with the more contaminated upper aquifer zone. The
water quality pattern changes probably reflect groundwater flow field development
around the recovery well and the impacts of vertical flow components created
during development. Although less likely, the data might also indicate
establishment of the capture zone and the withdrawal of downgradient
contamination in the deeper portion of the upper aquifer zone that had previously
passed the well location.
What Issues Have Been Raised by the RCRA Experience at This Facility?
One of the major continuing issues has been establishing groundwater quality protection
standards that are below the practical quantitation limits for laboratory analytical
constituents. In our opinion, this regulatory practice does not serve a useful purpose and
places an unnecessary "collar" on permittees. It also provides a potential avenue for third
party interventions in the permitting process because permittees might not be able to
conclusively demonstrate that they meet the regulatory criteria.
Testing and information requirements often appear to be a "checklist" for the regulatory
agency without regard for whether the data are actually needed or for the costs of data
collection. For example:
• CYTEC has been required to complete substantive testing programs on the
recovery system on four occasions over the past 4 years. Generally, the
testing has resulted in similar assessments about recovery system
performance. The need for repetitive testing appears to be arbitrary.
GNV/100152AF WP5

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•	CYTEC is required to obtain, assess and report groundwater level data
quarterly. Historical information over the last 10 to 12 years has shown
that natural groundwater elevations, flow rates, and directions of flow have
been relatively stable and slow to change. Groundwater conditions in the
WMA are controlled by the recovery system, which reliably operates at a
relatively constant flow rate. The need to collect and report quarterly
groundwater level data appears questionable at this facility.
•	Recently, CYTEC submitted a Quality Assurance Project Plan (QAPP) as
part of the conditions for the re-issued permit. The QAPP was rejected
because it was not in the proper format. This appears to be an insignificant
issue that will result in unnecessary expenditures of time and money.
CYTEC already has an approved Comprehensive Quality Assurance Plan on
file with the regulatory agency that governs all analyses completed at the
site.
Another issue involves support for a regulatory trend that considers the cost-effectiveness
and feasibility of remediating groundwater quality to prescribed levels on the basis of the
public health and environmental risks posed by the contamination. Costs for remediation
programs continue to increase while the feasibility of meeting most clean-up criteria
remains marginal. The concept of risk-based remediation encourages expenditures of time
and money in areas where the need is best warranted and justified.
GNV/100152AF.WP5

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I
CO
O)
O
r
CO
(0
Cvj
CM
eg
(/)
0
1
Well
Elevations of Screened
Screen
No.
Interval (ft NGVD)
Length (ft)
19
+22.48
to
+17.48
5
20
+17.79
to
+12.79
5
21
+4.57
to
-0.43
5
21D
-29.76
to
-44.76
15
22
+12.47
to
+7.47
5
25
-52.59
to
-62.59
10
27
-16.96
to
-21.96
5
28
-14.86
to
-24.86
10
29D
-52.84
to
-67.84
15
30
+18.89
to
+8.89
10
30D
-36.24
to
-51.24
15
31D
-29.85
to
-44.85
15
32
-2.68
to
-12.68
10
RW-2
+17.92
to
-42.08
60
PW-4
-90.54
to
-170.54
80
Table 1. ®i
Summary of Well Construction

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Parameter
Standard
Phenol
5
/l
Acrylonitrile
5
ug/L
Cyanide
0.2
mg/L
Betasulfopropionitrile
10,000
ng/L
Sodium thiocyanate
1,000
^g/L
Nitrate
10
mg/L
Chloroform
2
ng/L
Tetrachloroethene
3
^g/L
Carbon Tetrachloride
3
^g/L
Trichloroethene
3
ug/L
1,1,2,2-Tetrachloroethane
2
ug/L
Acetone
100
^g/L
Arsenic
0.05
mg/L
Barium
2.0
mg/L
Beryllium
0.004
mg/L
Cobalt
0.07
mg/L
Chromium
0.1
mg/L
Copper
1.0
mg/L
Nickel
0.1
mg/L
Lead
0.015
mg/L
Tin
8.0
mg/L
Zinc
5.0
mg/L
Table 2. ®j

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Pace

To Pensacola
/

Scale in Feet
400	800
Project
Location
Escambia Bay
-—
Escambia Bay
FIGURE 1.
CYTEC Santa Rosa Plant Location Map.
CHMHI

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¦3 10/93
\///A Relatively Low Permeability
~¥~ Water Levels (Measured 3/13/92)	©J
FIGURE 3. —i
Hydrogeologic Cross-Section across WMA.

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Cyanamld Rosd
At 25 gpm
LEGEND
#	Groundwater Monitor Wells
®	Recovery Wells
t i	Theoretical Steady-State Capture Zone
— —	Groundwater Elevation Contours
DIS222.33 10/93
Cyanamd Road
At 50 gpm
Note: Contours indicate approximate average NGVD
elevations and are estimates of spatial variations
throughout the site. Actual levels may vary point to
point because of changes in hydraulic or other influences.
PW-4 pumping rate at 150 gpm during penod.
Well pumps from lower aquifer zone.

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DIS222 33 10/93
MW-22
MW-21
MW-21D
18S9	1890 1991	1992 1993
Conductivity (|imhos/cm) —
FIGURE 5.

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FCC ENVIRONMENTAL
TEL:601-938-2734
Oct 26'93 14:22 No.005 P.03
TITLE: FCC Ground Water Remediation - A Case Study
ABSTRACT: First Chemical Corporation has produced aromatic
chemicals at Pascagoula, Ms. since 1967. For many years,
waste treatment was provided with an open pond used as a
settling area to promote chemical precipitation of
nitrophenolic wastes. Through ground water sampling
performed in the mid-1980's, it was determined that
chemicals had been released into the ground water. With
the direction, support, and review of state and Federal
regulatory agencies, FCC investigated the extent and
nature of contamination of the ground water. A plan was
developed to remediate the site and implementation of
this phased plan began in 1986. Remediation of the site
was to be accomplished through the removal and disposal
of organic sludges from the treatment pond and through
the removal and treatment of the ground water through a
series of recovery wells. These actions have been
accomplished, and significant volumes of heavily
contaminated water and DNAPL have been recovered. Even
though some success has been achieved, FCC has continued
to evaluate the effectiveness of these remediation
efforts and additional improvements are now being
implemented to further improve the performance of its
remediation system.
SPEAKER: Donald Scharr, P.E.
Mr. Scharr graduated from Mississippi state University in
1977 with a B.S. in Civil Engineering. He has been
employed with First Chemical Corporation since March
1993. He is currently serving as Senior Environmental
Engineer responsible for all water-related environmental
issues - including NPDES and pretreatment permitting,
storm water, and ground water remediation. Prior to
joining First Chemical, Mr. Scharr was employed by the
Ms. Gulf Coast Regional Wastewater Authority for nine (9)
years and by the Ms. Bureau of Pollution Control for six

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tiNViKUiNntiN I HL	I LL : b(J 1 -938-2734	Oct 26'93 14:23 No .005 P.
FCC GROUND WATER REMEDIATION - A CASE STUDY
First Chemical Corporation (FCC) has owned and operated a chemical
plant since 1967, producing aromatic chemicals, primarily through
the nitration, hydrogenation, and distillation of benzene and
toluene. The FCC plant is located in the heavily industrialized
Bayou Casotte Industrial Park in the southeastern part of
Pascagoula, Mississippi. It is nearly surrounded by a large
phosphate separation plant and a very large oil refinery. No
residential or consumer/commercial properties are in the vicinity
of the FCC site.
From its formation in 1967, the FCC plant in Pascagoula has grown
steadily and expanded to meet the ever-changing regulatory and
product requirements. Contained on 40 acres, existing on-site
facilities include: a variety of units to meet production
requirements; maintenance facilities; storage tanks for raw,
intermediate and final products; multi-stage wastewater
pretreatment facilities; an incinerator for onsite disposal of
hazardous and nonhazardous wastes; rail, truck, and drum loading
facilities; administrative, engineering, and research facilities;
and two separate ground water remediation systems.
As part of the early treatment of wastewater at the FCC site, a
pond (Pond 3) was constructed approximately 110 feet wide and 360
feet long. The pond received waste streams from various production
processes and was used as a settling area to promote chemical
precipitation of nitrophenol wastes. During the early 1980's this
system was regulated as a RCRA interim facility and steps were
begun to close out Pond 3. Ground water sampling performed in
conjunction with these efforts indicated that chemicals had been
released into the ground water as a result of Pond 3 and FCC's past
operating -practices. Primary contaminants identified included
phenols, nitrobenzene, benzene, toluene, and aniline.
Consequently, FCC began a more complete investigation (termed a
Remedial Investigation) of the potential contamination at the site.
Identification of the extent of ground water problems, the source
of the contamination, as well as the development, approval, and
implementation of an effective solution is a lengthy undertaking.
FCC recognized that Pond 3 was, at the very least, the primary
source of ground water contamination. Plans were developed to end
this source of contamination by modifying the FCC treatment system
through elimination of Pond 3 and replacing it with an above-ground
treatment system. A solvent extraction/recovery system was
developed to reduce the volume of waste to be treated. (A patent
for this process was issued to First Chemical Corporation in May
1990.)
In addition, a source isolation system, comprised of a series of
recovery wells surrounding Pond 3, was installed (12/86) to prevent

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I" Lt t. IN V I K U IN PI C. IN I HL
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water. As a final step in this investigation, FCC conducted the
required Remedial Investigation to assess the extent of ground
water contamination.
In June 1987, FCC completed its Remedial Investigation. The
investigation utilized much of the information generated by
previous investigations at the site. Altogether their assessment
included data from 68 monitoring wells, 25 piezometers, and 33
borings. The hydrologic investigation included rising head
permeability tests, water level measurements, laboratory
permeability tests of undisturbed soil samples, and laboratory
tests of the physical and mineralogic properties of selected soil
samples. A wide variety of inorganic chemical, organic vapor, and
organic chemical analyses were performed on ground water, surface
water, soil, sediment, and Ponds l and 3 fluid contents.
Attachment l summarizes the hydrogeologic system at the FCC site.
The hydrogeologic evaluation identified these important factors:
1)	The Upper Sand is the unit most impacted by the release
of chemicals at the FCC site.
2)	Ground water hydraulics in the Upper Sand is controlled
by a combination of precipitation infiltration, high
evaporation, low hydraulic conductivity (<0. l feet/year) ,
and restricted vertical downward flow due to the
underlying Upper Clay aquitard.
3)	The ditches surrounding the FCC site effectively act as
hydraulic barriers to off-site lateral flow, providing a
source of recharge.
4)	Distinct barriers preventing the downward migration of
contaminants were identified and major aquifers were not
considered to be potential receptors of contamination
from the FCC site. {This has continued to be confirmed
by the ongoing ground water monitoring program.)
5)	Upper Sand was identified as having limited lateral flow
confining contaminants and restricting their potential
migration. (Review of the distribution of contaminants
confirmed lack of movement and migration.)
6)	Corrective action directed remediation efforts within the
Upper Sand.
The Remedial Investigation identified two distinct areas of
contamination at the site: one confined to the southeast corner
(approximately 1.8 acres) and one near the concrete storm drain and
west to the North-South ditch (approximately 10.9 acres).
The southeast corner revealed potential sources of contaminants
associated with such site activities as: potential spillage in the
loading/unloading area, potential leaks from staged railcars off-
site, and from previous wastewater discharge. (An additional
compound, 4-Oxo-pentanoic acid methyl ester, was detected in high
concentrations but has never been manufactured or used at FCC.
Original source is possibly from a rail tank car or tank truck

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t_ii v i i\um'ic.n i ml.
I ILL ¦ oui-^oo-/ roa
UCt 2b'36 14 =24 No.005 P.
industrial park.) Sampling in the southeast corner also identified
a dense non-aqueous phase liquid (DNAPL).
Potential sources of contamination near the concrete storm drain
and west to the North-South ditch include existing and previous on-
site ponds (Pond l# closed Pond 2, Pond 3, closed Pond 4), the past
use of an open effluent ditch (replaced by the concrete storm
drain), and the landfill area. Contamination from Pond 3, the
primary source of initial concern, appeared to be limited to a
distance of approximately 70 feet from the perimeter of the pond.
Based upon these other potential sources, FCC decided to expand its
recovery system to incorporate all suspected areas of
contamination.
As a result of this investigation and subsequent evaluations, FCC's
site remediation plan has continued to be developed and modified to
incorporate new findings into the design of our remediation system.
Our existing remediation system has been incorporated as a part of
FCC's Pond 3 Post Closure Permit. The remediation plan now
includes the following elements:
1)	Construction of a source isolation system to prevent
further migration of contaminants from Pond 3.
(Completed in 1986.)
2)	Installation of a DNAPL recovery system in the southeast
corner. (Completed in 1988.)
3)	Removal, treatment, and/or disposal of the liquid
contents of Pond 3. (Completed in 1988.)
4)	Removal of all visibly contaminated sediment in Pond 3.
(Completed in 1988.)
5)	Incorporating the existing source isolation system,
installation an expanded "pump and treat" system to
recover contaminated ground water. Although a recharge
trench system was originally considered to be used as a
part of this remediation, Pond 3 was incorporated into
the system after removal of the contaminated soils. By
filling Pond 3, it could be utilized to induce an
additional hydraulic surcharge to expedite movement of
the contaminated ground water to the recovery wells.
(Completed in 1990.)
6)	Contaminated ground water to be discharged into FCC's
patented onsite pretreatment system.
7)	Upon completion of successful remediation, Pond 3 to be
closed and capped in accordance with criteria established
by the Ms. Department of Natural Resources.
The source isolation system has been shown to have a capacity of 3
gpm, based upon the specific capacity tests of the individual
wells. The existing recovery system incorporates two separate
pumping systems - one for the southeast corner which includes 13
recovery wells and one for the Pond 3 location consisting of 44
recovery wells. Current recovery rates have not met the
anticipated recovery rates. FCC has implemented some changes which

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FCC ENVIRONMENTAL
TEL: 601-938-2734
Oct 26'93 14:24 No .005 P .07
proposed additional modifications to the system surrounding Pond 3
to improve its performance.
operational problems have been associated with flow measurement
equipment and vacuum leaks within the piping system. Vacuum leaks
have been located and repaired as detected. Flow measurement
equipment has been impacted by occasional silt recovered from the
wells and through deterioration from the material being monitored.
An evaluation is ongoing to resolve these problems through possible
replacement of equipment and/or modification of operational
procedures to more closely monitor the performance of the system to
identify potential problems earlier to anticipate and prevent their
occurrence, if possible. Results from this ongoing evaluation will
be discussed at the RCRA Conference in December 1993.
As previously stated, FCC is currently proposing modifications to
the existing remediation system. Data will be presented at the
RCRA conference outlining the "success" of the existing recovery
systems. In addition, the costs currently associated with our
remediation efforts will be discussed.
In summary, FCC has worked with EPA and the Ms. Department of
Environmental Quality to identify and effectively monitor and
evaluate the remediation of ground water at the FCC site in
Pascagoula, Ms. Our remediation of this site has been trial and
error, as with many ground water remediation efforts, and has
required an ongoing process of evaluation and modification. FCC
believes that it can identify the following accomplishments with
its current remediation efforts:
1)	Much of the DNAPL has been recovered in the southeast
corner of the site;
2)	Recovery/drawdown of the ground water in the southeast
corner has_been effective in containing the plume;
3)	Pond 3, once a source of contamination, is now full of a
variety of wildlife - brim, bass, frogs, ducks, etc.; and
4)	There has been no contamination of the lower aquifer.
First Chemical Corporation will continue striving to insure
successful remediation of the ground water contamination at the FCC

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CONCEPTUAL
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Groundwater and Soil Bioremediation in Karst Aquifer
by
Gregory J. Rorech, P.E.
Geraghty & Miller Inc.
Tampa, Florida, 33618
INTRODUCTION
A site investigation and in-situ bioremediation were conducted at a manufacturing
facility to identify and to remove a prominent source of odor, metal corrosion, and
groundwater contaminants. Three acres of a 20 acre facility were seriously affected. A soil-
gas sampling program revealed that a rotten egg odor originated from a variety of
subsurface sources including ground-water monitor wells, subsurface conduits (telephone,
electrical lines), and persisted in wind-protected areas of the facility. Soil-gas samples
contained highly elevated hydrogen sulfide (H2S) concentrations (up to 7000 ppm) and little
or no oxygen (<5%).
The project strategy proposed a two-phased approach: (1) the rapid exchange of
subsurface vapors with ambient air to remove the odor and to promote aerobic conditions,
and (2) a ground-water recovery, treatment and injection program to remove the ground-
water contaminants, and to improve the rate of natural aerobic bioremediation in the
aquifer. Because a highly anaerobic subsurface environment was suspected, an in-situ
bioremediation system was considered ideal to remove the contaminant source.
1

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A soil vacuum extraction (SVE) system was also used to assist the in-situ
bioremediation system. It was recognized that the SVE alone would neither remove the
source of hydrogen sulfide vapors permanently nor significantly lessen the concentration of
organic contaminants in the groundwater.
The in-situ bioremediation system was based on the results obtained from four major
activities: (1) ground-water investigation, (2) soil-gas investigation, (3) bacterial evaluation,
and (4) ground-water modeling. The methods used and results obtained from these activities
are presented below; they provided the basis to design the treatment program. The site
investigation was conducted between July 1988 and September 1990. Ground-water
remediation began December 1991 and is expected to continue for several more years.
Facility History
During initial facility construction in the 1960's and expansion in the 1970's,
subsurface pipelines were installed to transfer domestic and industrial wastes to either a
waste-water treatment or solvent recycling facilities. Over a 15-year period, subsurface
pipelines deteriorated and released liquid wastes into the subsurface. Accidental surface
spills and solvent delivery system failures may have also contributed chemicals to the aquifer
via storm drains.
Although hydrogen sulfide odors were evident for 10 to 15 years before the
investigation, severe metal corrosion problems and increased hydrogen sulfide odor
2

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complaints prompted a subsurface investigation to locate and remove the source. Samples
obtained from ground-water monitor wells and soil-gas probes indicated that the hydrogen
sulfide source was generated from a subsurface source, most likely a ground water plume.
Site Geology/Hvdrogeologv
The site geology is characterized as karst. Site soil borings were consistent and
reported consolidated limestone from land surface to approximately 20 feet (ft) below land
surface (bis). Soil borings logs and sample coring exhibited cavernous areas and highly
porous features.
Ground water direction of movement and aquifer characteristics were determined by
simultaneous water-table elevation measurements and pumping tests, respectively. Water-
table elevation fluctuations between 1.5 ft and 2.0 ft were recorded in monitor wells during
continuous measurements over a 24 hour period. These measurements corresponded to tide
responses that occurred approximately 2 hours after they were recorded in a harbor tide
gauge located approximately 1 mile from the site.
A thin freshwater lens (7 to 15 feet thick) was present beneath the facility. Water
quality results from facility background wells indicated that the water quality met USEPA
drinking water criteria. This condition prompted concern toward the groundwater recovery
program and the need to design a remediation system that protected the freshwater lens
from saltwater upconing during ground water pumping.
3

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SOIL-GAS INVESTIGATION
The soil-gas investigation was conducted to identify the lateral extent of hydrogen
sulfide odors and to determine whether soil-gas odors correlated to the location of the
ground-water plume. Soil-gas samples were collected approximately 3.5 ft bis at 40 locations
and analyzed for H2S and selected volatile organic chemicals (VOC) content using a
portable gas chromatograph (Photovac, Model 10S50).
The objective of the full-scale SVE was to capture soil-gases from the entire sub-
surface area that produced the odor. For this purpose, 24-SVE wells were drilled and
manifolded to one of five collection grids. Each grid (5 total) consisted of either 4 or 5 SVE
wells located in the area identified in the soil-gas survey and positioned to control vapor
capture and to accommodate the available space within the manufacturing area (Figure 3).
The SVE wells were located approximately 100 ft apart and connected to a blower (Rotron,
20 hp). In addition, 14 air inlet wells (AI-1 through AI-14) were drilled outside the grids
to assist with the introduction of ambient air beneath the site and move air toward the SVE
wells. Because of the extreme anaerobic environment beneath the facility, the introduction
of ambient air was considered essential to inhibit odor production.
The full-scale SVE lowered ambient H2S odors within the majority of the facility to
acceptable levels ( < 5 ppb) following four days of operation. After two weeks of operation,
the H2S concentrations measured in subsurface air samples were variable but had decreased
significantly. One, two, or three fold decreases in H2S concentration were reported in air
4

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samples from 21 of 24 SVE wells. Oxygen measured in 17 of 24 SVE air samples increased
to concentrations nearer ambient conditions (Figure 1).
GROUND-WATER INVESTIGATION
A ground-water investigation was conducted to identify the extent and nature of
suspected ground-water contaminants. Ground-water sampling was conducted at 18 monitor
well locations using standard procedures. Ground-water samples were collected for analyses
semiannually throughout the course of the investigation. The samples were analyzed for
VOCs, reduced sulfur compounds, and selected drinking water parameters. Ground-water
samples were collected both before and after the start of the in-situ bioremediation
program.
During all sampling events, a contaminant plume was identified beneath the
manufacturing, solvent recovery and storage areas of the facility. A variety of reduced
sulfur compounds (carbonyl sulfide, dimethyl sulfide, methyl mercaptan, propyl mercaptan,
and hydrogen sulfide), aromatic hydrocarbons (benzene, toluene, ethylbenzene, xylenes) and
other process chemicals (e.g., methyl tertbutyl ether, and diethyl ether) were detected.
Hydrogen sulfide concentrations were the highest among the reduced sulfur compounds
while benzene and diethyl ether were the highest VOCs reported.
5

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BACTERIAL EVALUATION
The purpose of the bacterial evaluation was to determine whether naturally-occurring
bacteria could degrade man-made chemicals at the site and to justify the decision to use in-
situ bioremediation. The presence of H2S vapors at the facility had been attributed to the
microbial degradation of organic chemicals in the ground water. The presence of elevated
H2S concentrations and low oxygen concentrations in the vadose zone indicated that
microbial degradation was occurring under anoxic conditions.
Based on limestone core samples retrieved during monitor well drilling, the
subsurface region that supported the highest microbial activity was believed to be located
between the vadose zone and the top of the water table approximately 20 ft bis. This active
microbial zone (AMZ) was several feet thick (20 - 24 ft bis) and influenced by the tide. The
microbial isolation and evaluation techniques addressed three data requirements: (1)
enumerate heterotrophic aerobic microbes, (2) evaluate bacterial metabolism of
contaminants, and (3) determine nutrient adsorption to the substrate (limestone).
Heterotrophic Aerobic Bacteria Enumeration Results
Two distinct areas of aerobic bacteria counts were reported. The highest aerobic
bacteria counts (1.7 x 107 to 2.1 x 107 CFU/gm[colony forming units per gram]) were
obtained from core samples obtained from areas with the least H2S odor: the solvent
recovery and the background areas. The lowest counts (2.2 x 104 to 7.8 x 105 CFU/gm) were
enumerated from core samples collected in the production building area; this area reported

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the highest H2S concentrations in soil-gas measurements.
Bacterial Contaminant Metabolism Results
The Direct Plating Method degrader plate count enumerations were low. Bacterial
counts ranged from no growth detected to an estimated quantity of 2.4 x 103 CFU/gm.
Bacterial growth was demonstrated on the majority of carbon sources evaluated. Bacterial
plates incubated in diethyl ether, benzene, and sulfolane demonstrated growth in 60% to
84% of the samples.
Using the Disk Diffusion Method, the results showed that bacteria isolated from
background, solvent recovery, and production buildings areas were capable of growth and
could metabolize each carbon source. No growth was observed around disks containing
toluene at 0.5 and 5 ppm for samples isolated from the solvent recovery and production
areas. Control disks (distilled water) showed no growth.
Nutrient Adsorption Results
The limestone column evaluation showed that ammonia and o-phosphate ion solution
at pH 7.6 had no affinity for limestone. The control column results indicated that neither
ammonia nor o-phosphate were present or liberated from the limestone column. Results
from the pH analyses indicated that the crushed limestone material tended to elevate the
pH approximately 0.5 to 1.0 pH units.
7

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GROUND-WATER MODELING
The essential element of the in-situ bioremediation treatment program was the
presence of freshwater aerobic bacteria. Because these bacteria are adapted to specific
salinity tolerances, it was considered essential that ground-water salinity remain within the
tolerances for bacterial growth and reproduction. Because freshwater resources are scarce
at the facility's location, protection of the freshwater lens from saltwater flow upwards was
considered a performance criteria for the remedial program.
Two conceptual models were performed: (1) to investigate the potential vertical
migration of saltwater near a recovery well, and (2) to determine the capture zones of the
proposed recoveiy wells (Figure 2). The saltwater upconing simulation was conducted with
the SUTRA (Saturated Unsaturated Flow and Transport) model by Voss (1984), and
included infiltration from rainfall and variable density effects. The steady-state capture zone
analysis was performed with MODFLOW (McDonald and Harbaugh 1988) and MODPATH
(Pollack 1989).
REMEDIAL DESIGN AND CONSTRUCTION
The in-situ bioremediation system was designed to fulfill several tasks: (1) recovery
of ground water from the contaminant plume, (2) support an acclimated bacterial
population, (3) removal of organic constituents from the ground water as it passes through
the aerobic biological unit, and (4) introduction and discharge of oxygen, nutrients, and
bacteria into the aquifer to enhance the in-situ biological degradation of contaminants. The
8

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partially treated ground water was designed to contain bacteria to be released from the
treatment unit and introduced into the aquifer to enhance in-situ biological degradation
(Figure 3).
The bioenhancement unit was 10'-2" X 10'-2" (internal dimensions) resulting in a
hydraulic loading rate of 1.3 gpm/ft2 at the design flow rate of 130 gpm. A distribution
header with four full cone spray nozzles were utilized to distribute the flow over the media.
The media within the unit was designed to have a minimum wetting rate of 0.20 gpm/ft2 to
allow flexibility if either the unit experienced a reduced flow rate or a much larger flow
during intermediate tide cycles.
A natural draft unit was not initially designed for this unit due to odors from the
hydrogen sulfide. Therefore, ah induced draft unit was designed and constructed to dispense
the vapors emanating from the unit. However, the unit was designed to be easily modified
for natural draft operation with the removal of the blower and cover. During the initial
operation with the induced draft blower an operating air flow rate of 750 to 1000 cubic feet
per minute (cfm) was utilized. Currently, the unit is operating by natural draft since the
odors have been significantly reduced.
9

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The facility's existing wastewater treatment plant utilized a nutrient feed of ammonia-
nitrogen and ortho-phosphate which was also utilized in the ground-water remediation
system. A flow rate of approximately 0.20 gallons per hour (gph) has been utilized to
establish a healthy population on the media.
The in-situ bioremediation unit was designed to reduce the contaminant
concentrations in the aquifer to significantly lower concentrations (50 ug/l[parts per billion]
selected organic constituents). An underlying design criteria of the recovery system was that
it prevent saltwater intrusion into recovery, injection, and monitor wells. The recovery and
injection well locations were selected to maximize the contaminant removal in a cost
effective manner.
Based on optimum flow rates obtained from groundwater modeling, the aeration unit
was designed for a flow rate of approximately 130 gpm from 13 recovery wells pumping 10
gpm each. This flow rate was not designed to capture the entire plume, but rather to
introduce sufficient nutrient-enriched and oxygenated ground water to enhance in-situ
biological degradation over a majority of the affected area.
The main operational unit of the treatment system was a ground-water
bioenhancement unit. The design was based on trickling filter technology. Packed media
with a large surface area (42 ft2/ft3) for the microorganisms to grow on was placed in a
square container constructed of concrete. The media was 6 ft deep and provided sufficient
10

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surface area for the bacteria to attach and grow and oxygen to transfer into the water as it
moved through the media. Nutrients were added to ground water before the
bioenhancement unit to enhance the microorganisms growth.
The groundwater recovery wells (13), treatment system and injection wells (10), as
depicted on Figure 4, were designed to include valving, sample ports, and instrumentation,
with ease of maintenance taken into consideration. The valving, sample ports, and
instrumentation for the injection wells were designed to provide easy maintenance and to
evaluate clogging. The system is designed to minimize maintenance and includes access to
the plastic media, access to the bottom of the unit and the ability to by-pass the treatment
unit. Supporting instrumentation including pH meters, dissolved oxygen meters,
salinity/TDS conductivity meter and temperature probes were specified.
In-situ Groundwater Bioremediation Performance Evaluation
The analysis of ground-water samples showed a reduction in total VOC content since
commencement of the in-situ ground-water remediation program (Figure 5 and 6). Despite
several system shutdowns and pumping rate corrections, an estimated 9.84 pore volumes
(44.4 million gallons) were moved through the aquifer during this period.
11

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The bioenhancement unit has resulted in the near complete removal of organic
constituents from the ground water. A comparison of VOC removal efficiency between
influent and effluent samples from the bioenhancement unit showed an increase from an
initial removal percentage of 93% to 99% two months later.
Among the recovery wells, individual chemical analyses showed VOC reductions
ranging from 52% (toluene) to 100% (methyl tertbutyl ether, ethylbenzene, and xylene)
when the average VOC concentration in water samples were compared. The initial
dissolved oxygen content in influent samples (0.1 to 0.2 ppm) did not increase measurably
during the first two months of operation; however, the dissolved oxygen content in the
bioenhancement unit effluent samples increased from 2.3 ppm to 4.5 ppm.
Air quality measurements reported no safety or health risks during the initial start
up and operation. Noticeable H2S odors were reported during the first 8 to 12 hours
operation; thereafter, H2S concentrations diminished rapidly and could only be detected with
10 to 20 feet of the bioenhancement unit.
Hydrogen sulfide concentration measurements were also obtained from the discharge
stack of the bioenhancement unit after 8 hours of operation. H2S concentrations ranged
from 120 to 140 ppm and diminished to 30 to 40 ppm the following morning. H2S
measurements obtained at ground level near the bioenhancement unit remained below 10
ppm after 24 hours of operation.
12

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A clogging problem was observed in the injection wells following several weeks of
operation. This condition was corrected by drilling the injection wells deeper to remove
accumulated debris and to extend vertically the discharge of effluent into the karst aquifer.
Following 15 months of operation, there was no apparent mixing of the freshwater
lens with salt water. Salinity measurements and total dissolved solids content were obtained
from all ground-water monitoring wells as part of a routine sampling program. Field notes
and analytical results showed the normal range of values [Conductivity, 767 to 7490
microsiemens/centimeter (mS/cm); TDS, 381 to 3220 mg/L] when compared to background
wells (726 to 5700 mS/cm; TDS 726 to 2860 mg/L). Oxygen concentrations in ground water
monitor wells have increased in the contaminant plume. Before the ground water recovery
and treatment program was initiated oxygen concentrations were near 0 mg/1. Oxygen
concentrations in March 1993 ranged from 1 to 2 mg/1.
13

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References
Voss, C.I., 1984. A finite-element simulation model for saturated-unsaturated, fluid-density-
dependent ground-water flow with energy transport or chemically-reactive single
species solute transport, U.S. Geological Survey, Reston, Virginia.
McDonald, M.G. and A.W. Harbaugh, 1988. A modular three-dimensional finite-difference
ground-watons, Book 6, Chapter Al, U.S. Geological Survey, Reston, Virginia.
Pollock, D.W., 1989. Documentation of computer programs to compute and display
pathlines using results from the U.S. Geological Survey modular three-dimensional
Finite-difference ground-water model, Open File Report 89-381, U.S. Geological
Survey, Reston, Virginia.
g:\user\gregr\synepa.w51
14

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20.9
BDL
Figure 1 - SVE Recovery Well Summary

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Figure 2 - Simulated Water Levels and Capture Zones for 10 Recovery Wells
Pumping 10 gpm each.

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Rw-8
©—
0IOENHANCEMENT
UNIT
Rw-2 RW-1
RW-4
RW-5	Rw— 3
- T T T
bb
Rw-6
-C	O
6 RW
RW-1 J
¦+L| RW- 7
m
« RW-9
WW-10
RW-U
1-3
(\-A 1-5 ! - 5 1-7
0 O 0 O O
1-10—
1-9
_2_
o o
i-8 1-10
1-2
RECOVERY WELLS (13)
INJECTION WELLS (10)
EXPLANATION
O
1-8
O
RW-13

INJECTION WBJ. LOCATIONS
RECOVERY WELL LOCATIONS
MANUFACTURING/SOLVENT
USE AREAS
200 100 0
200
SCALE. / "=200 Ft
Figure 3 - Ground-water Recovery and Treatment System

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Figure 4 - Process Flow Diagram

-------
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400-
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I
h

'A
VAPOR
RECOVERY
SYSTEM
INSTALLED
PC
GROUND-WATER
RECOVERY
SYSTEM
INSTALLED
DEC 5,1991
JUL 89 MAR 90 OCT 90
MAR 91 OCT 91
DATE SAMPLED

1

f

i

i

¦8
i

'JS/.y-
%
MAR 92 SEP 92 MAR 93
LEGEND
VOLATILE ORGANIC CHEMICALS V777A REDUCED SULFUR COMPOUNDS
Figure 5 - Ground-water Monitoring Well Results

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3000
2700
2400
2100
1800
1500
1200
900
600
300
2945
1480
2
i
148
315
3.6
ffDLBDL
177
,36.4
1544
?:V
>#¦
174.6
54	7.3
^BDLBDL rmBDLBDL
ETHYL
ETHER
MTBE BENZENE TOLUENE
ETHYL
BENZENE
XYLENE
EXPLANATION
P71
SAMPLES TAKEN DEC. 5, 1991
w
(BEFORE STARTUP)
El
SAMPLES TAKEN FEB 5. 1992

SAMPLES TAKEN SEPT. 10. 1992
BDL
BELOW DETECTION LMTS
Figure 6 - Average VOCs in all Recovery Wells

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Cardinal.

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GROUNDWATER REMEDIATION
(A CASE STUDY)
GNB BATTERY TECHNOLOGIES
Columbus, Georgia
Prepared by
Lake Engineering, Inc.
Atlanta, Georgia
To be presented at the
GROUNDWATER REMEDIATION/STABILIZATION CONFERENCE
United States Environmental Protection Agency
Region IV

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ABSTRACT
This case study addresses a lead/acid battery recycling and manufacturing facility operated by
GNB Battery Technologies. The facility is located in Columbus, Georgia. Past practices
conducted at the facility have impacted the groundwater. The study involves two primary
constituents of concern, lead and trichloroethylene. The constituents are migrating in two
overlapping plumes from two separate sources. The facility has implemented interim corrective
action and is currently performing investigation activities to define the extent of the plumes.
The investigation has been conducted in phases which have included the installation of 36
monitor wells. The corrective action includes the installation of a recovery well, pumping and
treatment of the groundwater. Both the corrective action and investigation activities are being

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DESCRIPTION OF THE FACILITY
LOCATION OF THE FACILITY
The setting for this case study is a battery manufacturing and recycling facility operated
by GNB Battery Technologies in the city of Columbus, Georgia. The recycling center includes
processes for battery breaking, smelting and the refining of lead and lead alloys. The
manufacturing plant produces various types of automotive and industrial lead-acid batteries.
The recycling center currendy operates as a permitted Hazardous Waste Facility, regulated
under RCRA.
NATURE OF THE PROBLEM
The groundwater monitoring activity at the site has identified lead and trichloroethylene
(TCE) in groundwater at the facility. The lead was identified in 1987 during the preparation
of the Part B permit application for the recycling center. Groundwater detection monitoring
identified elevated levels of lead and other heavy metals generally associated with the battery
recycling process (i.e. arsenic and cadmium). The permit for the facility, subsequendy issued
in March 1988, included provisions for implementing both further investigation and corrective
action measures. The first phase of the RCRA Facility Investigation (RFI) was completed in
July 1989. Based upon the early detection monitoring and investigation results, the primary
contaminant was identified to be lead. The other heavy metals have subsequently proved to
be a minor concern.
The TCE was first detected during the periodic Appendix IX sampling stipulated in the
facility permit. The first phase of the RFI, being conducted at the time of the initial TCE
detection, was modified to include additional investigation activities for the TCE. A second
phase of the RFI was conducted in 1990 to further define the presence of TCE in the
groundwater at the facility and to attempt to identify the source of the TCE. A third phase
of investigation, including several off-site monitor wells, was recently completed. The data

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DESCRIPTION OF THE HAZARDOUS WASTE UNITS
PERMITTED UNITS
The facility is permitted to operate two solid waste management units consisting of a
battery storage area and a raw material storage area. The battery storage area is defined for
use as a temporary holding area for spent batteries awaiting breaking and processing. The raw
material storage area, designated as a waste pile, is used for the collection of the lead bearing
components removed from the batteries during the breaking process. The raw materials are
removed from the area and later used as feed for the facility's two blast furnaces. Both of the
permitted areas are located within an enclosed metal building.
PREVIOUS OPERATIONS AND OTHER SOURCES
Periodic compliance monitoring has indicated that the currently permitted units are not
the source of the groundwater contamination. The sources of both the lead and TCE plume
appear to be past practices conducted at the facility prior to RCRA regulation.
The major source of the lead contamination was identified during the RFI as an area
of the plant previously used for the storage of raw materials prior to smelting.
The TCE, first detected during the initial RFI, was the subject of additional
investigation. Although the exact location of the TCE source was not pinpointed during the
second phase of investigation, the source is suspected to be past practice of using
trichloroethylene during the battery manufacturing process.
DESCRIPTION OF THE HYDROGEOLOGY
GENERAL GEOLOGIC SETTING
The facility is located near the fall line of Georgia, which separates the Piedmont
crystalline bedrock of north Georgia from the Coastal Plain province to the south. The site
is located in a transition zone along the fall line, but, the conditions at the site are more typical
of the Coastal Plain. Undifferentiated surficial alluvial deposits are common to the area. The

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kaolinitic clay. Locally, the upper soil regions consist of predominately sand and sandy silt
with clay occurring in numerous lenses and layers.
DESCRIPTION OF THE CURRENT MONITORING SYSTEM
Preliminary groundwater investigation began at the site in 1987. A total of 36 monitor
wells and piezometers have been installed at the site to date. Figure 1 shows the locations of
the monitoring devices relative to the site. Some of the monitor wells have been installed in
pairs with screened intervals at different depths (designated as shallow and deep in Figure 1).
Table 1 presents a summary of the monitor well construction data. It was concluded that
although some groundwater is perched on top of clay lenses, the uppermost aquifer actually
exists at a depth of approximately 35 feet. The current groundwater monitoring program was
initiated in March, 1988 as a requirement of the Hazardous Waste Facility Permit. At present,
21 monitor wells and 5 piezometers, all screened within the uppermost aquifer, are maintained
and periodically sampled.
DESCRIPTION OF THE AQUIFER SYSTEM
The TCE and lead in" the groundwater has been limited to the uppermost surficial
aquifer. The aquifer consists of a medium to coarse grained sand which occurs at a depth of
approximately 35 feet. The sand unit has an average thickness in the range of 25-40 feet
across the site. A low permeability silty clay forms a consistent aquitard below the sand.
Figure 2 shows the cross section developed from the information obtained during the
installation of the monitor wells. Figure 3 indicates the direction along which the cross section
is taken. Based upon test boring results, the silty clay layer extends to a depth of at least 100
feet. No evidence has be found to indicate that the TCE and lead in the groundwater has
migrated past the confining layer.
ESTIMATED FLOW PLATES AND PARAMETERS
Water level measurements have been recorded quarterly since June 1988. Continuous
pumping at the recovery well has been in progress throughout most of the monitoring period.
Figure 4 and Figure 4A show a set of typical water level contours developed from the
quarterly measurements. The influence of the pumping well is obvious. However, the pumping

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undisturbed natural water levels. The water level contours developed from the first of these
events are shown in Figure 5. Both sets of contours indicate a general direction of flow
toward the northwest. Information from several new off-site monitor wells is currently being
collected to more accurately define the downgradient flow pattern outside the boundary of the
facility.
The flow rate has been calculated to be approximately 0.4 to 0.5 feet per day. Based
upon information obtained from slug tests and limited pumping tests, hydraulic conductivity
values in the range of 175 to 350 feet per day were derived. Information collected during the
recent third phase of the RFI is currently being compiled and evaluated in order to verify or
better define these values.
EXTENT OF THE GROUNDWATER IMPACTS
INITIAL CONCENTRATION LEVELS
Initial lead concentrations in the range of 1.07 to 1.35 mg/1 were detected in 1987 in
several of the monitor wells around and downgradient of the old raw material storage area.
The highest cadmium concentration initially detected was 0.02 mg/1 in monitor well MW-6D,
nearest to the old raw material storage area. It should be noted that this was the only well
out of the seven sampled that had a cadmium concentration above a detection limit of 0.005
mg/1. Similarly, arsenic has only been detected in excess of the established standard one time.
In January 1988 arsenic was detected at a value of 0.056 mg/1 in compliance well C-4 located
immediately downgradient of the old raw material storage area.
TCE was first detected in 1988 in a range of 0.008 to 6.1 mg/1, with highest
concentration occurring in MW-9D. Later investigations included consistent concentrations in
the range of 1.0 to 6.0 mg/1 in monitor well MW-14 which is closest to the probable source
of the TCE.
DEFINITION OF THE LEAD AND TCE IMPACTS
The lead and TCE plumes at the facility each has its own separate source. However,
due to the apparent source locations and the influence of the pumping well, the plumes

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Due to the direction of flow being essential parallel to the western most boundary of
the facility, only approximately one half of the lead plume has currently been defined.
Compilation and evaluation of data generated during the third phase of the RFI is currently
being conducted.
The TCE plume has been reasonably defined within the boundaries of the facility.
Sufficient data has not been collected to determine the full extent of the plume. The recent
third phase of the RFI was the first step in collecting the data necessary to further define the
plume.
THE GROUNDWATER REMEDIATION SYSTEM
IMPLEMENTATION AND COMPLETION OF THE RFI
Initial corrective action measures were implemented as part of the permit requirements
concurrent with the preliminary investigation of the TCE. Consequently, the system was
primarily designed to address the lead plume. An interceptor well was installed adjacent to
the battery processing area to extract impacted groundwater. The location of the recovery well
was selected to be immediately downgradient from the old raw material storage area. Water
is currently pumped from the interceptor well at a rate of 32 gpm on a continuous 24 hour a
day basis. The extracted groundwater is pumped to an on-site storage tank. Until recently,
stored water was recycled as process water, which was collected and processed through the
existing plant wastewater treatment system. Plans are currently being evaluated for installing
a new treatment system (ie. an air stripper or carbon adsorption unit) to remove the TCE.
Excess extracted groundwater is discharged directly from the storage tank overflow to the
plant's sewer line which discharges to the city sewer system. All excess groundwater
discharged to the city sewer system has a lead concentration less than the limit allowed under
the current POTW discharge permit for the facility.

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SOURCE IDENTIFICATION CONTROL
In addition to the recovery of groundwater by pumping, GNB has implemented several
other measures designed to control the various sources of TCE and lead at the facility and
reduce migration of such to the groundwater. In particular, all raw material is now handled
within an enclosed building with a concrete floor to reduce the chance of runoff and
infiltration. The area previously used for raw material storage has been re-graded in a manner
to direct surface runoff to the existing stormwater retention tanks. The area has also been
paved with asphalt to reduce the infiltration. Other improvements include the installation of
a stormwater pipeline to replace an open ditch which was transporting contaminants from
surface runoff, the installation of berms and other runoff control to eliminate standing water
and off-site runoff, and modifications in plant operations to eliminate miscellaneous releases.
OPERATIONAL PROBLEMS ENCOUNTERED
STORAGE AND DISPOSAL OF THE RECOVERED GROUNDWATER
The transport, storage and location of treatment systems for recovered groundwater has
proved to be an obstacle. The operation of the facility requires the extensive use of trucks and
transfer equipment for moving materials. Available space is very limited in the areas where
the recover wells need to be located. Likewise, there is very little room for the installation
of storage tanks and transport piping. Any above ground piping is subject to damage by
vehicular traffic.
Another major problem encountered is the disposal of treated groundwater. The plant
is currently operating on a temporary sewer permit which limits discharge volumes. There is
no access for a NPDES permit. An infiltration system to recharge the recovered groundwater
is being considered, but again available space limits the placement of the system.
EFFECTS OF THE CORRECTIVE ACTION
The effects of the corrective action is best demonstrated by TCE and lead concentration
graphs developed for the individual monitor wells. Several of the graphs for each plume have

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Lead Plume
The Graph 1 shows the monitor well adjacent to the recovery well. A drop in the
initial concentration can be observed in 1989 when the pumping rate was and operated
pumping was begun on a continuous basis. The Graph 2 shows the effect on one of the
downgradient monitor wells. Again a significant decline in the initial concentrations can be
observed after the pumping operation was started.
TCE Plume
Although the recovery well was not specifically located to intercept the TCE plume, the
observed effect on the TCE concentrations is more dramatic than those observed for the lead.
The Graph 3 shows a sharp reduction of the TCE concentrations in compliance well C-2
which is downgradient from the recovery well. In contrast, the Graph 4 shows a sharp
increase in the TCE concentration at compliance well C-4 which is located adjacent to the
recovery well. This indicates that the TCE is being drawn into the recovery well. The last
graph, Graph 5, shows a significant decrease in the concentrations in monitor well MW-D11
located downgradient from the recovery well.
The current investigation activities will address this problem and propose alternatives

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NQTES;
1	ELEVATIONS SHOWN	AT THE WELL LOCATIONS INDICATE THE TERMINATION ELEVATION OF THE BORING
2	REFER TO MONITOR	WELL CONSTRUCTION DATA TABLE FOR SCREEN ELEVATION.
3	THE WATER LEVELS SHOWN REPRESENT THE MEASUREMENTS MADE ON JANUARY 13, 1993 AND WAY VARY SLIGHTLY WITH TIME

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007700
(107500
007300
007100
<
006500
006300
006100
005000
- Water Level Contours - January 13, 1993
SCALE 1 inch = 300 Feet
~
J	I	I	L	L
J	I	I	L
J	L
J	L
262700 263000 263300 263600 263000
X Coordinate
264 200 264 500 264 000

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mm oo
007100
oooooo
000500
nuozoo
001)900
Contour Interval = U.^ Fecit
j	i	i	i	i i	i	L
-L	L
2G2700 203000
20H300 203600 203900 2G4200
Fast Coordinate
2600 2G4000

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TABLE 1
MONITOR WELL CONSTRUCTION DATA
GNB Battery Technologies - Columbus, Georgia
I11
hi
Data
(East)
(North)
Date
Date
Surface
Boring
Bottom
Distance to
Measurement
Length
Bottom of
Screen
Top of
Point
X
Y
Ins tailed
Closed
Elevation
Length
of Boring
Measurement
Point
of Casing
Screen
Length
Screen
ID
Coor.
Coor.



(ft)
(msl)
Point (ft)
Elevation (msl)
(ft)
(msl)
(ft)
(msl)

263,742
886,374
06/29/87

267 63
59 3
208 33
1 93
269 56
59 6
21059
10
220 59
C-i
263,494
886,738
06/24/87

268 76
640
204 76
209
270 85
63 8
207 65
10
217 65
:-j
263,448
886,729
06/27/87

268.21
640
204 21
1 92
270 13
63 3
207 51
10
217 51
- i
i
263,447
886,650
06/28/87

268 99
640
204 99
1 95
270 94
65 0
206 55
10
216 55
1 * '
263,399
886,815
04/18/86
11/04/87
268 50
50 0
218 50
2 96
271 46
22 0
250 09
15
265 09

263,515
886,502
04/08/86
11/04/87
267 80
45 0
222 80
2.96
270 76
45 0
226 39
15
241 39

263,555
886,508
04/09/86
11/04/87
268 00
50 0
21800
1 61
269 61
47 5
222 74
10
232 74
| . ,W-4
263,615
886,490
04/09/86
11/04/87
267 90
50 0
217 90
2 97
270 87
50 0
221 50
10
231 50
MW-5S
263,178
887,147
01/21/87
01/15/91
264 99
18 5
246 49
4 40
269 39
22 8
247 20
5
252 20
,.i»V-6S
263,549
886,478
01/23/87

267 67
190
248.67
2 45
270 12
21 0
249 80
5
254 80
: nv-7S
264,018
886,003
01/15/87
01/15/91
272 04
22 5
249 54
2 20
274 24
25 o


MW-8S
264,194
886,880
01/23/87
01/15/91
273 88
190
254 88
2 20
276 08
20 0
£H J O /
256 71
5
5
254 87
261 71
;,;'.y-9S
263,654
886,723
01/23/87

268 13
24 0
244 13
2 35
270 48
26 5
244 63
5
249 63
MW-IOS
264,634
886,373
10/07/88
01/15/91
276 19
26 0
250 19
1 69
277 88
27 5
251 01
10
261 01
MW-1IS
263,375
886,884
10/17/88

268 78
160
252 78
1 61
270 39
170
254 00
5
259 00
MW-12S
262,949
887,415
10/11/88

263 67
79 0
238 08
1 91
265 58
26 0
240.21
10
250 21
MW-5D
263,171
887,154
01/20/87

264 88
53 5
211 38
4 45
269 33
59 7
210 27
10
220 27
MW-4D
263,542
886,490
01/29/87

267 59
63 5
204 09
2 45
270 04
66 8
203 92
10
213 92
MW-7D
264,009
886,005
01/15/87

272 12
55 5
216,>2
2 30
274 42
57 7
21735
10
227 35
MW-8D
264,188
886,880
01/16/87

273 95
58 9
215 05
2 05
276 00
60 9
215 78
10
225 78
r l,V-9D
263,662
886,723
01/18/87

268 13
58 8
209 33
2 30
270 43
60 9
210 13
10
220 13
¦VW-10D
264,634
886,364
10/16/88

276 67
74 5
202 17
1 87
278 54
72 1
207 08
10
217 08
nr" iid
263,377
886,892
10/17/88

268 67
64 0
204 67
1 78
270.45
62 4
208 68
10
218 68
MW-12D
262,941
887,424
10/10/88

263 61
640
199 61
1 92
265 53
61 6
204 56
10
214 56
J ' 13D
263,682
886,558
01/11/91

266 88
60 0
206.88
1 91
268 79
61 7
207 70
10
217 70
"f"'-l4D
263,781
886,610
01/12/91

267 95
60 0
207 95
2 04
269 99
61 9
208 77
10
218 77
1


08/10/93


65 0





10

OS-2


08/11/93


55 0





10

P-i
263,705
886,757
10/13/88

268 04
64 0
204 04
1 71
269 75
66 0
204 38
10
214 38
¦>
263,784
886,440
10/18/88
01/15/91
267 79
59 0
208 79
1 76
269 55
35 0
235 18
10
245 18
f-J
263,680
886,313
10/13/88
01/15/91
269 16
59 0
210 16
1 79
270 95
22 5
249 08
10
259 08
P-4
263,530
886,880
10/13/88

268 60
64 0
204 60
1 69
270 29
64 4
206 57
10
216 57
P-5
263,475
887,150
10/12/88

265 44
64 0
201 44
1 48
266 92
62 0
205 54
10
215 54
P-6
263,245
887,035
10/12/88

268 86
64 0
204 86
1 89
270 75
66 2
205 22
10
215 22
P-7


08/09/93


60 0





10
D-l
263.448
886,721
01/17/91
09/23/92
268 20
104 0


270 30
102 5
168 43
10

PW-1
263,450
886,663
11/04/87

268 90
65 0
203 90
2 10
271 00
65 0
206 63
10

-------

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©D
B
S
©
•+-»
ca
u
fi
U
s
o

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Lead Concentrations at Well MW-5D
GNB Battery Technologies - Columbus, Georgia
10
0.1
0.01
0.001
1987
MCL
1990 1991 1992
Date of Sampling
1995
Graph revised September 10, 1993

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6D
a
©
cs
u
G
CJ
CJ
G
O
U
TCE Concentrations at Well C-2
GNB Battery Technologies - Columbus, Georgia
10
0.1
0.01
UL
LL
Upper Limit = 0.559
Median = 0.317
Lower Limit = 0.076
displays evic
ient of variati
ence of non-
on = 1.38
normality,

MCL
1987 1988 1989
1990 1991 1992 1993 1994 1995
Date of Sampling
Graph revised September 10, 1993
Graph 3

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TCE Concentrations at Well C-4
GNB Battery Technologies - Columbus, Georgia
MCL
1987 1988
1989 1990 1991 1992 1993
Date of Sampling
1994 1995
Graph revised September 10, 1993

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TCE Concentrations at Well MW-11D
GNB Battery Technologies - Columbus, Georgia
10
0.001
MCL
1987 1988 1989
1990 1991 1992
Date of Sampling
1993 1994 1995
Graph revised September 13, 1993

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p
Cardinal.

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EFFECTIVENESS OF GROUNDWATER REMEDIATION
IN KARST TOPOGRAPHY IN NORTHERN ALABAMA
By
H.S. GIB, PtvD.
Dames & Moore
Tampa, Florida
ABSTRACT
In December 1986, GTE Communications Systems Corporation (predecessor in interest to
GTE Products of Connecticut Corporation) received post-closure permits from the U.S.
Environmental Protection Agency (EPA) and the Alabama Department of Environmental
Management (AOEM). These post-closure permits required GTE to undertake certain
corrective actions following closure of the metal hydroxide sludge surface impoundment at
its former Huntsvilie, Alabama facility (February 1967). These actions included the
installation of recovery wells (RW-1 and RW-2), additional on-site monitoring wells, and an
off-site irivestigatkxVremediation program. In 1992, additional recovery wells (RW-3, RW-5,
and RW-6) were designed, installed, tested and placed into operation. The on-site and off-
site recovery well installations and subsequent pump tests were conducted to assess
recovery well and respective aquifer characteristics. Several analytical methods were used
to evaluate aquifer characteristics, which allowed comparison of results to provide the best
estimate of an aquifer's nature. Both short-term and long-term aquifer responses were
analyzed. The short-term response was useful in evaluating aquifer transmissivity and
storage coefficients. The methods used for the analyses induded Theis's (1935) non-
equilibrium curve matching method for non-steady state, confined aquifers; Cooper and
Jacob (1946) modified non-equilibrium method; and Jacob's (1955) non-steady state, leaky
aquifer method. The assessments has enabled an evaluation to be made of the on-site/off-
site long-term effectiveness of corrective actions.

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EFFECTIVENESS OF GROUNDWATER REMEDIATION
IN KARST TOPOGRAPHY IN NORTHERN ALABAMA
By
H.S. QiB, PtvD.
Dames & Moore
Tampa, Florida
SUMMARY
1.0 INTRODUCTION
In December 1986, GTE Communications Systems Corporation (predecessor in interest to
GTE Products of Connecticut Corporation) received post-closure permits from the U.S.
Environmental Protection Agency (EPA) and the Alabama Department of Environmental
Management (ADEM). These post-closure permits required GTE to undertake certain
corrective actions following closure of the metal hydroxide sludge surface impoundment at
its former Huntsville, Alabama facility, which was completed in February 1987. These
actions included the installation of recovery wells and additional on-site monitoring wells,
the design and installation of an on-site treatment system, and an off-site
investigation/remediation program. Dames & Moore was retained to assist GTE in
performing these tasks.
2.0 REGIONAL AND SITE HYDROGEOLOGtC SETTING
The GTE Huntsville surface impoundment is located on the fringe of the Tennessee River
floodplain and the Highland Rim Physiographic Province. Bedrock in the area consists of
nearly ftefiying, sedimentary rocks. With respect to the hydrogeologic conditions, the basal
geologic formation is the low permeability Chattanooga Shale. This shale Is overlain by the
Fort Payne Chert and the Tuscumbia Limestone, which together range in thickness from
about 150 to 200 feet at the site. The Tuscumbia Limestone serves as the primary
groundwater supply in the area and is considered to be the uppermost aquifer with respect
to groundwater monitoring:
Aerial photograph interpretation, limited geophysical surveys (EM 31) and installation of the
wells have confirmed extensive fracture systems in the limestone with secondary solution

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The limestone is overlain by silty clayey soils which range from 8 to 16 feet in thickness in
the soil borings and monitoring wells drilled at the site. These soils are fine grained with
approximately 80% or more passing the No. 200 sieve. They have an average plasticity
index of about 25 and are composed of about 70% kaolinite and montmorillinite clays.
Shallow monitoring wells were installed to depths ranging from about 8 to 11 feet and
screened in the surficial soils to determine the phreatic surface. Intermediate depth
monitoring wells were installed in the underlying limestone to depths ranging from 32 to 50
feet deep monitor wells have been installed to depths between 70 and 90 feet. The data
from the limestone monitoring wells indicate that a slight groundwater mound exists in the
vicinity of the surface impoundment. In addition, the limestone wells confirm that the
regional gradient is generally towards the nearby Tennessee River.
3.0 EFFECTIVENESS OF REMEDIATION
The on-site monitor well recovery well and remediation system design and installation was
completed in 1987.
The site location and a schematic illustration of the closed surface impoundment and on-
site\off-site monitor well and recovery well locations are shown in Figures 1 and 2,
respectively. Additionally, a tabulated summary of on-site monitor wells, off-site monitor
wells, and their respective installation dates is presented in Table 1. In accordance with
GTE's post-closure permit, monthly and/or quarterly data for volatile organic compounds
(VOCs) and metals have been collected for monitor wells 2, 6, 9, 10, 11, and 12 since
March, 1986, and quarterly data have been collected for wells 20, 21, 22, and 23, since
May, 1987.,
Significant reductions in on-site VOC concentrations have been achieved since GTE
implemented its remediation program in 1987. A relatively large decline in VOC
concentrations occurred in early 1987 aftef th« closure of the surface impoundment was
completed. This initial decrease in VOC concentration in the on-site wells is believed to be
the result of the closure and elimination of the impoundment as a continuing source of
contaminants coupled with the natural flushing of the aquifer. To achieve further decrease
in VOC concentrations and to minimize migration of VOCs off-site, two 6-inch stainless
steel recovery wells were installed on-site in May, 1987. Subsequent to the installation of
the recovery wells, an air stripping system was installed at the site in October, 1987, for the
removal of VOCs from the groundwater. The air stripping unit was used to treat the
recovered groundwater until June 16, 1988. Since that time, the recovered groundwater
has been discharged directly to the City of Huntsville sewer system with the City's and

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In December of 1991, two additional off-site recovery wells were installed, based on the
observed localized conditions and subsurface Karst complexities (fractured and solutioned
limestone). The discharges from the off-site recovery wells were piped to the existing on-
site air striping building, and discharged in the City's sanitary sewer system (with the City's
approval). Required modifications to the pumphouse were be made to accommodate
additional extracted water volumes.
Additional corrective actions at the facility were implemented in October, 1992. Recover
well RW-3 was installed to enhance the on-site recovery system, and recovery wells RW-5
and RW-6 were installed to initiate an off-site recovery system in the vicinity of well cluster
15. The installation of the proposed on-site recovery well RW-4 was postponed until further
evaluation for an optimum location was conducted.
The results of the pump test analyses showed that expansion of the on-site recovery
system would be successful in extracting increased volumes of groundwater and enlarging
the on-site radius of influence. Additionally, the newly installed off-site recovery system
was located in the zone of high transmissivity. As a result, it is expected that the off-site
recovery system will notably enhance recovery of VOC contaminants, particularly in the
vicinity of well cluster 15.

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TABLE 1
MONITOR WELL INSTALLATION SUMMARY
GTE • HUNTSVILLE CLOSED SURFACE IMPOUNDMENT
ON-SITE MONITOR WELLS*
| WELL NUMBER
DATE INSTALLED
1 2
WAA
6
^27/84
9
7/17/84
1 10
7/1^34
11

12
V*86
20

21
W87
22
V-VS7
23

RW1
yi2^7
RW2
W7
RW3
13/1092
| OFF-SITE MONITOR WELLS' I
15A
5^86
15B
W86
15C
W6
24
^90
25
WO
26
^1^90
28
3/13/30
29
iy2V90
30
1/1V91
31A
yiv9i
31B
iyi^9o
RW5
i
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TABLE 2
SUMMARY OP LABORATORY RESULTS
DECEMBER 1992 SAMPLING
Parameter Well Number
Detection
Field Samples'/Ground water concentrations, jig/1

Limit,
w/i
2
6
9
10
11
12
DUP
12
20
21
22
23
RW1
RW2
RW3
1,1 • DichJoroethane#
6.0
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
FDL
1 1-Dichloroethene#
6.0
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
Toluene#
6.0
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
Trichloroethene#
6.0
BDL
BDL
BDL
BDL
18
61
40
BDL
BDL
BDL
BDL
BDL
BDL
BDL
cis-1,2-dichloroethene
6.0
BDL
17
BDL
7
BDL
14
12
BDL
BDL
BDL
BDL
BDL
6
14
trans-1,2-dichloroethene#
6.0
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
Vinyl Chloride
10.0
BDL
BLD
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
TetracKloroethena
6.0
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BQL = Below Quantitation Limit.
#VOC constituents included in posVclooure permit.

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TABLE 2 CONTINUED...
SUMMARY OP LABORATORY RESULTS
DECEMBER 1992 SAMPLING
Parameter Well Number
Detection
Limits
Mfi/1
Field Sample#'/Groundwater concentrations, (ig/1 I
15A
DUP
15B
15B
15C
24
26
26
28
29
30
31A
31B
RW5
RW6
1,1 - Dichloroethane#
6.0
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL j
1,1 - Dichloroethene#
5.0
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL |
Toluene#
6.0
BDL
BDL
BDL
BDL
BPL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL (
Trichloroethone#
5.0
670
730
60
490
BDL
BDL
BDL
BDL
BDL
BDL
20
17
380
340 |
cia-1,2-dichlorcathene
5.0
680
630
110
370
BDL
BDL
12
BDL
BDL
10
14
12
330
260
trans- 1,2-dichloroethene#
6.0
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
'inyl Chloride
10.0
34.6
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL I
Tr *rachloroethene
6.0
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL |
¦»\UMoaV«Uka rW7Tb<
BQL = Below Quantitation Limit
AVOC constituents included in poet-cloeure permit

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Base Map: Street Map of Hunttvill*. Alabama, by Universal
Map, Incorporated, 1989.
Ub-*p—___JLnMn,M===j
Scale
N
Figure 1
VICINITY MAP
CTE Clq
-------
FISH POND WELL
MONITOR WELL
EXISTING RECOVERY WELL
	ONSlTE PROPERTY L«t
0	900 FEET

-------
HARCH GILL, Ph. D
General Manager
Southern Region
Brief Background Information
Dr. Gill graduated with a Ph.D. in Civil and Environmental Engineering from Cornell
University in 1971. He joined Dames & Moore in 1971, and became a Partner in 1976. He
has over 20 years of experience specializing in the management of solid and hazardous
waste. His experience includes numerous projects in the United States, Canada, Europe
and the Far East.
Dr. Gill has been the Project Director, Principal Investigator or Technical Advisor on over
20 Superfund projects. In 1987, he directed a support services contract for the Office of
Groundwater Protection, U.S. Environmental Protection Agency (EPA). The tasks included
the development of guidelines for Wellhead Protection Areas, mitigation measures for
pesticide leaching, and Critical Aquifer Protection Areas.
Dr. Gill has published over 30 technical papers in groundwater contamination and
remediation. He has provided expert testimony at several adjudicatory proceedings, public

-------

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ABSTRACT
Over the course of operations, IBM has used various industrial
solvents in manufacturing processes at its Research Triangle Park,
North Carolina facility. During the 1970's, leakage from a solvent
storage area resulted in the presence of low concentrations of
1,1,1-trichloroethane and similar constituents in the groundwater
underneath the site. Several highly transmissive diabase dikes
have intercepted the IBM site and fractured the adjoining rock.
These controlling hydrogeological units initially led to the
sitewide dispersion of the chemical plume along these dikes.
Utilizing the directional groundwater drawdown effects of the dikes
in an "pump and treat" remediation system, IBM has been able to
reverse groundwater flow within the dikes back to the source area.
Control of groundwater movement extends beyond all boundaries of
the chemical plume. IBM's corrective action system has also
effectively reduced the chemical plume size and chemical

-------
Groundwater Remediation Case Study
International Business Machines Corporation
Research Triangle Park, North Carolina

-------
IBM's facilities in the Research Triangle Park area constitute
one of the company's largest U.S. development and manufacturing
sites. Operations in the area consist of more than 6.5 million
square feet of laboratory, manufacturing, and office space, and
employ approximately 10,000 full-time IBMers. The main IBM campus
is located on over 500 acres in Research Triangle Park, North
Carolina.
IBM is fully committed to the protection of groundwater as a
natural resource. In the 1980's, IBM's Research Triangle Park
facility discontinued using below ground chemical storage tanks and
minimized its chemical use. All chemicals at the site now are
located above ground and provided with secondary containment to
prevent groundwater contamination.
Over the course of operations, however, IBM has used various
industrial solvents in its site manufacturing processes. From 1976
to 1978, some of these solvents were stored in buried tanks outside
the site's Chemical Distribution Center (CDC). In March, 1978, a
5000 gallon waste 1,1,1-trichloroethane tank and a 500 gallon mixed
solvent waste tank were discovered to be leaking and were removed
from service. Unfortunately, releases from these underground tanks
resulted in some groundwater contamination underneath the site.
Low concentrations of several chemicals including 1,1,1-trichloro-^
ethane (TCA), 1,1-dichloroethane (DCA) and 1,1-dichloroethene (DCE)
have been found.
In 1978 an investigation of the affected groundwater was
initiated. Monitoring wells were drilled to determine the nature
and extent of the constituents in the groundwater. Initially the
investigation showed that the chemicals, primarily TCA, had
remained in the source areas with limited migration away from the
source in the direction of groundwater flow. However, further
investigations performed in 1981 revealed a more widespread
dispersion of chemicals along these units. Figure 1 shows the
extent of the chemical plume in 1981, prior to the implementation
of sitewide groundwater remediation.
Given the typical geology for the area, we expected a very
slow migration of the dissolved chemical plume away from the source
area. The IBM-RTP site is primarily comprised of soil and rock of
very low permeability- In general, the rocks mapped during the

-------
Triassic sedimentary rocks- The IBM facility is characterized
chiefly by siltstones with some sandstones, shales, sands, silts,
and clays grading into each other both vertically and horizontally.
The rocks vary so greatly in composition and thickness that it is
virtually impossible to trace them linearly for any distance, even
from borehole to borehole. These variations make the country rock
almost impermeable in some areas.
The greater dispersion of the chemical plume 'is due to the
site's unique geology. The controlling hydrogeological features for
groundwater movement at the site are several highly transmissive
diabase dikes which have intercepted the site and fractured the
adjoining country rock. Four major dikes have been discovered
during the subsurface investigations; two dikes trend east-west and
two dikes trend north-south as shown in Figure 2. The longer of
the north-south dikes has an offshoot with a short dike mapped
parallel to it. One dike is located approximately 75 feet from the
release and acted as a conduit for the migration of the released
constituents.
Many field studies have been conducted to determine the
characteristic of the diabase dikes, their communication with each
other and the country rock, and their role in a remediation
program. These studies have revealed the atypical directional^
versus radial effect of groundwater drawdown along the dikes. For
example, a 24 hour pump test conducted in a well located in the
north-south trending dike showed response from wells as far away
as 1000 feet along the dike while wells in the country rock as
little as 30 feet away from the dike and only 150 feet from
extraction well were not influenced. Long term pumping of the dike
has shown drawdown in wells as far as 2500 feet along the dike
structures.
In 1979 IBM began corrective action. The buried tanks and
adjoining soil down to below the water table were excavated.
Approximately 435 tons of soil containing much of the released
chemicals were removed. Two groundwater sumps (L-5 and R-2) and
one four foot diameter shallow well (304-48) were installed in the
vicinity of the excavated tanks and placed into operation as
groundwater recovery wells. These provided for chemical recovery
and control of chemical migration in their immediate vicinity but
were ineffective in controlling and inhibiting the growth of the

-------
In 1981, IBM expanded the groundwater remediation system to
meet the following objectives: 1) to control and inhibit the
growth of the dissolved chemical plume; 2) to limit the areal
extent of the highest concentrations of the plume to as small an
area as possible; 3) to maximize the cost effectiveness; and 4) to
diminish as effectively as possible the concentrations in all
monitoring wells. The expansion involved the completion of
production well PR-2 in the diabase dike close to the area where
chemicals were released to the country rock near the CDC. Well
PR-2 was placed into operation the third week of September 1981
and has continued pumping groundwater with only short-term
interruptions. It has maintained an average pumping rate of 16.35
gallons per minute over the last four years, while the average
annual rate has recently varied from 17.5 gpm in 1990 to 14.65 gpm
in 1991. The extracted groundwater is treated by an air-stripping
tower and discharged to a sanitary sewer (POTW permit number 3008).
In addition to PR-2, shallow well 304-48 and pits L-5 and R-2 pump
at a combined average rate of 1.5 gpm from the area near- the CDC.
PR-2 has remained in full operation except for a period of
malfunctioning in early 1984 and other brief shutdowns related to
general maintenance. During the first few months of 1984, scale
buildup around PR-2's pump caused the pump rate to drop off
significantly and the water to rise to a level too high to maintain
control of groundwater flow. Consequently, reversal back to
natural groundwater flow and short-term increases in concentrations
occurred. PR-2 quickly regained control of groundwater plume once
its pump was replaced. The water level in PR-2 over time is shown
on Figure 3.
To constantly maintain a depressed water level within the
dike, a time delayed alarm system was been added to alert IBM
security when PR-2 is been down for more than 1 hour. Weekly
inspections are performed to ensure that PR-2 is pumping at the
desired rate and its water level remains low. Well CO-2, also
completed in the dike, serves as a backup production well for use
during maintenance shutdowns and repairs of PR-2.
The groundwater remediation system has proven very effective
in preventing the dispersion of the dissolved chemical plume and
limiting high concentrations to the source area. Figures 4, 13,
and 14 show the areal extent of the dissolved groundwater chemicals

-------
the site display the limit of the chemical plume- All wells
outside the BDL line have chemical concentrations below the
quantification limit of 5 ug/L. A comparison of these maps with
the plan view map for 1981 (Figure 1) shows the declining size of
the chemical plume. These areal maps also show high constituent
levels to be confined to the source area and nearby dike wells.
In 1992, over 99% of the total chemical concentrations measured
across the site were from samples taken from two shallow source
wells.
The extraction system has reduced the total chemical levels
within the entire plume. Chemical declines are illustrated on time
versus concentration graphs. (Figures 5 through 12.) Total
chemical concentrations have dropped in all plume monitoring wells
at the site since IBM began monitoring. Significant decreases in
concentrations have occurred within country rock out from the
source area and along dikes while only limited reductions in
chemistry levels have taken place in the shallow source area. This
may be indicative of a nearby residual source of solvent in this
area.
The improvements in groundwater quality are the result of the
remediation system's reversal of the natural groundwater flow back
towards the dike pumping center and the source area. The equi-
potential contours constructed using intermediate and deep well
data show how the extraction system controls groundwater flow in
these zones. (See Figures 13, and 14.) The equipotential contours
extend away from the source area for long distances at low
gradients along-the diabase dikes, reflecting the extent of PR-2's
influence along the highly transmissive dikes. Groundwater in
country rock adjacent to these dikes is shown then to drain into
the dikes which serve as collectors.
Vertical cross sections further demonstrate the control of
groundwater movement. Three cross sections, A-A', B-B' and C-C',
have been prepared to demonstrate the hydraulic control in 1992.
Their location is shown on Figure 15. Figures 16, 17, and 18
display the cross sectional views.
Cross Section A-A' shows significant dewatering of shallow
rock near the source area. The wells to the north and the south
of the source area have declining head potentials with depth. The
groundwater flow from each direction is back towards well PR-2.

-------
site's major east-west trending dike, which cross the north-south
trending dike to the south of well PR-2. Groundwater flow as shown
along this section is strongly controlled by the pumping of well
PR-2. This control extends to the west as far as well 002-300 and
to the east as far as well L-300.
Cross Section C-C' crosses the north-south dike and passes
through the source area. The cross section shows that groundwater
flow is controlled by the source area pumping as far west as the
DG-5 series wells and as far east as the 627 series wells.
The TCA levels in the groundwater underneath the site have
been reduced further through natural remediation. In the source
area, TCA is degrading to DCE through naturally occurring
hydrolysis. In other areas of the plume, natural hydrolysis and
biological degradation have transformed TCA to DCE and DCA. Since
1988, the level of TCA has steadily declined and the levels of DCE
and DCA have declined or stabilized.
In summary, the groundwater pumping operation has a positive
impact on groundwater flow and dissolved cnemical movement beneath
the site. With this operation, capture extends to the entire
portion of the chemical plume, chemical concentrations in all wells
are diminishing, and the areal extent of the highest concentrations

-------
KEY
— rsvai
19 31 PLUME
4
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-------

-------
360
332
IBM RTP: Groundwater Elevation
Extraction Well PR-2
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Jan 80 Jan 82 Jan 84 Jan 86 Jan 88
Date
Jan 90
Jan 92
Jan

-------

-------
IBM RTP: Groundwater Chemistry
DATE
FIGURE 5
IBM RTP: Groundwater Chemistry

-------
IBM RTP: Groundwater Chemistry
627-100: East of Source Area
1200
en
3 900 ¦
c
o
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v_
£ 600-
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- DCE
DCA
Jon 80	Jan 62	Jon 84	Jon 86	Jan 88
DATE
8i § 81818 ^
Jan 90	Jon 92	Jon 94
FIGURE 7
5500
Jen SO
IBM RTP: Groundwater Chemistry
PR-1: South of Source Area
Jan 82

-------
IBM RTP: Groundwater Chemistry
DAI l

-------
IBM RTP: Groundwater Chemistry
FIGURE 11
IBM RTP: Groundwater Chemistry
DATE

-------
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Kquipotential Contour Map
October 30, 1992
Intermediate Monitoring Wells
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-------
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FIGURE 14
lpoU'ru.i: Contour Map
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-------
A
ptf-: a -
Legend
Deeo Monitoring Well	*
Intermediate Monitoring Weil /
Shcllow Monitoring Well /
/
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Plume Monitoring Area
Cross Section	7
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FIGURE 15




| Reeeorch Triangta Parit, NC
I Site Plume Monitoring and
Crf ss Section Location Map
I DRAW BT. JUl/33 DATE. 2/18/93
SCALE
! Cu£CKrO tr APP'OVcD 3T $AK
DRAWING NO
8701 1-018-.A
\
300'	600"

-------
No) tn
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FIGURE 16
WlUCC*!	hrt. NC
Cross Section A-A'
October 30, 1992
W-»"| BV uui/Si I a.ft. 2/5/93
CHCCKED A APPPOVtO BY £_dX
ORAWTNC ho.
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-------
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	3W.5L—T1	r-
MjaSfJl i 36087
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^ 126 38
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cr
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6?/ Jf)0
627-500
627-70 627-100
627-200
^ JJSJ 56
- 360 -^7 Th
-350
• 340 -
-300		 Groundwoter Demotion Contour (feet amsl)
1AJ73 - Groundwater Devotion (feel omil)
• - Woler Level Not Fully Recovered
»• - Total Volotile Organ* Compounds, uq/l (VOCs)
(four qyorter overoqe)
- Not Analyzed
<5 - Not Detected ot <5 ug/l
Waler Table Devotion (feet amal)
- Diabose
£| - Baked Zone
| - Scroened Interpol
Honzonto! 1* ¦ 100'
verticol 1* - 50'
Verhcal E*oggeration 2X
FIGURE 18
IBM
tti	*•»*, >*C
Cross Section C—C'
October 30, 1992
0ft*wn frr MJi/X3\PArt. 2/10/93
CHtCKto * approvco or- SAX
DRAWNC HO
87011—CS15-A

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PRESENTER: Jennifer Kelvington
Staff Environmental Engineer
Jennifer Kelvington will be presenting the IBM case study. Ms.
Kelvington is the site groundwater engineer at IBM's Research
Triangle Park, North Carolina facility. Ms. Kelvington began her
career with IBM in June, 1984 shortly after receiving a B.S. degree
in Chemical Engineering from North Carolina State University. At
IBM, she has worked in the Environmental Engineering and Chemical
Management Department in groundwater monitoring and remediation,
air emissions control, chemical tracking, hazardous waste
management, industrial and sanitary wastewater monitoring, and
stormwater management. Ms Kelvington's current responsibilities
in groundwater management include implementing the site's
corrective action and plume monitoring plans, analyzing groundwater
data, preparing reports for government agencies, updating permits

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CORRECTIVE ACTION PROGRAM
INTERNATIONAL PAPER
TREATED WOOD PRODUCTS DIVISION
WIGGINS, MISSISSIPPI
Project Manager: Mr. Thad McCoy
International Paper
Presentation by: Mr. Michael SSmms

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Woodward-Clyde
ABSTRACT
CORRECTIVE ACTION PROGRAM
INTERNATIONAL PAPER
WIGGINS, MISSISSIPPI
International Paper operates a wood-treating facility in Wiggins, Mississippi for
treatment of poles and landscaping lumber with pentachlorophenol (PCP or penta) and
chromated copper arsenate (CCA). The plant previously used creosote and PCP as
wood preservatives. The state of Mississippi granted a RCRA post-closure permit on
April 15,1987 for management of three closed recovery impoundments (creosote, penta,
and cellon recovery ponds) and one closed contact-water cooling impoundment. The
post-closure permit requires corrective action for releases of wood-preserving
constituents to groundwater and monitoring of groundwater. Figure 1 shows the plant
layout and the locations of Corrective Action Program wells.
The Wiggins plant is located in the southern part of Mississippi, in Stone County,
approximately 30 miles from the Gulf Coast. The area consists of coastal plain uplands
of the Southern Hills physiographic province. The maximum land surface elevations are
approximately 250 feet above mean sea level (msl) with relief of 50 to 75 feet. The
plant site is underlain by the Citronelle Formation of Pleistocene age which consists of
silty sand and clayey silt from the land surface to approximately 20 feet below land
surface (bis) and fine to medium grained sand with some gravel to approximately 120
feet blsT The Citronelle Formation is underlain by the Pascagoula Formation of
Miocene age which consists of clay to at least 200 feet bis.
The movement of groundwater in the Citronelle Formation in the area is controlled by
topography. At the plant site, the direction of groundwater flow is to the south and
southeast toward stream valleys located to the south and east of the plant.
Between 1986 and 1989, International Paper developed and implemented a Corrective
Action Program for remediation of groundwater in the Citronelle Formation consisting
of groundwater recovery, biological treatment of the recovered groundwater, recharge
of treated groundwater to the Citronelle water-bearing zone or discharge of treated
groundwater to the city of Wiggins POTW, and groundwater monitoring. Figure 2
93B099P-107/099P-107TXT PRP93
1

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Woodward-Clyde
shows the extent of creosote constituents in the Citronelle zone. The extent of PCP is
much more limited.
International Paper installed eight recovery wells to the south (downgradient) of the
closed recovery ponds and one recovery well adjacent to the closed contact cooling
water pond in the Citronelle zone. The biological treatment facility was constructed at
the plant process area. Eight recharge wells were installed to the north (upgradient) of
the closed recovery ponds in the Citronelle zone. Monitoring wells were installed in and
around the perimeter of the plume.
Groundwater recovery was initiated in May 1989. The maximum rate of groundwater
recovery has been approximately 2.4 million gallons per month (approximately 55
gallons per minute). The treated groundwater has been recharged by gravity to the
recharge wells and discharged to the POTW in varying proportions. Figure 3 shows the
monthly rates of groundwater recovery, recharge, and POTW discharge since May 1989.
By the first half of 1991, approximately equal amounts of treated water were recharged
to the Citronelle zone and discharged to the POTW. Figure 4 is the April 1991
potentiometric map for the Citronelle zone showing the water level mound developed
by the recharge wells. In July 1991, International Paper reduced the proportion of the
treated groundwater that was recharged to achieve greater control of groundwater
movement. Subsequently groundwater levels have been lower and greater capture of
the plume has occurred as shown in Figure 5, the potentiometric map for November
1992.
Selected monitoring wells have been sampled quarterly for analysis of the constituents
listed in Table 1 to determine compliance with the Ground Water Protection Standards
(GWPS) specified by the post-closure permit. The Corrective Action Program has
significantly reduced the concentrations of these constituents in the monitoring wells.
Figures 6 through 9 show trends of concentrations of creosote constituents and PCP in
monitoring wells WC-8 (upgradient side of plume), WC-14 (center of plume), WC-25
(downgradient side of plume), and WC-33 (downgradient of the closed contact cooling
water pond). The trends in concentration show that the groundwater plume is being
remediated and that a former affected area near the closed contact cooling-water pond
has been remediated.
93I3099P-107/099P-107.TXT PRP93
2

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I Location: B.R..LA HI* namo: K:\DRWC\INTPAPER\1B272C-6.DWG U»t edited: 05/21/83 O 12:09
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CITRONELLE WELL
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Figure 3 - CAP FLOW RATES
2.5

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CITRONELLE WELL
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RECOVERY WELL

-------
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-------
Woodward-Clyde
CREOSOTE CONCENTRATIONS, WELL WC-08
WICJGINS, MISSISSIPPI

-------
Woodward-Clyde
CREOSOTE CONCENTRATIONS. WELL WC-14
WIGGINS, MISSISSIPPI
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-------
Woodward-Clyde
CREOSOTE CONCENTRATIONS, WELL WC-25
WIGGINS, MISSISSIPPI
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Jan-66 Jan-87 Jan-fl8 Jan-89 Jan-90 Jan-91 Jan-92 Jan-93 J an-94
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WIGGINS, MISSISSIPPI
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Jan-86 Jan-87 Jan-68 Jan-89 Jan-90 Jan-91 Jan-92 Jan-93 Jan-94

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CORRECTIVE ACTION PROGRAM
INTERNATIONAL PAPER
TREATED WOOD PRODUCTS DIVISION
WIGGINS, MISSISSIPPI
Project Manager: Mr. Thad McCoy
International Paper
Presentation by: Mr. Michael Simms

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ABSTRACT
GROUND WATER REMEDIATION
SHALLOW AQUIFER
KAISER ALUMINUM & CHEMICAL CORPORATION
MULBERRY, FLORIDA
Kaiser Aluminum & Chemical Corporation has been operating a surflcial aquifer ground water recovery
system at its Mulberry, Florida facility since 1986. This recovery system was initially designed and
installed to prevent the migration of chloride and fluoride-enriched ground water as a result of past
operational procedures at the site. Since its installation, this ground water collection system has been
found to be suitable for the recovery of contaminated water allegedly resulting from the operation of two
hazardous waste impoundments at the site. The ground water recovery system consists of a series of ten
(10) wells installed to depths of up to 38 feet below ground surface equipped with centrifugal pumps.
The recovered ground water is disposed via the on-site deep injection well used to for the disposal of
process wastes. To date, the system has been found to be effective in containing and recovering the
contaminated water at the site.

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KAISER ALUMINUM & CHEMICAL CORPORATION
MULBERRY, FLORIDA FACILITY
1.0 INTRODUCTION
1.1 FACILITY BACKGROUND
1.1.1 Plant Process and Raw Materials
Kaiser Aluminum & Chemical Corporation (KACC) owns and operates a chemical manufacturing facility
located approximately lYi miles west of Mulberry on State Route 60 in Polk County, Florida, as shown
on Plate 1. The plant began operations in March, 1957 to produce sodium silicofluoride (NaSiF6) from
the reaction of sodium chloride (NaCl) in solution and fluorosilicic acid (HjSiFj). Fluorosilicic acid is a
derivative of the phosphate industry and is shipped to Kaiser's plant in a concentration of 10-25 percent
(by weight) in rubber-lined tank trucks. The fluorosilicic acid (FSA) is stored in steel, open-topped tanks.
These tanks are lined with either rubber or HDPE and are located within a lined containment area. Salt
is currently delivered by truck in the form of rock salt. In the past, salt was delivered by railcar. The
rock salt is stored on a concrete "pad" with approximately three-foot high sidewalls. This pad is utilized
to create the brine for the sodium silicofluoride process by continually recirculating water over the salt
piles. The salt pad is lined with High Density Polyethylene (HDPE).
The rock salt is dissolved in water to create a saturated brine and is reacted with the fluorosilicic acid.
A nearly insoluble sodium silicofluoride precipitate is the reaction product. The dry sodium silicofluoride
was historically shipped to Kaiser's Chalmette, Louisiana, Aluminum Reduction Plant to produce
synthetic cryolite for use as a "bath" chemical in the aluminum reduction cells.
As part of waste reduction efforts, Kaiser's aluminum facilities converted their wet off-gas scrubbers to
dry off-gas scrubbers, using alumina (Al203) ore. As a result, fluoride was recovered and recycled back
into the process resulting in a decreased demand for synthetic cryolite and, therefore, a decreased
demand for sodium silicofluoride. Gradually, the reduced market for cryolite caused a shift in the sodium
1

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sillcofluoride market. As Kaiser's internal use of synthetic cryolite decreased for aluminum reduction,
Kaiser has shifted its marketing of sodium silicofluoride to municipal and industrial users.
In 1990, Kaiser also began to produce relatively small quantities of potassium silicofluoride (K, SiFe) in
response to specific client orders. The potassium silicofluoride is manufactured in the same manner,
using the same equipment as that used to produce sodium silicofluoride, however, potassium chloride
(KC1) is utilized instead of rock salt. The dry potassium chloride is dissolved in water. The solution is
then stored in lined, steel, open-topped tanks located within a concrete containment area.
The reaction of fluorosilicic acid with salt or potassium chloride,
H,SiF4 + 2NaCl - Na,SiF4 + 2HC1,
HjSiFj + 2KC1 - KjSiF, + 2HC1
results in the production of sodium or potassium silicofluoride plus the byproduct, a weak hydrochloric
acid (less than 5%). The actual waste stream from the process consists predominantly of byproduct HC1,
but can also include some soluble silicofluoride, excess salt, and amorphous silica.
1.1.2 Waste Disposal
The sodium silicofluoride plant was started in March, 1957, and had a designated annual capacity of
35,000 tons. The current annual production rate is less than one-third of the design capacity. Based on
the review of Kaiser's files and historical aerial photographs, the byproduct HC1 was initially neutralized
with finely divided limestone to a pH of approximately 4 in what is identified as the "Neutralization Pit".
From this facility, the waste stream overflowed into the western third of what is now considered the
"Inactive Drainfield". The waste water then discharged to the North Pond and eventually into nearby
streams. The locations of the Neutralization Pit, Inactive Drainfield and the North Pond are shown on
Plate 2.
In 1964, Kaiser upgraded the acid neutralization facility by adding a lime slaking facility utilizing "quick
lime" (CaO) as a second stage to the limestone neutralization system. These improvements reportedly
increased the pH of the discharge from the neutralization facility to a range of 7.0 to 9.0. Also at this
2

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time, the Inactive Drainfield was expanded to approximately its current size by incorporating the eastern
one-half of its area. The neutralized waste stream, including unreacted limestone and the other waste
stream components were discharged to the Inactive Drainfield for settling. The decanted slurry water
then discharged to the North Pond via a weir structure. The water in the North Pond overflowed via a
weir structure in the northwestern portion of the pond into a small unnamed stream and thence to the
North Prong Alafia River.
While the pH of the waste stream had been treated, the neutralization process released chlorides, in the
form of calcium chloride (CaCl), into the neutralized fluids. In late 1969, the State of Florida expressed
concern over excess chloride discharges from the plant.
Kaiser responded by installing a deep disposal well in 1972 to inject the waste stream into deep carbonate
formations. At this time, the use of the Neutralization Pit and Inactive Drainfield was discontinued. The
injection well system consisted of a surge basin, constant head tank and injection well. The waste stream
was pumped to the "Surge Basin" which was an above-ground, earthen basin lined with an artificial
membrane (Hypalon). A seepage detection pipe was constructed beneath the basin along the longitudinal
axis of the basin. The Surge Basin acted to moderate the effects of changing production rates and to
feed a constant rate into the injection well system. The Surge Basin-also allowed solids in the waste
stream, which included unrecovered sodium silicofluoride and amorphous silica, to settle out. From the
Surge Basin, the acid was pumped to a constant head tank and then pumped down the injection well.
The location of the Surge Basin in shown on Plate 2.
In 1976, KACC was notified by the Polk County Health Department that two domestic wells located
adjacent to the North Pond had elevated chloride concentrations. The locations of these two wells are
shown on Plate 2. At this time, the North Pond still contained relatively high concentrations of chlorides
as a result of the previous "flow through" waste disposal procedure. A subsequent investigation attributed
the chlorides in the ground water of the upper semi-confined aquifer to the North Pond. Recommenda-
tions resulting from this investigation included lowering the pond level to decrease the vertical head
difference between the North Pond water and the potentiometric level of the intermediate aquifer system.
It was also concluded that natural dilution of the chloride-impacted ground water would occur if pumping
of the North Pond waters was implemented.
3

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KACC began pumping the North Pond in 1976 as a result of these recommendations. The pumped water
was discharged to the South Pond. From there, it was pumped to the Surge Basin for disposal through
the injection well. The location of the South Pond is shown on Plate 2. In addition to reducing the
vertical head difference, it also removed high chloride waters resulting from the previous waste disposal
practice and caused surficial aquifer waters to flow towards the pond, thus recovering chloride-enriched
surficial aquifer water.
Process improvements were made that resulted in the recovery of the sodium silicofluoride product and
other solids that previously entered the waste stream. As a result, on January 20, 1983, the Surge Basin
was taken out of the disposal circuit. Since then, the waste stream has been pumped directly to the
constant head tank for disposal Currently, water is still pumped from the North Pond to the South Pond
and, thence, to the constant head tank for disposal.
1.2 ENVIRONMENTAL SETTING
1.2.1 Generalized Geologic and Hvdrologic Setting
The Kaiser Mulberry Works lies on the Central Highlands physiographic province and within the Alafia
River basin. This part of Polk County is also in the Central Florida Phosphate District.
Geologv/Hvdrogeology
Geologically, the region is underlain by several thousand feet of Tertiary carbonates which are mantled
with granular sediments. The artesian Floridan aquifer occupies the upper several hundred feet of the
carbonate deposits consisting of the Lake City Limestone, Avon Park Limestone, Ocala Group, Suwannee
Limestone, and permeable portions of the Tampa Formation. Secondary artesian aquifers are found in
the permeable parts of the Hawthorn Group. The lesser permeable sections of the Tampa Limestone
and fine-grained sediments of the Hawthorn Group act as the confining bed overlying the Floridan
aquifer.
The Mid-Miocene Hawthorn Group includes the Bone Valley Member. T. Scott, 1988 in "77le
Lithostratigraphy of the Hawthorn Group (Miocene) of Florida", Florida Geological Survey, describes the
4

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Bone Valley Member of the Hawthorn Group as clay ranging in color to include blue green and olive
gray with widely varying percentages of quartz sand and phosphate grains. The phosphate grains
reportedly range in color from black to white. Typically, near the bottom of the Bone Valley Member,
phosphate and quartz sand are absent, or nearly so, resulting in a "bed clay", which is approximately 10
feet thick in the area. (Please note that Scott, 1988 elevated the Hawthorn Formation into a Group-
status of which the Bone Valley Formation became a "Member". This report reflects these changes
whereas the RFI Workplan did not.) The Bone Valley Member has been subjected to extensive mining
in western Polk County to remove the phosphate ore. A coarser sediment overlies the phosphate deposit,
which is generally composed of quartz sand with varying percentages of finer-grained sediment. This
coarser-grained quartz unit comprises the shallow, water table aquifer in the region.
Kaiser's Mulberry Works property was mined in the 1930's, prior to acquisition by Kaiser, for the pebble
phosphate which originally occurred in the Bone Valley Member. These mining activities have disrupted
and disturbed the surficial sediments and shallow aquifer at the site. During mining, the surficial
sediments which comprise the shallow aquifer were stripped to allow removal of the pebble phosphate
contained in the sandy and clayey matrix. This matrix was slurried and pumped to the beneficiation
facilities. After extraction of the pebble-sized phosphate, the waste clay and quartz sand (tailings) were
slurried and pumped back to the mine pits. At the time that the Kaiser site was mined, the overburden
was often also moved by slurrying and deposited in the mine pits. In various areas, mine pits were not
completely filled, creating ponds on the site. The North and South Ponds are two such mine pits as is
at least the eastern one-third of the "Inactive Drainfield".
As a result of mining activities, the shallow aquifer at the site has been greatly altered. Throughout the
site, the redeposition of waste clays interbedded with sand tailings has created an anisotropic and hetero-
geneous condition in the surficial sediments that once were the shallow aquifer. In places dominated by
waste clay, the shallow aquifer is not present and the clay acts as a barrier diverting the shallow ground
water flow. On the other extreme where sand tailings are predominant, the sediments are quite perme-
able. This complex framework has greatly complicated the shallow aquifer conditions on Kaiser's
property. Plates 3, 4 and 5 show the shallow geologic conditions in cross-sections at the site based on
soil borings drilled as part of investigations on Kaiser's property.
5

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As shown on the cross sections, the soils of the mined areas can generally be classified into two units.
These units are an upper layer of tailings and overburden sands underlain by a unit consisting of a variety
of mine wastes. The upper unit varies from approximately 3 to 35 feet in thickness and represents the
more! permeable portions of the shallow aquifer.
The sediments underlying the tailings unit consist of a variety of materials including overburden, waste
clay, tailings, and interbedded tailings and waste clays. These sediments are areally discontinuous across
the site.
Clayey sand/sandy clay underlies these units and is generally unmined matrix of the Bone Valley
Member. This unit is continuous across the site and appears to act as the base of the shallow aquifer
except in those areas where waste clays overlie the matrix. In these areas the waste clays are the base
of the shallow aquifer. The thickness of the unmined matrix varies from approximately nine to 31 feet
as measured in those borings that penetrated the matrix.
Numerous permeability and pumping tests have been conducted on the site in order to evaluate the
hydraulic characteristics of the surficial sediments. As would be expected in sediments with these varying
physical characteristics, the hydraulic characteristics also vary widely. Hydraulic conductivity of the
surficial aquifer ranges from a high of 1.0 x 10'2 centimeters/second (cm/sec) to a low of 1.6 x lO"*
cm/sec. The clayey matrix displays lower hydraulic conductivities, on the order of 10"5 to 10"7 cm/sec.
Waste phosphatic clays are reported to have hydraulic conductivities ranging from 1 x 10'7 to 1 x 10"10
cm/sec as reported by W.D. Carrier, HI, L.G. Bromwell, and F. Somogyi in a professional paper dated
May 1983 entitled "Design Capacity of Slurried Mineral Waste Ponds* in Vol. 109, No. 5 of the Journal of
Geotechnical Engineering. The permeability of the unsaturated portion of the surficial aquifer, while not
tested, is expected to be similar to that of the saturated portion of the aquifer due to the similarities of
the soils.
The clayey sand/sandy clay that serves as the base of the shallow aquifer has a vertical hydraulic conduc-
tivity that ranges from 6.15 x 10"4 cm/sec to 2.64 x 10'7 cm/sec.
At least two secondary artesian aquifers underlie the confining bed. The first such aquifer consists of
a sandy limestone ranging in thickness from approximately 9 to 19 feet. The lower of the secondary
6

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artesian aquifers consists of a dense limestone interbedded with clay layers. These two units have
generally low permeabilities but are used locally for domestic water supplies.
Two soil borings drilled in 1976 adjacent to the North Pond provide an illustration of subsurface geology
below the surficial sediments. A geologic cross-section developed from these borings is shown on Plate
6. The approximate location of this cross-section is shown on Plate 3.
Surface Features
The ground surface of site is gently sloping to flat, with the highest point on the site located in
approximately central to north-central portion of the site. Three ponds exist on the site, identified as the
North Pond, the South Pond and the West Pond, as shown on Plate 2. The area identified as a "pond"
west of the South Pond is a "wet weather"-type pond. This area contains standing water only during
periods of heavy or prolonged rainfall. As will be discussed in the following, the South Pond was a
RCRA-regulated unit. Similarly, the North Pond is included in one of the SWMU's being investigated
as part of an RFI. The West Pond is hydrologicaUy separated from the North and South Ponds and does
not receive surface runoff from the plant process area or other known waste disposal areas.
13 REGULATORY HTSTORY
The following discussions present information pertaining to regulations and permits appropriate for the
waste disposal and"waste management units. This discussion is not intended to encompass all of the
permits issued to Kaiser.
1.3.1 Ground Water Monitoring Plan
In 1984, a Ground Water Monitoring Plan (GWMP) was prepared for the Kaiser Mulberry facility. This
document was a compilation of data from several studies at the site that had shown that plant operations
had contributed to alterations of the ground water quality within the shallow, water table aquifer at the
site. In particular, the ground water in the surficial aquifer contained elevated concentrations of
chlorides, and, to a lesser degree, fluorides. Plates 7 and 8 identify the plume of water affected by
chlorides and fluorides, respectively, in 1984.
7

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As part of the GWMP, a ground water recovery system consisting of ten (10) wells pumped on a near-
continuous basis was also installed by Kaiser. The locations of these wells are shown on Plates 7 and 8.
The recovery system consists of 10 recovery wells, an electrical centrifugal pump mounted at each well
and plumbing fixtures (Plate 9). The recovery wells have been set up to operate in three groups or lines.
Line 1 consists of wells R-l through R-5, Line 2 consists of wells R-6 and R-7, and Line 3 consists of
wells R-8 through R-10. Water from the three "lines" converge between R-5 and R-6 where each line
discharges through a flow meter to a common collection pipe. It then flows to an in-ground sump and
then to the injection well (Plate 10).
The recovery system was designed to create a ground water barrier in the path of contaminant migration
identified in the GWMP. In general, the plume of chloride contaminants extended to the west and
northwest of the plant site. The designed drawdown was initially developed to be effective over a long
and narrow area, removing contaminated ground water as it passed the recovery system. The recovery
system was placed in operation in December, 1985.
The recovery wells were installed using rotary wash drilling techniques. At each recovery well, borehole
soil samples were collected to select proper well screen settings. The recovery wells are constructed of
4-inch diameter, Schedule 40 PVC, .015-inch slotted screen and casing and vary in depth from 27 to 38
feet below ground surface, with the exception of well R-7. Well R-7 is located in a lower-lying area and
was installed to a depth of 17 feet below ground surface. All of the wells extend to the base of the
surficial aquifer and are screened through the entire saturated portion of the aquifer.
Aquifer performance tests were performed on each of the ten recovery wells after their installation to
identify the productivity of each recovery well. Design withdrawal rates for each well were selected based
on findings of these tests to "fine-tune" the recovery system design.
Based on the information collected, the design pumping rates for each of the recovery wells was as
follows:
8

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Weil
Pump Rate >'
(gallons per minute)
R-l
2
R-2
5
R-3
5
R-4
5
R-5
5
R-6
2
R-7
0.5
R-8
5
R-9
5
R-10
2
The design pumping rates were developed by evaluating the drawdown of ground water levels projected
by pumping the recovery wells for a one-year period. The drawdown projection levels were obtained by
using a computer model based on the Hantush-Jacob Method.
Kaiser also designed and installed source controls to curtail the possible release of contaminants at
potential sources. These source control improvements were completed in July 1987. They included the
lining and installation of sumps and pipelines to catch and/or control releases from the raw product
storage areas, the process area and the waste stream disposal (injection well) area.
13.2 Hazardous Waste Closure Permit
Kaiser previously operated two hazardous waste storage units regulated under the provisions of RCRA.
These regulated units were the Surge Basin, utilized for the settling of solids and moderating of process
waste flows prior to the injection into the disposal well, and the South Pond. Both of these units
contained "characteristic wastes" that were classified as hazardous as a result of corrosivity (pH less than
2). While not a dedicated portion of the industrial waste stream, the South Pond had received overflows
of process waste water (and during early stages of plant operations, may have accepted the waste stream
directly) as well as other spills of acid products and waste stream to lower the pH of the water to less
than 2. Prior to January 1984, Kaiser modified the manufacturing process to allow the removal of the
9

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Surge Basin from the process waste injection system. Also at this time, Kaiser installed measures to
intercept any spillage of process waste and/or raw products and to prevent their introduction into the
South Pond. A closure plan was prepared and submitted to the Florida DER for review and approval.
The Florida DER issued Closure Permit No. HF53-098862 to Kaiser on March 8, 1988 for the closure
of these two regulated units.
Closure of the Surge Basin consisted of neutralization of the remaining sediment and fluid in the basin
with soda ash. Fluid generated during neutralization activities was decanted and disposed through the
injection disposal welL The neutralized sediments were left in the Surge Basin and the berms were
graded so as to cover these remaining sediments. This work was completed in September 1988 and the
closure was certified in accordance with the approved closure permit.
At the time of submittal of the closure permit application, the pH of the water in the South Pond had
risen to above a pH of 2 and the fluid was no longer considered hazardous. No further closure activities
were performed for the South Pond and the pond was certified as being closed in April 1988.
As part of the Surge Basin closure activities, soils were sampled in the unsaturated portion of the surficial
aquifer beneath the Surge Basin and analyzed for hazardous constituents (metals only) in accordance with
EP Toxicity methods. None of the soil samples analyzed in this manner were determined to be
hazardous as a result of EP Toxicity for metals. As a result, no additional solids removal was required
after neutralization activities were completed.
As part of the approved closure requirements, ground water samples were collected every two months
from eight wells and analyzed for several water quality parameters. This water quality data was
statistically analyzed in accordance with 40 CFR Part 264, Appendix IV (student t-test) to assess the
possible past release of hazardous waste or hazardous constituents from the two regulated units. The
water quality data and the mandated statistical analysis indicated that statistically significant increases
in the concentration of several parameters had occurred. Under 40 CFR Part 264.98, these increases
purportedly indicate release(s) from one or more of these units. However, KACC contended that
interferences from other sources (primarily the inactive drainfield but also historical mining activity and
other waste management units on-site) and not regulated units, where the source for the apparent
statistically significant increases. Accordingly, KACC submitted a report demonstrating "clean closure"
10

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in support of this contention. After reviewing this document, the DER determined that clean closure of
the two regulated units had not been demonstrated as it could not be cgnclusivefy shown that the presence
of contaminants in some monitor wells could not be attributed exclusively to the inactive drainfield.
As a result, Kaiser submitted an application to the DER to modify the closure permit to include post-
closurecare. Kaiser has been operating under a "Post-Closure" permit since September 20, 1991. During
the development of this permit, the monitoring and reporting requirements in the GWMP permit were
revised and incorporated into the post-closure permit in order to consolidate monitoring and reporting
to the DER.
As part of this permit submittal, the plume of the hazardous constituents detected during the closure
activities had to be delineated. These hazardous constituents were arsenic, barium, cadmium and
chromium. With the exception of chromium, the plumes of these constituents are shown on Plates 11,
12 and 13. Chromium was detected in these wells at concentrations below the Maximum Contaminant
Level (MCL). As a result, no plume was delineated.
1.3.3 RCRA/HSWA Permit
KACC applied for a renewal of the facility's injection well permit on October 21, 1985. Underground
injection control (UIC) permit (permit No. UO53-111507) was issued to KACC on February 6, 1989
under the provisions of Chapter 403, Florida Statutes and Chapter 17-28, Florida Administrative Code
(FA.C.). The location of the Class I UIC injection well is shown on Plate 2.
During review of the RCRA permit, EPA Region IV conducted a RCRA facility assessment (RFA) and
issued a report which identified a total of eleven Solid Waste Management Units (SWMU's) at the site.
The EPA concluded that three of these SWMU's required additional study. These SWMU's were the
Inactive Drainfield and North Pond, the Concrete Neutralization Pit, and a small area where waste
product (sodium silicofluoride) had been stored outside. The locations of these three SWMU's are
shown on Plate 2.
As a result, the RCRA permit, effective March 17, 1989, required that a RCRA Facility Investigation
(RFI) be performed for each of these SWMU's. On May 3, 1991, the EPA approved the RFI Workplan
and the results of the RFI were presented to the EPA on November 8, 1991. The RFI report was
11

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subsequently revised to provide additional information requested by the EPA and resubmitted to the
EPA on September 22, 1992. KACC is currently waiting for the EPA's final approval of the report.
The results of the RFI activities were summarized as follows:
a.	Ground water around the Inactive Drainfield contains elevated concentrations of chloride,
fluoride, arsenic and total dissolved solids. The sludge in the Inactive Drainfield was found
to be a contributor of these constituents.
b.	Surface water in the North Pond contains elevated concentrations of chloride and total
dissolved solids. Sludge in the North Pond, apparently from the Inactive Drainfield, is a
likely contributing source of these constituents.
c.	No appreciable impacts resulting from the neutralization pit or the waste product storage
pile on the ground water were identified.
However, the existing ground water recovery system adequately controls and collects contaminated
ground water and surface water resulting from the Inactive Drainfield and the North Pond. As a result,
no further corrective actions were believed to be necessary at the site.
SUMMARY
The ground water recovery system installed at the Kaiser facility has been found to collect and contain
ground water contaminated at the site by a number of sources including past operational practices, the
storage of raw materials, and, allegedly, the now-closed hazardous waste units. This system has been
operated since 1985. The oral presentation for this project will address operational problems and
remedies and the effectiveness of the system.
12

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KAISER ALUMINUM ft CHEMICAL CORPORATION.
MULBERRY. FLORIDA PLANT SITE*.
PREPARED BY RICHARO FOUNTAIN & ASSOCIATES.
JULY 1976.
KAISER ALUMINUM A CHEMICAL CORP.
DATE
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Conoultama In the earth sclonces
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400 Ft.
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DISTRIBUTION OF CHLORIDES

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400 Ft.
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KAISER ALUMINUM
& CHEMICAL CORPORATION
Paul Maasen is currently the General Manager for the
Fluorides Business Unit with Kaiser Aluminum & Chemical
Corporation. This responsibility includes over-all management
of a chemical plant in Mulberry, Florida with environmental
signature authority for the State of Florida. During the past
five and one half years, the facility has been involved in
several RCRA oriented activities including post closure
permitting, HSWA permitting, and successful deep well variance
permitting.
Mr. Maasen holds an engineering degree with extensive
post-graduate credits in addition to a master's degree in
business administration.

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CASE STUDY OF AN ENVIRONMENTAL MANAGEMENT
PROGRAM TO STABILIZE CONTAMINATION FROM A
COLUMBUS, MISSISSIPPI WOOD TREATING FACILITY
Kerr-McGee Chemical Corporation, Forest Products Division initiated
an Environmental Management Program in the mid-1980's at Columbus,
Mississippi to stabilize releases of wood preserving constituents
in soils and groundwater. Alternative waste management processes
were developed allowing closure of surface impoundments, drip
tracks, tank farms and heavily contaminated areas. Contaminated
soils were removed, clay lined concrete facilities were installed
to prevent future contamination of soils and groundwater.
Groundwater corrective measures have been implemented at the
facility to prevent the migration of wood preserving constituents.
Ten operating recovery wells and two containment trenches were
installed to recover dense non-aqueous phase liquid (creosote) and
recover contaminated groundwater. A high density polyethylene
(HDPE) barrier in conjunction with a containment trench was
installed to ensure no additional migration of wood preserving

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I. THE WOOD TREATING INDUSTRY
The purpose of the wood treating industry is to extend the useful
life of wood in the environment. For example, the life cycle of
creosote treated railroad products such as railroad ties in the
commercial environment is extended from approximately 5-7 years to
30-40 years by pressure treatment with creosote. Although our
forests are a renewable resource, treated wood reduces the demand
for lumber and thus treated wood saves trees. It has been
estimated by the industry that 30,000 trees per year are saved by
using treated wood in the environment. Creosote, a by-product of
coal, is forced into wood under pressure to prevent decay by
insects, nematodes, fungi and bacteria for commercial product such
as railroad ties, utility poles and piling. Creosote preservation
of wood constitutes approximately 10% of the total volume of
treated wood per year in the U.S.
The wood treating industry is regulated by the Federal Insecticide
Fungicide Rodenticide Act (FIFRA) of 1988 and mandates the safe use
and handling of restricted use pesticides in the environment.
FIFRA regulates the application of wood preservatives and reguires
Licensed Certified Applicators to use pesticides such as creosote.
The Act requires registration of pesticides, facility inspections,
labeling of products, and proper personal protective equipment,
certification of applicators, and annual training requirements for
commercial applicators.
II. KERR.McGEE CHEMICAL CORPORATION
The Forest Products Division of Kerr-McGee Chemical Corporation is
the largest producer of creosote treated railroad products in North
America. Railroad cross ties, switch ties and railroad bridge
timbers are produced by the Divisions seven wood treating
facilities located in Avoca, PA; Columbus, MS; The Dalles, OR;
Indianapolis, IN; Madison, IL; Springfield, MO and Texarkana, TX.
In the past eight years, Kerr-McGee's market share has increased
from 26% to approximately 45* of the U.S.market. The Forest
Products Division attributes the increase in market share to the
quality assurance of our products and services, environmental
stewardship and safety. The highest quality is achieved by the
Forest Products Division at a rate 17 times safer than their
competitors in the forest products industry as reported by the
Bureau of Labor Statistics. An overview of Kerr-McGee, Forest
Products Division's, strategies for the past decade are contained
in Attachment 1.
III. THE COLUMBUS, MISSISSIPPI WOOD TREATING FACILITY
Kerr-McGee Chemical Corporation, Forest Products Division (KMCC-
FPD) owns and operates a wood preserving facility in Columbus,
Mississippi. The Columbus facility has been in operation since

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1928, manufacturing pressure treated railroad products including
wooden cross-ties, switch ties and bridge-timbers. KMCC-FPD
purchased the facility in 1964. Upon it's purchase, the facility
became part of Moss American Corporation, a wholly owned subsidiary
of Kerr-McGee Corporation. In 197 4, Moss American became the
Forest Product Division of Kerr-McGee Corporation. The plant
occupies approximately 90 acres and its location is shown in
Figure 1.
The facility previously maintained a hazardous waste surface
impoundment as part of the wastewater treatment system/creosote
recovery system. The impoundment was used to settle out solids and
preservatives from the process wastewater. Preservatives were
recovered from the impoundment and returned to the production
process for reuse. In 1980 KMCC-FPD submitted a Part A, RCRA
Application to operate the surface impoundment.
IV. ENVIRONMENTAL MANAGEMENT PROGRAM
In the mid-1980's Kerr-McGee adopted strategies to upgrade the
Columbus, Mississippi facility. These strategies included the
following elements: 1) develop new waste management practices which
would permit the closure of surface impoundment, drip track and
tank farms; 2) remove significant sources of soil contamination in
the product unloading area, drip track and tank farms that
contribute to groundwater contamination; 3) eliminate ongoing
releases of contamination to soils and groundwater by installing
creosote impervious containment in tank farms, unloading and
drippage areas; 4) prevent the potential for future releases of
contamination to the environment; 5) and cleanup releases to
groundwater which resulted from historical operations. The
operations and environmental practices of the Columbus wood
treating plant date back to the 1920's; consequently, the facility
had significant levels of soil and groundwater contamination.
For example, common practices in the Industry and at the Columbus
facility even up to 1985 were to store creosote and contaminated
water in a clay lined surface impoundment; remove freshly treated
wood from treatment cylinders allowing creosote drippage to
adjacent soils; and store creosote in unlined tank farms. These
operating practices resulted in releases of creosote to the soil
and groundwater.
The commitment by KMCC-FPD to change historical operational
practices, resulted in the design and implementation of water
conservation programs, design of a new production process creosote
recovery system and design of the 40 CFR 264, Subpart W Drip Pad.
Implementation of a water conservation program and installation of
a new creosote recovery system allowed impoundment closure in the
Summer of 1986 in accordance with a state approved closure plan.
Design of a Subpart W drip pad and tank farm containment allowed
voluntary closure of the drip track and tank farms in 1987.

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V. SITE STABILIZATION
A.	REGULATORY OVERVIEW
Groundwater monitoring in the vicinity of the surface impoundment
in the mid-1980's demonstrated that releases to groundwater had
occurred. This resulted in several groundwater quality assessments
and in 1989 Kerr-McGee Chemical Corporation and the Mississippi
Department of Environmental Quality executed an Agreed Order
requiring that the nature and extent of releases be characterized
for regulated units and solid waste management units as well as
submission of a revised RCRA, Part B Application. In addition, the
Agreed Order required the implementation of groundwater corrective
measures both on and offsite.
B.	RESULTS OF SITE INVESTIGATIONS
Introduction
The Columbus facility has undergone extensive field investigations
to delineate groundwater contamination associated with the
historical releases due to past practices in the production process
area Solid Waste Management Units (SWMU) and the closed
impoundment. Over fifty soil borings and fifty monitoring wells
have been installed at the facility. In addition, twelve recovery
wells and two trenches have been constructed to contain and
remediate groundwater. The location of wells, piezometers and
borings installed during these investigations are shown in
Figure 2.
These investigations concluded that two separate areas of Dense
Non-Aqueous Phase Liquid (DNAPL) are present. One contaminant
plume is located in the area of the production process at the
southwestern corner of the facility. A second plume, is located in
the eastern end of the facility and is associated with past
releases from a historical below ground loading dock in the black
tie storage area. These contaminant plumes are depicted in Figure
3 . Releases in the production process areas are attributed to past
operational practices of the surface impoundment, drip track and
tank farm.
Regional and Local Geology
The Columbus facility is located along the eastern flank of the
Mississippi Embayment of the Gulf Coastal Plain (Stephenson and
Monroe, 1940). The site is underlain by Quaternary alluvial
deposits. Underlying the alluvial deposits is the Cretaceous age
Eutaw formation consisting of impervious interbedded clays, silts
and fine sands. A 1982, U.S. Geological Survey, Water Resources
Regional cross-section located south of Columbus (Figure 4)
illustrates the steep southwesterly dip typical of the Eutaw
formation. The Eutaw outcrops in the Columbus area. Figure 5
describes the stratigraphy underlying the Columbus facility.
The Columbus facility, located approximately one mile west of the
Luxapalila Creek, is located in the Upper Tombigbee River Basin.
A topographic map shows the facility location in relation to the
creek (Figure 1). The map shows a topographic high ridge west of

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the facility which represents a surface water divide. Due to the
influence of this feature, the local groundwater discharges to the
east into Luxapalila Creek.
An east-west cross-section across the KMCC-FPD facility has been
provided as Figure 6. Quaternary alluvial deposits beneath the
site are approximately 15-25 feet thick consisting of interbedded
silty clay, sands and gravels. The cross-section illustrates that
the alluvium consists of approximately 5 feet of clays overlying
undifferented sands and gravels in the production process area.
The Eutaw formation and also a weathered zone of the Eutaw is
encountered approximately 15-25 feet below the ground surface.
Regionally, the Eutaw formation can be as much as 500 feet thick.
At an approximate depth of 2 00 feet or greater, the Eutaw has
served as a water bearing aquifer and source of industrial and
domestic water. However, in the area of the Columbus facility, the
Eutaw consists of finer grained material, is less permeable, and
serves as an aquitard for the Alluvium aquifer.
The Eutaw structure map shown in Figure 7 was constructed from soil
borings and monitoring wells installed at the facility. A
weathered zone of orange, medium to coarse grained glauconitic
sand, sometimes overlays the green colored Eutaw. Erosional
channels are evident as north to south trending low areas on the
surface of the Eutaw formation.
Creosote is heavier than water and migrates vertically through the
saturated subsurface until encountering a geologic formation that
is impermeable to creosote. Free phase creosote product, DNAPL,
has been observed beneath the production process area and beneath
a historical tie loading area at the Columbus facility. The
migration of free phase creosote product on the Eutaw surface is
controlled by the topographic surface produced by the erosional
channels in—the Eutaw formation. Eutaw formation soils encountered
in 50 borings and nearly 50 monitoring wells throughout the site
have shown the Eutaw formation is impervious to creosote.
After sixty years of operation the creosote (DNAPL) contaminant
plumes are relatively small and are confined to low (topographic)
areas of the Eutaw formation as shown in Figure 3. This suggests
free phase product moves extremely slowly and is controlled by dip
of the Eutaw formation, low permeability of the alluvium and
adsorption of the creosote product. The on-site remediation system
and the proposed off-site expansion of this system were designed to
prevent further migration and to recover historical releases.
Groundwater
The structural configuration of the Eutaw formation controls the
migration of free phase product with free product migration related
to gravity. In contrast, migration of the dissolved constituents

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is predominantly controlled by groundwater flow direction and
constituent solubility. The constituents of creosote are
relatively insoluble in water as shown in Figure 8.
A potentiometric map of the alluvial aquifer is shown in Figure 9
and was constructed on the groundwater elevations prior to the
implementation of groundwater recovery. The static water level
of the facility ranges from just below the surface to a depth of 13
feet below grade. The potentiometric surface varies by
approximately 12 feet across the facility with a gradient of 1
foot/180 feet. Slug tests performed at the facility have
determined that hydraulic conductivities are in the range of 3 X 10'
5 cm/sec. Generally, the groundwater flow direction is in a south-
easterly direction. A potentiometric map of the Eutaw formation is
shown in Figure 10.
C. GROUNDWATER CONTAMINANT AND REMEDIATION
Introduction
The contaminant plumes are composed of both free oil and dissolved
constituents. As previously discussed and shown in Figure 3, free
oil contaminants in the production process area is concentrated in
the erosional depressions of the Eutaw surface. The Eutaw
structure map (Figure 7) depicts the erosional surface. The
recovery wells and collection trenches were placed in the erosional
lows to maximize product recovery.
The dissolved constituents parallel the east to south-southeast
groundwater flow direction of the alluvial aquifer. Based on
field assessments, soil borings and analytical data, the extent of
contamination and configuration of the contaminant plume is shown
in Figure 3.
The interior (inner-most) plume of free creosote oil has
recoverable free product. The free oil plume extends from the
facility production process area southward to the location of
Trench 1 corresponding with erosional lows in the Eutaw Formation.
A plume of free product has also been delineated on-site in the
eastern half of the facility and is associated with a SWMU.
Generally, the free product in the SWMU is at shallower intervals
than product found in the production process area. In many of the
soil borings, the product has not migrated vertically to the
contact between the Eutaw and the overlying alluvium.
KMCC-FPD implemented several corrective measures for the recovery
of both product and dissolved constituents in the groundwater.
Twelve recovery wells as well as two containment trenches with
three collection galleries serve as hydraulic barriers for capture
of dissolved constituents and the recovery of free product. In
addition, boundary control wells, compliance wells, corrective
action effectiveness wells, Eutaw wells and alluvial piezometers
are monitored to demonstrate the effectiveness of groundwater
corrective measures.

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Recovery Wells
The purpose of initial corrective action was to prevent off-site
migration of free creosote product found in the structural lows of
the Eutaw surface south of the production process area. The
initial corrective action system consisted of five recovery wells
(RW3, RW4, RW5, RW6, and RW7) placed south of the production
process area on the property line. These 8-inch diameter recovery
wells were placed approximately 100 feet apart with piezometers
placed between each well to measure the area influenced by the
pumping wells.
These wells were installed with a duplex suction to the recovery of
either DNAPL or groundwater. Conductivity level switches cycle the
recovery well to maintain hydraulic control. Figure 11 is a
schematic diagram of the installation of recovery wells.
All recovered groundwater is pumped directly into a 2,000 gallon
recovery tank or discharged to the POTW when pre-treatment permit
requirements are met. The recovery tank is pumped into the
facility creosote recovery system during DNAPL recovery or whenever
pre-treatment permit requirements are not met.
Although not required by the permit, two recovery wells (RW2 and
RW8) were constructed in the production process area for
supplemental removal of free phase product interior to the DNAPL
plume. Recovery well, RW10, was installed in the interior of the
DNAPL plume to recover free phase product in the SWMU at the
eastern end of the facility. Recovery wells RW11 and RW12 were
installed for hydraulic control, downgradient of Trench 2.
Trenches and Collection Galleries
Dewatering galleries were placed in containment trenches south of
the process area and at the SWMU area east of the production
process area. Two collection galleries were placed in the lowest
Eutaw erosion.al surface found in the east-west trending Trench 1A.
The third sump was placed in the SWMU area, in the southern end of
Trench #2. A schematic diagram of dewatering galleries and the
containment trenches are shown in Figures 13 and 14 respectively.
Locations of the three collection galleries and the two trenches
are shown on Figure 15. Cross-sections of the construction details
of Trench 1 are shown on Plate l. The east/west section of Trench
IA,	is approximately 392 feet long. The north/south "TM, Trench
IB,	is approximately 344 feet long. Trench 2 is approximately 290
feet in total length and is shown in Plate 3. The trench is
overlain on the northern edge by one set of railroad tracks.
Each of the three collection galleries utilizes a dual pumping
system. The upper pump intake is placed approximately seven feet
from the sump bottom in Trench 1 and at four feet from the bottom
of the sump in Trench 2. The lower pump intake is placed at the
bottom of each collection gallery to remove free product. Free

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product is removed weekly. Product thickness is measured on a
daily basis to ensure that product is removed at appropriate
intervals. Each pump is operated as, required to maintain a
predetermined water level using a level controller and groundwater
is discharged to the POTW or to the facility creosote recovery
system. Figure 16 is the potentiometric surface of the alluvial
formation with recovery wells and the containment trenches in
operation.
Containment Trench 1 was installed in 1992 and is located south of
the production process just south of recovery wells RW3 through
RW7. Trench 1, RW3, and RW7 are now used for a hydraulic
groundwater barrier and product extraction. RW4, RW5 and RW6 are
now used exclusively for product removal. These wells are measured
for product thickness and pumped as required to optimize product
removal. RW3 and RW7 are cycled with level controllers to augment
hydraulic control of Trench 1.
D. MEASURES OF EFFECTIVENESS
The effectiveness of the recovery system is based on the removal of
groundwater, reduction of free product thicknesses in monitoring
wells, and also on the zone of capture produced by the recovery
wells/trenches. Piezometers have been placed in the vicinity of
pumping wells and the trenches to measure water levels. The
piezometer locations are shown on Figure 16. Piezometers were
constructed within Trench 1 and 2 to monitor their performance. A
capture zone is observed surrounding both Trench 1 and Trench 2.
The recovery of free creosote product and dissolved constituents
from the 8" recovery wells was initiated August 20, 1990. From
August 8, 1990 to October 22, 1992, approximately 7.5 million
gallons of contaminated groundwater and free creosote product have
been recovered from the recovery wells. The pumping of the
recovery trenches/collection galleries and the recovery wells
contributed.to the total recovered volume of 9.3 million gallons on
December 31, 1992.
An additional 5.1 million gallons have been recovered during the
first six months of 1993 from recovery wells and trenches. A total
of 14.4 million gallons have been recovered and treated since the
start-up of the recovery system.
A program has been developed to measure and remove DNAPL in
dewatering galleries, recovery wells and monitoring wells. Removal
of DNAPL is of the highest priority. Collections galleries and
recovery wells have been placed in Eutaw lows and measurement of
DNAPL thickness provides an indicator of DNAPL removal over time.
Figure 17 is an example of declining thickness of DNAPL in a
monitoring well (CMW12) where active removal has been implemented.
CMW12 is also under the influence of DNAPL recovery well RW2.
Figure 18 is an example of declining thickness of DNAPL in a

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recovery well (RW4) where active removal has been implemented. Not
all wells at the facility have shown dramatic, reductions in DNAPL
thicknesses.
The contaminant plume has been relatively stable since
identification through various groundwater investigations. This is
attributed to the chemical and physical behavior of wood preserving
constituents, low solubility of these constituents, local geology,
and low hydraulic conductivity of the alluvial formation.
VI. WHY THE ENVIRONMENTAL MANAGEMENT PROGRAM
HAS BEEN SUCCESSFUL
A.	Commitment from Upper Management
B.	Commitment From the Facility
C.	Commitment from the Community
1. Open House
2	. Knock on Doors
3	. News Media Interviews
D.	Relationship with State Agency
1.	Voluntary Actions
2.	Communication
3.	Oversight
4.	Consent Orders
5.	Permits
E.	Customer Awareness Program

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1970's WOOD TREATING PLANTS
PROCESS SCHEMATIC
WASTE PIUS

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1990's WOOD TREATING PLANTS
PROCESS SCHEMATIC
- - - 1 - ^1

%
rSl) ... . ' )
J

*rr kHy
B B
\Hy
B
P
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COLUMBUS NORTH. MISS.
SWM CALEDONIA IS' QUADRANGLE
33088-E4-TF-024
1987
DMA 3351 10 SW-SERIES V843
FIGURE 1
TOPOGRAPHIC MAP SHOWING THE COLUMBUS FACILITY,
KERR-MCGEE CHEMICAL CORPORATION, FOREST

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EXPUUUTION
CUE1 •	CMC - EUTAW WELLS
CMW4 •	CMW-SHALLOW ALLUVIAL WELLS
835 O	BORMSS
nm	PIEZOMETERS
Rl A	RECOVERY WELLS
CMWU *	PLUMED
KERR-McfiEE CORP. - HYDROLOGY DEPT.
00LUWIU8 FACILITY
KtRR-MeCti CBSM1CAI COKP.
fOMWST PRODUCTS DITISIOH
MAr DATS 8/S3

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cww-fli
Oe - BLTTAW WELLS
CMW1 • CMW-SMLLOW ALLlMAL WBXS
WSO BOOKS
re ¦ riFZocras
Ml A R6C0VBH WBXS
QWI3» n.UOOH>
0 tUMP
EZ2) THCMCH
CHw-ae
KERR-Mc6EE CORP. - HYDROLOGY OEPT
ooLuwaua faoiuty
KtHR-VtCKK CaamtCAL COUP.
MUST PRODUCTS DIVISION
OATB JANUMT 1083

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10 MlKt
o s 10 is KtioMdms
VERTICAL SCALE GREATLY EXAGGERATED
EXPLANATION
|''J"L """j Outcrop of Eutaw and HcShan Formations
A	J*	A1 Line of geohydrologlc section with electric-
log location.
Base map fro® U. S. Geological Survey Map
of Mississippi, 1972.
Geology froa Professional Paper 448-1, Plate 2.

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FIGURE 5
LITHOLOGIC DESCRIPTION FOR THE STRATIGRAPHIC UNITS
UNDERLYING THE COLUMBUS, MS FACILITY
u
£
0>
>»
-ua.
—w
41
S.
01
CO
A.
3
O
L.
CJ
Stratigraphlc
Unit
Thiclcness
(FT)
Llthologic Description
A1luvium

>1
o
L.


o
c
N
u
OJ

c
•M
01

o
3

©¦
c
0>
u
4)
QC
at
c
41
u
O
4>
a.
0-60
Approx.
25 at
Facility
Clay, silt, sand, and gravel
Basal part generally has
the coarser material.
Occurs as alluvial fill
in the flood plains of
the Tombigbee River and
its larger tributaries.
Terrace
Deposits
0-50
Not present
at facility
Clay, silt, sand I gravel.
Basal part generally has
the coarser material.
Deposits forming terraces
cover extensive areas along
the eastern side of the
Tombigbee River & small
areas on the western side.
Eutaw
Formation
* (including
Tombigbee
Sand Member)
240
0
01
iA
3
0
01
0
«
4-)
01
u
o
3
O
O)
o
40
+J
k.
o
u
&
Q.
McShan
Formation
Sand with clay & shale
lenses. Tombigbee Sand
Member forms the upper
half (120 feet) of the
Eutaw formation. The Tombigbee
is fine-to-medium-grained,
highly glauconitic, calcareous
and massive sand, but may
include shale and bentonic
clay.
Beds of sand in the lower
half of the Eutaw generally
have slightly coarser sand
A less glauconite than
sand beds in the upper
half. The ratio of clay
£ shale to sand may vary
widely within short distances.
The Eutaw crops out along
& mostly east of the Tombigbee
River and dips to the southwest.
~The Tombigbee Sand Member
is not present at the Columbus
Facility.
100-150
Clay and sand with a few
thin beds of gravel in
the lower part of the formation.
Clay is mostly gray and
may be lignitic. Sand
beds are variable in thiclcness
and in grain size. McShan
uneerlies the four counties
exrspt for a small area
in northeastern Monroe
County.

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aor
D
w
1B5.0
180.0
175.0
170.0
165.0-
g
160.0 -
165.0
150.0-
145.0
140.0 J
- _ CMW-22
B-11
FIGURE 6
CROSS-SECTION ACROSS COLUMBUS FACILITY
MAP SHOWING CROSS-SECTION A - A\ >
KERR-MCGEE CORPORATION,	;
FOREST PRODUCTS FACILITY.	|

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WATER SOLUBILITY OF
POLYNUCLEAR AROMATIC COMPOUNDS
BACE/NEUTRAL SOLUBLE COMPOUNDS
CONSTITUENT
ACENAPHTHYLENE
ACENAPTHENE
ANTHRACENE
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(QHI)PERYLENE
BENZO(K)FLUORANTHENE
CHRYSENE
DIBENZ(A,H)ANTHRACEN
FLUORANTHENE
FLUORENE
INDENO(1,2,3-CD)PYRE
2-METHYLNAPTHALENE
NAPTHALENE(NAPTHENE)
PHENANTHRENE
PYRENE
0
10
15
20
MG/L
25
30
35

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1
FIGURE 9
POTENTIOMETRIC MAP OF ALLUVIAL FORMATION, 1ST QUARTER 1/30/90
KERR-McGEE CHEMICAL CORPORATION, FOREST PRODUCTS DIVISION

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CHW-Gl
CHw-se
gXFUUUTION
CHE3 •	OE - an AW WELLS
CHW4 0	CMW-SHALLOW ALLUVIAL WELLS
B25 O	BORINGS
P8 •	PlEIOftTBS
R1 A	RECOVQn WELLS
CMW13 w	PLUGGED
¦ fr	GROUNDWATER FLOW DIRECTION
208 FT
KERR-McGEE CORP - HYDROLOGY DEPT
C0LUMBU8 FACILITY
KERR-VoCEE CHEMICAL CORP.
FOREST PRODUCTS DIVISION
FIGURE 10

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I

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ACE
PUMP
DISCHARGE
ACCESS HATCH
3'X3' HINGED DOOR
FILL
MATERIAL
NOT TO SCALE
BENTONITE

-------
t. 0
x • ;
.*• . I
"-i " i
• - ¦ ;~ M
FILL MATERIAL
NATIVE SOILS
• GEOTECHNICAL FABRIC
DDDdDQQDDDDdDDnDDDDdd
idDdDDaaaddadDddanafld
ddddddadddDdddddddd
dddddddddddd
dddddddddd
aaaaaaaa
ddddddd
d d d d d d
ddddddd
d d d d d d d
ddddddd
ddddddd
d d d d d d
d d d d d tv
d d d d d
d d d d d
d d d d d
d d d d a
d d d d d
d d d d d
SAM fl fiftAVEP
NOT TO SCALE
(LATERAL FROM CORRECTIVE ACTION DEWATERING GALLERYI
FIGURE 14: CORRECTIVE ACTION CONTAINMENT TRENCH

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4' SCH. 40 PVC FRENCH DRAIN
NOT TO SCALE

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-------

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k RE 17
KMCC-FPD COLUMBUS, MS
PRODUCT THICKNESS
DATE MEASURED

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PRODUCT THICKNESS
1/29/92 3/2/92 4/27/92 6/26/92 6/22/92 7/27/92 8/31/92 9/28/92 1 0/26/92 11/23/92 12/21/92 1/26/93 2/22/93 3/23/93 4/26/93 6/24/93
DATE MEASURED

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Kerr-McGee Chemical Corporation
Forest Products Division
Oklahoma City, Oklahoma
The Forest Products Division of Kerr-McGee Chemical Corporation is
the largest producer of creosote treated railroad products in North
America. Over 45% of the U.S. volume of railroad cross ties,
switch ties and railroad bridges are produced by the Divisions
seven wood treating facilities located in Avoca, PA; Columbus, MS;
The Dalles, OR; Indianapolis, IN; Madison, IL; Springfield, MO and
Texarkana, TX. These facilities pressure treat both hardwoods and
softwoods to extend the useful life of wood in the environment from
5-7 years to 30-40 years. Although our forests are a renewable
resource, treated wood reduces the demand for lumber and thus
treated wood saves trees. Creosote, a by product of coal, is
forced into wood under pressure to prevent decay by insects, fungi
and bacteria.
The highest QUALITY is achieved by the Division at a rate 17 times
SAFER than their competitors as reported by the Bureau of Labor
Statistics, with a watchful eye on the ENVIRONMENT. World class
people build world class products safely with respect towards the
environment. Historically, these attributes were not the priority
that they are today. One of the predominate factors which have
changed the Division into a world class organization was an
environmental awakening which began in the early 1980's.
AN ENVIRONMENTAL COMMITMENT
In the early 1980's the Division and the plants made a commitment
to become a major producer of creosote treated wood products for
the railroads. To accomplish an increase the U.S. market share
from 20% to 40% a strategy was developed to completely change the
way we produced railroad ties. The environmental practices of the
treated wood industry had not advanced very much in the preceding
decade and the country was rightfully demanding environmental
accountability from all industries. Early on, the Division
concluded that its good business to conduct all operations in an
environmentally responsible way. To accomplish an improved
environmental awareness which is efficient and cost effective, new
and innovative ideas were developed since appropriate governmental
regulations and industry practices did not exist.
The strategies adopted by the Division were to 1) develop new waste
management practices; 2) eliminate all ongoing releases of
contamination to air, soil, and groundwater; 3) remove sources
that contribute to groundwater contamination; 4) install creosote
impervious surfaces to prevent the potential for future releases of

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contamination; 5) and cleanup releases of contamination to
groundwater which resulted from historical operations. The
operations and environmental practices of most o^our wood treating
plants dated back to the early 1900's; consequently, many of the
plants had significant levels of soil and groundwater
contamination.
For example, common practices of the Industry and Kerr-McGee in
1985 were to store creosote and contaminated water in clay lined
surface impoundments (ponds) which leaked; remove freshly treated
wood from treatment cylinders allowing creosote drippage to
adjacent soils; and store creosote in unlined tank farms. These
methods resulted in releases of creosote to the air, soil and
groundwater. Recognition that these methods resulted in pollution
were the cornerstone of the Divisions strategy to develop methods
for new and innovative waste management practices.
MODERNIZATION OF SEVEN WOOD TREATING FACILITIES
k
From 1985 to 1988 the Division closed all surface impoundments,
drip tracks and tank farms in the Division. New management
techniques required modificattion of the production process before
these units could be closed. | Prior to 1985 the production process
required large volumes of wiater to cool the process which was
stored in surface impoundments. New methods to obtain vacuum,
required by the production process, eliminated the need for large
water volumes and smaller volumes were satisfied by cooling water
towers where the water does fiot come into contact with creosote.
Water which comes in contact'with creosote was treated at a newly
designed and installed wastewater treatment plant to remove nearly
all of the creosote and discharged to a municipal wastewater
treatment plant for final treatment. Additional production process
changes resulted in reduced idrippage of freshly treated material
and less potential spillage iof creosote in the vicinity of tank
farms. __
After production changes were in place the Division began closure
of surface impoundments, drip tracks and tank farms. The EPA did
not have closure standards for these units in 1985. However, Kerr-
McGee committed to close all units by recycling and removing
contamination to the extent possible.
Typically, the contents of the impoundment were pumped to the new
waste treatment plant to recover creosote for reuse in the
production process. A patented process developed by Kerr-McGee was
then used to remove creosote from heavily contaminated material for
reuse. The remaining contaminated soils were excavated from
impoundments, drip tracks and tank farms were placed in an approved

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hazardous waste landfills. These units were then capped with clay
to prevent rain infiltration. Thus ongoing releases of
contamination were eliminated.
Drippage from freshly treated wood presented a unique challenge.
Not only were EPA closure standards non existent for drip tracks
there were no management techniques used in the Industry. The
Division designed and installed drip pads. A drip pad is an 18"
thick concrete pad to collect and reuse creosote drippage. All
Kerr-McGee facility's drip pads were installed before 1988. In
1990 the EPA ruled that all wood treating facilities must have drip
pads. The basis for the drip pad design adopted by EPA was the
Kerr-McGee drip pad.
During this same period contaminated soils were removed from areas
adjacent to tank farms, transfer lines were brought above ground
level permitting inspections, clay liners were installed providing
additional protection and impervious concrete floors and
containment walls were installed. Construction of tank farm
secondary containment was a voluntary program.
Groundwater remediation has been implemented at all facilities
where releases to groundwater has been identified. Recovered
groundwater is treated in the facility's wastewater treatment
system to remove and reuse wood preservative and discharged treated
water to a municipal wastewater treatment plant for final treatment
under the auspices of the Clean Water Act. At four facilities the
Division has implemented biological treatment of wastewater prior
to discharge. Biological treatment systems are relatively new
within the wood treating industry.
To date, the Division has spent over 30 million dollars upgrading
facilities.	These expenditures prepared the Division
environmentally for the 1990's, eliminated the potential for
ongoing releases to the environment, remediated past environmental
releases to soils, initiated groundwater remediation and resulted
in new and innovative waste management operations.
A NEW COMMITMENT
In the early 1990's the Division made a new commitment to the
environment and to the communities adjacent to Forest Product
Division plants. Specifically this commitment renewed our efforts
to reduce the generation of all wastes from ongoing operations. As
part of our operations thousands of tons of wood waste was
generated annually. Pollution Prevention and Waste Minimization
became the hallmarks of Division programs.
The plants have initiated preventive and corrective methods to
reduce inspection loss or the production of lower quality railroad
ties. During the drying and treatment process wood has a tendency

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to split. Split ties were rejected to a lower quality grade. In
the late 1980's Kerr-McGee begin a program pf installing a steel
plate on the end of the tie to correct and prevent tie splitting.
This program now has wide customer acceptance and significantly
reduces waste at the Plants.
The plants have in the past five years reduced the volume of solid
waste sent to landfills. The plants now transform the solid waste
into useful and profitable products. Kerr-McGee produces railroad
products, firewood, wood chips for mulch, industrial fuel, scrap
metal, recycled paper and wood chips to compost municipal sludge.
These "new products" have saved valuable landfill space, resulted
in a cost savings of over $300,000 per year and conserve valuable
natural resources.
Installation of creosote impervious surfaces in production process
area permit recycle and reuse of creosote as previously mentioned.
Reclamation of creosote contaminated groundwater also allows
recycle and reuse of the creosote.
THE RESULT
In the late 1980's our environmental expenditures put our Division
at a significant cost disadvantage since most companies were not
incurring environmental expenditures of this magnitude. However,
new regulations now require other companies to upgrade their
facilities and adopt environmental practices like Kerr-McGee's.
Many facilities have chose not to or have been financially unable
to upgrade their facilities and are no longer -in business. In the
past eight years, Kerr-McGee's marketshare has increased from
approximately 2 6% to approximately 4 5%
IP ANYTHING IS CONSTANT - "IT IS CHANGE"
Based on our past experiences, good environmental practices are
good business. Our proactive environmental programs have resulted
in Kerr-McGee being the largest producer and leader in the Industry
for safety, environmental stewardship and quality assurance. It is
apparent, that to thrive in today's economy requires the desire and
ability to recognize and implement change. The Division is
currently looking ahead to the end of the decade and has begun to
implement programs for the twenty first century.
The Division has started a new pilot plant to produce a new
generation of products. Rail Fast® is a new method to attach
railroad ties to railroad track, easy to maintain, and allow quick
rail change.
The Division has reentered the utility pole market and offers
treatment services using creosote or a new, environmentally
friendly substance, copper naphthanate.

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As a result of amendments to Clean Air Act of 1990 the Division is
preparing for new regulations expected to be final in 1996. The
Division is evaluating air pollution control technologies for odors
and emissions from the facilities. This proactive approach will
identify and evaluate appropriate control technologies and may
result in selection by EPA of approved control measures. The
Division has evaluated activated carbon and is currently evaluating
wet scrubbers and thermal oxidation.

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NICHOLAS BOCK
Nicholas Bock has a Bachelor of Science degree in Environmental
Health from Ferris State University. Post graduate studies in
hydrology have been conducted at the University of Waterloo and the
University of Delaware. Nick has been a Certified Hazardous
Materials Manager, Master Level, for the past five years.
Nick is Manager, Environmental Compliance and Regulatory Affairs,
for Kerr-McGee Chemical Corporation's, Forest Products Division and
has responsibility for seven operating wood treating facilities.
Previously, he conducted environmental research for the pulp and
paper industry for four years, was an environmental engineer at an
automotive manufacturing plant and served as an Environmental

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Cardinal*

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A Comparison of Two Groundwater Recovery Systems:
Finding Solutions that Work
Abstract:
In 1967, Lockheed Aeronautical Systems Company, located in
Charleston, South Carolina was constructed. Situated on the
property were three surface impoundments used to contain wastewater
and sludge from metal cleaning and plating operations. In 1982, a
leak detection system revealed that leakage was occurring from one
of the three ponds. In 1987, a groundwater recovery system
consisting of three recovery wells was installed. Both the Theis
and Plasm models were employed in system design. However, field
conditions drastically differed from the model output; the wells
could not produce the expected flow rate, and iron bacteria caused
severe operational problems. Because of these factors, the system
required intense maintenance for continued operation. In 1993, the
original system was abandoned and a new groundwater recovery system
was installed. The new system, consisting of 15 recovery wells,
was designed to correct the inadequacies and failures of the
original system. Recent hydrogeological data demonstrates
increased hydraulic control. This discussion compares and
contrasts design parameters, operation and maintenance procedures,

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LOCKHEED AERONAUTICAL SYSTEMS COMPANY
A COMPARISON OF TWO GROUNDWATER
RECOVERY SYSTEMS:
FINDING SOLUTIONS THAT WORK

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TOPICS OF DISCUSSION
•	FACILITY BACKGROUND
•	SOURCES OF GROUNDWATER CONTAMINATION
•	SITE HYDROGEOLOGY
o CONTRAST ORIGINAL GROUNDWATER RECOVERY
SYSTEM [in operation 12/87 - 7/93] WITH NEW
GROUNDWATER RECOVERY SYSTEM [completed 7/93]
Design Parameters
Operational Difficulties

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LOCKHEED AERONAUTICAL SYSTEMS COMPANY
CHARLESTON. S.C.
PRODUCT: MANUFACTURER OF BONDED AND RIVETED
AIRCRAFT PARTS (C-5, C-141, C-130, P-3 AND F-22)
PROCESSES: METAL FABRICATION, CLEANING, PAINTING
AND PLATING
DATE OF CONSTRUCTION: 1967
SIZE: 14.5 ACRES
FOUR MAIN BUILDINGS
TOPOGRAPHY: ATLANTIC COASTAL PLAIN
NORTHERN PART OF PROPERTY

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LOCKHEED AERONAUTICAL SYSTEMS COMPANY

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CAUSE OF CONTAMINATION:
3 SURFACE IMPOUNDMENTS
UNiT AND DIMENSIONS
Equalization Pond #1
135'X 135'X 18'
Equalization Pond #2
81'x 81'x 12'
( Settling Pond #3
70' x 110' x 6'
WASTE
Metal Cleaning and Plating
Wastewater (Raw)
Metal Clearing and Plating
Wastewater (Raw)
Metal Cleaning and Plating
Wastewater (Treated) and
F006 Sludge
WASTE
CHARACTERISTICS
Low pH, Chromium, TCE
Low pH, Chromium, TCE

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HYDROGEOLOGY
UPPERMOST AQUIFER: SURFICIAL AQUIFER OVERLYING
THE COOPER MARL
COMPOSITION: SAND, CLAY AND SHELLS
AQUIFER SATURATED THICKNESS: 13 FEET
FLOW VELOCITY: 60 FEET PER YEAR

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53,3% l<),,6e8
1I6,3
-------
DESIGN PARAME. cRS -- ORIGINAL SYSTEM
® THEIS Well Field Model used to Estimate
Pumping Rates
-	Infinite Homogenous /^uifer Conditions Assumed
-	THEIS Determined Maximum Pumping Rate: 2 gpm
® PLASM Mode! used to Provide Direction in
Recovery Well Placement and Quantity
-	PLASM Results Indicated that 3 Recovery Wells
(Total Yield 6 gpm) Would Create an Effective Capture Zone
-	Cone of Depression is Limited by the Short Saturated

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OPERATIONAL PROBLEMS
ORIGINAL RECOVERY SYSTEM
•	Recovery Wells Incapable of Maintaining Hydraulic Control
Average Pumping Rates: RW-1 0.1 gpm
RW-2 0.5 gpm
RW-3 0.75 gpm
° Sedimentary Fines Clogged the Well Screens
•	Slime Attack - Iron and Sulfur Bacteria Clogged Lines,
Flow Meters, Pump Impellers and Well Casings
° Solvent Attack - TCE Corroded Electrical Wiring,

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ORIGINAL GROUNDWATER RB JRY WELL SYSTEM
AND
2/1/92 POTENTIOMETRIC SURFACE
PACE STREET
LEGEND
~ RECOVERY WELL
0 POINT OF COMPLIANCE WELL
MONITORING V/ELL
o.j'7 oRGUMnwriirR elevation iet h.s.lj t-ir Ac.ufccr> /1/¦ 

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23400 6,600
11,808
Sco 1 o »n Fco t
100
© MW_23 Point of Complionutt W»ll
^MW~22 Monitoriny Well
Lockheed Aeronouticol Systems Cofnpony
Charleston, South Carolino
GROUNDWATER TRICHLOROE THlflENE(og/L)
CONCENTRftlIONS
AKIfcR 5

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DESIGN PARAME1ERS - NEW SYSTEM
° Mathematical Equatipn used to Determine the Well
Yields Required to Sustain a Radius of Influence
Q = *K(H2-h)
In (R0/rJ
Known: K	=	Hydraulic Conductivity = 9 gpd/ft
H	=	Saturated Thickness of Aquifer = 13 feet
rvv	=	Radius of Wei! = 2 inches
h	=	Saturated Thickness of Aquifer at Well = 8 feet
R0	=	Radius of Influence
* Conclusion:
- .5 gpm (actual field value) would provide a
radius of influence of 30 feet
60 feet (2 x 30') required to provide hydraulic control

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PROBLEM - ORIGINAL SYSTEM
° Lack of Hydraulic Control with 3
Recovery Wells
SOLUTION - NEW SYSTEM
15 Recovery Wells Resulted in Increased
Hydraulic Control
° Bacterial and Solids Fouling
® Solvents Attacking Pump Wiring
• Sedimentary Fines Clogging
Recovery Well Screens
New Groundwater Pretreatment System
for Iron Removal Prior to Flow Entering
Stripping Towers
Existing Air Stripping Towers Repiped
for Cleaning Purposes
Quarterly Heat Treatment of Recovery
Wells to Destroy Bacterial Slime
Vacuum Extraction System, Rather than
Submersible Pumps Utilized
Sieve Testing Performed to Correctly

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NEW GROUNDWATER RECOVERY SYSTEM
AND
8/11/93 POTENTIOMETRIC SURFACE
NO II	
Bote mop on10 CcntOuf o' Lgud
O
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COST
Design &
Installation
Operation &
Maintenance
(Yearly)
ORIGINAL SYSTEM
$90,000
$45,000
Includes 4 new pumps
and motors/well/year;
2 new carbon units/year
and disposal; 3 new
sets tower packs/year
and disposal
NEW SYSTEM
$785,000
$ 63,360
(Projected)
includes steam treatment
of all recovery wells and
2 stripping towers

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CONCLUSIONS
•	KNOW FIELD CONDITIONS
-	MODELS MAY NOT SIMULATE ACTUAL FIELD CONDITIONS
-	PILOT SCALE STUDIES MAY BE USEFUL
•	MAKE SURE THE SYSTEM IS COMPATIBLE
WITH YOUR ENVIRONMENT
-	SOLVENTS IN GROUNDWATER CAN DAMAGE EQUIPMENT
-	BACTERIA CAN WREAK HAVOC
•	BEWARE OF OPERATION AND MAINTENANCE COST -

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elle Routman, Pollution Prevention Coordinator for Lockheed
nautical Systems Company
slle was employed by the Georgia Environmental Protection
sion from 1984 - 1990 in the Hazardous Waste Management Branch
; she evaluated groundwater monitoring and recovery systems at
-dous waste management facilities. In 1990, Rochelle became
>yed with Lockheed where she coordinated the hazardous waste
iance and remediation programs. This past year, Rochelle was

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16

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MODEL ASSISTED DESIGN OF A GROUNDWATER PUMP AND TREAT
SYSTEM AT THE PADUCAH GASEOUS DIFFUSION PLANT (PGDP)
Jeff W. Douthitt
Bruce. E. Phillips
Martin Marietta Energy Systems, Inc.
ABSTRACT
Discovery of contaminated residential well? north of the PGDP led to characterization of
an off-site ground-water plume containin2jrichloEoe,thylene (TCE) and technetium-99
("Tc) and identification of an on-site deri^ri^aqueous phase liquid (DNAPL) source
zone. A Record of Decision (ROD) requires an interim remedial action using pump and~
treat technology to control the most contaminated Ddttion of the plume and isolate the
source zone.
Extensive numerical, semianalytical, ajid analytical modeling aided every facet of well
field design. Initial modeling yielded^uant&afwe^conmarisons of optimal well numbers,
well placement, and flow rates. Lat6r. airioainea lffiteeer Drogramming model was used
to identify optimal monitoring well locations for capture zone analysis and on- and
off- plume contaminant concentration nfo^'tciri0g.,^nally, modeling provided

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INTRODUCTION
Contaminated ground water was detected in residential wells north of the Paducah
Gaseous Diffusion Plant (PGDP) in August 1988. Pursuant to an Administrative
Consent Order (ACO) administered under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), the Department of Energy (DOE)
conducted an investigation to determine the nature and extent of groundwater
contamination and to identify potential sources. The investigation results, combined with
related independent studies, have characterized a ground-water plume, known as the
Northwest Plume, consisting of trichloroethylene (TCE) and technetium-99 ("Tc).
proposed plan (Science Applications International Corporation 1993a) to
hydrodynamically control the plume hot spot and DNAPL source zone led to a Record
of Decision (Science Applications International Corporation 1993b) to install two pump
and treat systems within the Northwest Plume. One well field will hydraulically control
the hot spot, while a second will isolate the DNAPL source zone to prevent further
growth of the dissolved phase plume. The hot spot is defined as that portion of the
plume where TCE concentrations exceed 1000 micrograms per liter (ug/1) and 99 Tc
activities exceed 900 pico Curies per liter (pCi/1).
SITE DESCRIPTION
PGDP is owned by the United States Ezr-hment Corporation and operated by Martin
Marietta Utility Services, Inc. The plant is located approximately 10 miles west of
Paducah, Kentucky, and 3 miles south of the Ohio River (Figure 1). The plant is rurally
located on a 1350-acre reservation and :s surrounded! by the West Kentucky Wildlife
Management Area, homes, and farm land. The area is characterized by low relief with
the-Ideal topogpaphv sloping gently towards the Ohio River. The plant property is
:'relatjy§j$K®miph elevations ranging from 350 to 380 feet above mean sea level (amsl).
^^SfiPlias operated continuously since 1952 using a gaseous diffusion process to enrich
uranium in the 233U isotope. Uranium output from PGDP is ultimately designated for
national and international clients as fuel for commercial nuclear power reactors. PGDP
consists of a diffusion cascade and extensive support systems. Plant operation results in
generation of several waste streams (Science Applications International Corporation
1993c) that include organic constituents (primarily solvents) common to any large
industrial facility, nonradioactive metals related to the enrichment process, and uranium
and other radionuclides associated with the feed material.
GEOLOGY AND HYDROGEOLOGY
PGDP is located in the northern tip of the Mississippi Embayment. This area is
characterized by Cretaceous and Tertiary sediments unconformably overlying

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Pliestocene deposits collectively described as continental deposits. The continental
deposits are characterized by clay dominated facies overlying a sand and gravel
dominated facies. Site investigators subdivide the continental deposits into two units
referred to as the upper and lower continental deposits as illustrated in Figure 2.
Pliestocene alluviation of the entrenched ancesteral Tennessee River resulted in the sand
and gravel valley fill sequence (Clausen et alM 1992). The lower continental deposits lie
at an approximate depth of 60 feet, and range in thickness from less than 20 to greater
that 50 feet. The lower continental deposits are locally a primary ground water source
and are informally designated the regional gravel aquifer (RGA).
The RGA was deposited on an erosional surface at approximately 280 ft amsl (see
Figure 3a). A fining upward sequence with two distinct facies is evident. A sand unit,
when present, lies at a consistent statigraphic position overlying the sandy gravel facies.
This lower sandy gravel facies is predominantly gravel with silt and sand, but is
occasionally all sand or all cobbley gravel (Gausen et al., 1992). Figures 3b and 3c show
the thickness of these units. Their combined thickness, illustrated in Figure 3d,
constitutes the RGA.
Based on aquifer pumping tests, the RGA hydraulic conductivity ranges from 50 to 1200
ft/day. Computer modeling suggests average hydraulic conductivities are on the order of
425 to 725 ft/day (Clausen et al., 1992). The RGA is a leaky-confined aquifer, and in
general, the high hydraulic conductivity contrast between the RGA and the underlying
and overlying sediments requires flow to be primarily horizontal within the RGA.
Groundwater flow is generally northward toward the Ohio River. Most of the site
conceptual model is based on steady state concepts. However, the system is highly
transient and dependent on Ohio River stage. The potentiometric surface fluctuates
about 10 feet annually from approximately 322 to 332 feet amsl. Monthly water level
measurements exhibit variations which are dependent of the short-term transient
behavior of the jiver.
The upper continental deposits are primarily clay and silt, with lenses of sand or gravel,
and are approximately 50 feet thick. Ground water flow is believed predominantly
downward due to the strong downward hydraulic gradient and relative lateral
discontinuity of the permeable sediments. This unit primarily serves to provide recharge
to the RGA and is referred to as the upper continental recharge system (UCRS).
SOURCE DESCRIPTION
Two adjacent solid waste management units (WMU) located in the northwest corner of
the plant are the likely sources of the Northwest Plume. Monitoring data confirm the
presence of very high levels of TCE and 99 Tc.

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WMU 7 was used between 1957 and 1979 for disposal of uranium contaminated waste
consisting of noncombustible trash and equipment, concrete debris, and drums used to
collect uranium powder scrap. No specific records of TCE disposal are available, but the
burial ground was used for general waste disposal. A stockpile of radiologically
contaminated metal scrap is also present aboveground at the unit. WMU 30, contiguous
to WMU 7, was used from 1951 to 1970 to burn combustible trash. Remaining ash and
debris were buried belowground. Although no specific records are available, TCE
contaminated trash may have been disposed here.
Investigators have concluded these areas are a primary source of off-site contamination.
Results from the CERCLA investigation indicate TCE in soils and groundwater at levels
up to 5800 ug/1. ®*rc was detected at activities up to 3500 pCi/1. In addition, several
metals, including arsenic, barium beryllium, cadmium, chromium, cobalt, copper, lead,
nickel, vanadium, and zinc, were detected in groundwater (CH2M Hill, 1992).
Results from a later independent study show TCE concentrations near the WMUs
increasing with depth and exceeding 1 percent of the aqueous solubility. These results
strongly suggest the presence of residual or pooled DNAPL from the ground surface to
the base of the aquifer. Consequently, the source zone for this plume includes the
WMUs, along with the residual and pooled DNAPL within the soil and aquifer matrix.
(Clausen et al., 1993).
PLUME DESCRIPTION
The Northwest Plume, shown in Figure 4, is characterized by both TCE and "Tc
distributed vertically throughout the RGA. Data from 19 monitoring wells and 10
residential wells, located in or adjacent to the plume, were used to characterize the
plume. Additionally, 70 discrete-depth samples from temporary boreholes have been
collected. TCE concentrations in wells exceed 6000 ppb on-site and 2000 ppb off-site.
^Tc concentrations in wells exceed 3000 pCi/1 on-site and 1500 pCi/1 off-site. The plume
reaches a maximum width of approximately 3500 feet and extends roughly 2.5 miles
off-site. Discrete ground-water samples from vaiying depths in the plume show that
concentrations generally increase with depth (Clausen et al., 1993). Near the source,
TCE levels near 14,000 ppb were detected. The high dissolved phase concentrations
(>1 percent solubility), which tend to increase with depth, suggest a DNAPL source.
Figure 5 shows the interpreted plume profile through a north-south cross section.
Off-site, the TCE/^Tc concentration ratio in the plume is generally consistent and is a
geochemical signature for the plume (Clausen et al., 1992). The plume underlies a 1.75
square mile area and consists of approximately 3 billion gallons of contaminated
groundwater. Advective migration is approximately 1/2 to 2 feet per day, and the TCE
mass flux through a unit thickness cross section is on order of 6 gallons/year. The total
dissolved mass of TCE is approximately 400 to 600 gallons, the equivalent of 7 to 11
fifty-five gallon drums. Just 6 percent of the total mass occupies nearly 90 percent of the

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total contaminated pore volume. The estimated total mass of 99 Tc in solution ranges
from three to six lbs.
WELL FIELD DESIGN
Cleanup alternatives for the dissolved phase plume are limited because of the DNAPL
source zone. Consequently, DOE's ground water strategy involves source zone control
coupled with plume management. As outlined in the ROD, the objectives of the interim
remedial action are to utilize convetional extraction well systems to hydrodynamically
control the plume hot spot and isolate the DNAPL source zone (Science Applications
International Corporation, 1993b). Two well fields, designed to meet these objectives,
are located downgradient of the hot spot and near the DNAPL source zone. Both well
fields will consist of two extraction wells with ancillary monitoring networks.
Well field design criteria included creating capture zones sufficient for plume hot spot
and source zone capture, and installing monitoring wells sufficient for on- and off-plume
monitoring of background water quality, gradient control, contaminant fluctuations, and
aquifer properties (Keely, 1989). Three main constraints affected final system design.
First, no aquifer test data were available within the study area, and such tests were
considered logistically infeasible. Second, environmentally sensitive areas near both well
fields limited available field sites for exploration and well placement. Lastly, project
schedules and budgets limited the surface treatment capacity to 100 gallons per minute
per well field, and the number of monitoring wells to 10 per well field. Site staff used
these criteria along with extensive groundwater modeling to choose final well locations.
Extraction Well Network Design
GeoTrans, under subcontract, conducted initial modeling, focusing on extraction well
field design and consisting of two phases. First, an existing regional model was revised
to reflect the current conceptual flow system model. This 3-dimensional model,
developed using MODFLOW (McDonald and Harbaugh, 1988), simulated the overall
flow system but was discretized to support later detailed analyses of the Northwest Plume
containment option. This regional flow modeling provided estimates of hydraulic
conductivities, boundary effects, parameter sensativities, and mass balances.
The calibrated model was subsequently used to evaluate the feasibility, design, and
effectiveness of the proposed pump and contain system. This phase involved optimizing
well pumping rates and locations. Three codes were utilized for this phase:
MODFLOW was used for all groundwater simulations; MODMAN, a code developed by
GeoTrans for the South Florida Water Management District and later enhanced for the
U. S. Environmental Protection Agency, transformed groundwater management
objectives and constraints (i.e., maximum allowable pumping rates and well locations,
desired containment width) into linear and/or mixed integer programs; and LINDO
(Schrage, 1989) was used as a solver for the integer programs to yield optimal solutions

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to the management problem. Optimal well locations and flow rates were identified for
various combinations of extraction wells, flow rates, and containment objectives. While
flow rates were ultimately governed by surface treatment capacity, these analyses
provided system designers with quantitative comparisons of optimal well numbers, well
placements, and flow rates (GeoTrans, 1992). TTiis information was useful for making
capture zone comparisons for a number of well field scenarios during initial project
scoping. Table 1 is an example of the type of results generated from this study.
TABLE 1. Pumpage Optimization Results.
Containment
Optimal
Total
Line Length
Wells
Pumpage
(feet)

(gPm)
2400
16
464
600
5
183
A second modeling phase analyzed resultant well field efficiency when extraction wells
were combined with injection wells, in situ cutoff walls, and walls with permeable gates.
Note that the ROD for the Northwest Plume interim action currently specifies only the
use of conventional extraction wells. System designers felt, however, that any final
solution would require maximizing pumping efficiencies to reduce long-term operation
and maintenance costs. The results from this second phase showed that injection of
treated water, combined with extraction, reduced the required pumpage by 35 to 45
percent. Further, combining extraction wells with in situ cutoff walls decreased required
pumpage by 60 to 80 percent (GeoTrans, 1993).
Monitoring Well Network Design
The monitoring well network was designed to define capture zones, monitor for
contaminant fluctuation and breakthrough, and determine aquifer properties. In meeting
these objectives, the number of potential wells was limited by tight schedules and initial
budget estimates based on a ten-well monitoring network. This estimate included wells
completed within the RGA and within underlying and overlying strata. Additionally,
piezometers are required for aquifer test analysis during system start-up. System
designers assumed a minimum of one well each in under- and overlying strata, and a
minimum of three piezometers for aquifer test analysis. This left five potential locations
for monitoring system performance within the RGA. In order to meet design objectives
while maximizing resources, the previously developed ground-water flow model was
coupled with an optimization model.
This procedure involved generating a grid of hydraulic head values that simulated the
active well field (from the groundwater flow model). Following this, contaminant values

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were assigned to each grid node based on detailed plume maps interpreted from field
data. These data sets were subjected to optimization runs using a modified integer
programming model. This is a hueristic method based on facility location theory, and
allows consideration of data importance at specified locations. The data importance and
location are specified using weighting functions applied to grid regions. For this
particular case, areas with the greatest drawdown, and with contaminant concentrations
greater that 1000 ug/1 TCE and 900pCi/l, were assigned the greatest importance. The
most important locations were those located nearest the pumping center, providing
information regarding the potential field, contaminant breakthrough, and aquifer
parameters. Coverage at distal upgradient locations was considered less important.
Initially, potential locations resulting from each optimization run were plotted on a map
of the plume. Locations maximizing upgradient potential field coverage within the
plume, and downgradient coverage near the stagnation point, were then chosen. These
locations were subsequently modified to avoid environmentally sensitive areas.
Ultimately, five field sites were chosen which provided optimal coverage for the hydraulic
head and plume monitoring. Finally, well locations for aquifer testing were determined
using standard analytical techniques to estimate, expected drawdown as a function of
time and radial distance from the well field. Figure 6 shows the locations of both well
fields, along with the well network at each field.
SYSTEM PERFORMANCE EVALUATION
Lastly, well field performance was evaluated using analytical, semianalytical, and
numerical models. Capture zones were generated using each model and compared. Like
the earlier optimization modeling, capture zone analysis often require use two models:
one to simulate groundwater flow, and another to produce travel time-related capture
zones. For all cases, two extraction wells, spaced 150 ft. apart and pumping at 50 gpm,
were simulated.
Ground-water Flow Models
CAPZONE (Bair et al., 1991) and GWPATH (Shafer, 1990) were used for the analytical
solution. CAPZONE computes drawdown distributions at grid nodes for leaky-confined
aquifers using the Hantush-Jacob equation. The Hantush-Jacob equation assumes an
isotropic, homogeneous, infinite aquifer overlain by a continuous leaky confining unit.
Drawdown is superimposed on nonpumping potentiometric surfaces to simulate pumping
effects on nonuniform flow fields. GWPATH numerically computes the two-dimensional
steady-state velocity field at grid nodes based on distributions of hydraulic head,
hydraulic conductivity, and effective porosity. Travel time-related capture zones are
produced by placing particles in a circle surrounding a pumping well and tracking the
reverse pathlines for a specified time.

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RESSQC, a module in USEPAs WHPA program (Blandford and Huyakorn, 1989), was
used for the semianalytical solution. RESSQC computes travel time-related capture
zones for wells in fully-confined aquifers using the Thiem equation. This model
calculates the velocity potential assuming a uniform regional flow field. Since RESSQC
does not provide an output of head distribution, heads were modeled with DREAM
(Bonn and Rounds, 1990).
The capabilities of the previous models are limited by the simple flow systems they
simulate. To simulate a more complex flow field with spatially variable properties, it is
necessary to use numerical models such as MODFLOW (McDonald and Harbaugh,
1988) coupled with MODPATH (Pollock, 1989).
MODPATH is a semianalytical postprocessor for MODFLOW designed to compute
pathlines from steady-state output. MODPATH assumes linear velocity variation within
grid cells allowing an analytical expression to be obtained, describing the flow path within
the cell. Points along a particle path and intermittent travel time can be computed given
the initial particle position.
Conceptual Flow Model
The flow system at PGDP is conceptualized as a leaky-confined aquifer. The aquifer is a
heterogeneous sand and gravel deposit with an average thickness of 30 feet. This is
overlain by up to 50 feet of interbedded silt and clay with thin lenses of sand and gravel.
Differences in the conceptual flow model and the computer models are shown in
Table 2.
TABLE 2. Comparison of conceptual flow model to mathematical flow models.
Hydrogeologic
Feature —
Conceptual
Model
MODFLOW
CAPZONE
WHPA-RESSGC
Flow System
3-dimensional
3-dimensional
2-dimensional
2-dimensional
Aquifer
Leaky-
Leaky-
Leaky-
Nonleaky-

confined
confined
confined
confined
Regional
Non-uniform
Non-uniform
Non-uniform
Uniform
Flow Field




CAPZONE was used to construct the analytical flow model. The model was designed
with a 36 by 51 node grid with 200 feet nodal spacing. All four extraction wells were
modeled discharging 50 gallons per minute (gpm) over a 365-day period. Aquifer
parameters used in the analytical model are provided in Figure 7a. Drawdown from
CAPZONE was superimposed on the potentiometric surface for June 1992. The June

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1992 potentiometric surface was utilized in the model to represent the dynamic
steady-state configuration for the regional flow system. Dynamic steady-state is
considered to represent the spatial distribution of heads within the flow system when
their configuration represents average conditions based on hydrograph analysis
(Bair et al., 1991).
RESSQC was used to model the same area as the CAPZONE model. However, only
the northern pumping wells were considered in this model. Since RESSQC requires a
uniform hydraulic gradient, the capture zone for the southern well cluster would be
similar. The input parameters for RESSQC are provided in Figure 7b.
The same model used to support the extraction well design (GeoTrans, 1992) mentioned
previously was used to numerically simulate the flow field at the north well field. The
model is three-dimensional and consists of 117 columns, 91 rows and three layers. Total
areal coverage of the model domain is 23 square miles and block sizes range 50 x 50 feet
to 2200 x 1000 size. Model layering correlates to the site stratigraphy with layer one
representing the UCRS, layer two representing the RGA, layer three representing the
McNairy Formation (see Figure 2) (GeoTrans, 1992). Model output simulating the
north well field were input into MODPATH for particle tracking and capture zone
estimation.
Estimated Time-Related Capture Zones
Differences in the size of the one-year and two-year capture zones are shown in Table 3.
Figure 8 shows the outline of the projected one-year capture zones for the north well
field computed using the three previously described methods.
TABLE 3. Comparison of the area of the composite capture zones for the
north well field.
Method
1-Year Capture Zone
(acres)
2-Year Capture Zone
(acres)
MODFLOW/
31
54
MODPATH


CAPZONE/
24
43
GWPATH


RESSQC
22
43
From Figure 8 and Table 3, it is obvious the capture zone simulated by
MODFLOW/MODPATH is the largest. The one-year capture zone from

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MODFLOW/MODPATH encompasses 31 acres, approximately 30 percent larger than
the other models. The two-year capture zone encompasses 54 acres, approximately 26
percent larger than the others. These results are very similar to those of other
investigators (Springer and Bair, 1992). Because CAPZONE relies on superposition of
drawdowns on a nonuniform flow field, the capture zones generated by GWPATH are
more similar to the output from MODFLOW/MODPATH than those generated by
RESSQC. Springer and Bair (1992) note that because of the conceptual limitations in
applying CAPZONE and RESSQC, the capture zone generated by
MODFLOW/MODPATH is more realistic.
In all cases, however, it appears from Figure 8 that the capture zone will be sufficient to
satisfy the performance objective to capture the plume hot spot. The plume hot spot is
depicted by the dark shaded area signifying contaminant concentrations > 1000 ug/1
TCE. These capture zone widths mark the trace of the last particles captured at the
edge of the outer most stream tubes. It is unlikely these capture zones, as dipicted,
could be physically measured in the field.
An important distinction between the performance evaluation modeling and extraction
well optimization modeling, described earlier, should be noted. Extraction well
optimization modeling utilized MODFLOW with an optimization model (MODMAN)
and solver (LINDO). An input constraint into the optimization model was the desired
containment width (capture zone width) which is defined by specifying a minimum
inward hydraulic gradient. The inward hydraulic gradients used were chosen such that
they could be actually measured in the field (equivalent to a hydraulic gradient of 0.001).
Optimal well locations are identified which meet this constraint.
Conversely, the performance evaluation codes solve for capture zone size given a
configuration of wells and flow rates. This capture zone width, at any given distance
from the pumping center, is the combined width of all stream tubes ultimately entering
the wells. It is questionable whether this capture zone could ever be measured in the
field. The optimation modeling reflects capture zone widths that can actually be verified
through field monitoring and are thus smaller that the theoretically values. This is
illustrated by comparing the containment line widths reported in Table 1 with those
depicted in Figure 8. In Table 1, five wells, spaced 150 ft. apart with a total pumpage of
183 gpm, were required for the specified containment width of 600 feet. However, the
capture zones in Figure 8 are approximately 1200 feet wide and were created by only two
wells pumping a total of 100 gpm.

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CONCLUSION
Detection of an off-site ground-water plume north of PGDP resulted in a ROD requiring
hydrodynamic isolation of the plume hot spot and DNAPL source zone. Extensive
computer modeling supported design of well fields at two locations. In the absence of
site-specific hydraulic data, flow modeling provided system designers with estimates of
parameter sensitivity, boundary conditions, and hydraulic conductivity values. Modeling
also provided quantitative comparisons of containment scenarios, extraction rates, and
well spacing.
The authors realize the limitations of using mathematical modeling as a design and
performance evaluation technique. The theoretical assumptions inherent in models
necessarily limit the ability to simulate reality. Further, the ability of mathematical
models to evaluate pump and treat systems is also subject to considerable error where
the study site has not been adequately characterized (Keely, 1989). However, the system,
as designed, will provide detailed aquifer test data during intial start-up. Additionally,
during drilling and installation of the well fields, provisions have been made to gather the
necessary additional geologic data the authors consider critical. Hopefully, these data
will support more detailed near-field transient modeling, which will better predict system
performance.

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REFERENCES
Bair, E.S., Safreed, and Berdanier. 1991. CAPZONE - An Analytical Flow Model for
Simulating Confined, Leaky-Confined, or Unconfined Flow to Wells With Superposition
of Regional Water Levels. User's Manual prepared for Ohio EPA. Department of
Geological Sciences, Ohio State University, Columbus, OH.
Blandford, T.N., Huyadorn. 1989. WHPA: A Modular Semianalytical Model for
Delineation of Wellhead Protection Areas. Prepared by HydroGeoLogic, Inc., U. S.
EPA Office of Groundwater Protection.
Bonn, B., Rounds, S. 1990. DREAM - Analytical Groundwater Flow Programs. Lewis
Publishers, Inc.,: Chelsea, MA.
Cardwell, H., Huff, D., Douthitt, J.W., Sale, M. A Case Study of Optimization in the
Decision Process: Siting Ground Water Monitoring Wells. Oak Ridge National
Laboratoiy, Oak Ridge, TN: In Press.
CH2M Hill. 1992. Results of the Site Investigation, Phase II at the Paducah Gaseous
Diffusion Plant. CH2M Hill Southeast, Inc., Oak Ridge, TN: Ky/Sub/13b-9777c
P-03/1991/1.
Clausen, J.L, Zutman, J., Farrow, N. 1993. Characterization of the Northwest Plume
Utilizing a Driven Discrete-Depth Sampling System. Martin Marietta Energy Systems,
Inc., Paducah Gaseous Diffusion Plant: KY/ER-22.
Clausen, J. L., Douthitt, J. W., Davis, K. R., Phillips, B. E. 1992. Report of the Paducah
Gaseous Diffusion Plant Groundwater Investigation Phase III. Martin Marietta Energy
Systems, Inc., Paducah Gasesous Diffusion Plant: KY/E-150.
GeoTrans, Inc. 1992. Groundwater Monitoring and Off-Site Containment Evaluation at
the Paducah Gaseous Diffusion Plant. GeoTrans, Inc., Sterling, VA: GeoTrans Project
No. 6506-003.
GeoTrans, Inc. 1993. Assessment of Containment Alternatives of the Northwest Plume,
Paducah Gaseous Diffusion Plant. Sterling, VA: GeoTrans Project No. 6506-004.
Keely, J. F. 1989. Performance Evaluations of Pump and Treat Remediations. U. S.
EPA Office of Research and Development: EPA/540/4-89/005.
McDonald, M.G., Harbaugh, A.W. 1988. A Modular Three-Dimensional Finite-
Difference Ground-Water Flow Model. U. S. Geological Survey, Reston, VA: Open File
Report 83-875.

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Pollock, D.W. 1989. Documentation of Computer Programs to Compute and Display
Pathlines Using Results From the U. S. Geological Survey Modular Three-Dimensional
Finite-Difference Ground-Water Flow Model. U. S. Geological Survey, Reston, VA:
Open File Report 89-381.
Schrage, L., 1989. LINDO: Users Manual, Fourth Edition. The Scientified Press,
Redwood City, CA.
Science Applications International Corporation, 1993a. Proposed Plan for Hydraulic
Containment as an Interim Remedial Action at the Northwest Plume, Paducah Gaseous
Diffusion Plant, Paducah, Kentucky. Science Applications International Corporation.
Kevil, KY: DOE/OR/06-1127.
Science Applications International Corporation, 1993b. Record of Decision for Interim
Remedial Action of the Northwest Plume at the Paducah Gaseous Diffusion Plant,
Paducah, Kentucky. Science Applications International Corporation. Kevil, KY:
DOE/OR/06-1143&D4.
Science Applications International Corporation. 1993c. Groundwater Surveillance Plan,
Paducah Gaseous Diffusion Plant, Martin Marietta Energy Systems, Inc., Paducah
Gaseous Diffusion Plant: KYER-38.
Shafer, J. M. 1990. GWPATH - Ground-water Pathline and Traveltime Analysis,
Version 4, Champaign, IL.
Springer, A.E., Bair, E.S. 1992. Comparison of Methods Used to Delineate Capture
Zones of Wells: 2. Stratified-Drift Buried-Valley Aquifer. Ground Water: Vol. 30,
No. 6., pp. 908-917.

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Figure 2.

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ORNL-DWG 92M-12210R

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North
South
TVA
Steam Plant
DOE
Boundary
C-616
Lagoon
PGDP
Fence Line
SWMU's
7 and 30
CLAY
SAND AND CLAY
~~~l SAND
gravel
TRICHLOROETHENE
CONCENTRATIONS
<1.01o 100 ug/L
100 to 1000 ug/L
1000 to 2000 ug/L
2000 to 5000 ug/L
>5000 ug/L
Figure 5.

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^CONFINING V
-.LAYERS
AQUIFER

- '7
^\\\\\\\\\\^
v = 0.0006 ft/d
= 20 ft
\\\\\\\N

4-
4-
K = 500 ft/d
b = 30 ft
n = 25%
S = 0.008
/////////////////
IMPERMEABLE LAYER
7///////////////A
/
a)
¦> Q
AQUIFER
K = 500 ft/d
b = 30 ft
n = 25%
S = 0.008
i = 0.0006 ft/ft
i mpermeable'laye'r'
b)
Figure 7. Conceptual hydrogeologic models used for

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RESSQC
CAPZONEIGWPATH
MODFLOW/MODPATH
I I > 100 |ig/l TCE
IgiKi > 1000 jig/l TCE
Figure 8. Estimated one-year capture zones for the north

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Cardinal.

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Long Term Performance of a Groundwater Recovery System
Miles, Inc., Bushy Park, South Carolina
by Martin Healy1 and Dave Willis2
Abstract
Continuous groundwater recovery since 1986 at this facility has controlled
groundwater migration but has only improved groundwater quality in limited areas. Selected
groundwater analyses suggest that the source has been contained yet dissolved organic
compound concentrations remain elevated. Continued operation of this recovery system is
becoming maintenance intensive suggesting the existing recovery system may become
inoperable within a few years. Improved recovery well design could potentially extend the
life of the system but Miles may need to consider alternatives to groundwater recovery.
Introduction
Miles, Inc. operates a manufacturing facility in the Bushy Park Industrial Park, near
Charleston, South Carolina (Fig. 1).
The facility borders the marsh of
the tidally influenced Cooper River
and the topography is relatively flat.
The water table-is a few feet below
ground level in soft, unconsolidated
sands and clays. Groundwater in
the uppermost aquifer system
discharges to the nearby Cooper
River.
Miles closed a RCRA
regulated equalization pond at the
wastewater treatment plant of the
facility with a cap and slurry wall to
1.	Miles, Inc.
2.	Geraghty & Miller, Inc.

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encapsulate sludge in the pond. In
1985, Miles installed a groundwater
recovery system to control
degraded groundwater impacted by
the former pond (Fig. 2). The
groundwater recovery system has
been operated on a continual basis
since 1986 to control the migration
of degraded groundwater impacted
by sulfates, arsenic, and dissolved
organic compounds.
System Design, Operation, and
Maintenance
Recovery wells were located to create a continuous depression in the degraded
portion of the uppermost aquifer. Elevated dissolved sulfates accurately define the extent
of degraded groundwater (Fig. 3). Well placement was complicated by the heterogeneity
of the lower coastal sediments. Permeable sand units are limited in extent and are
surrounded by soft low permeability clays. The local geology was interpreted in detail to
minimize recovery wells screened in clay (Fig. 4). Eleven recovery wells were installed over
a distance of 1,200 feet to control
the degraded portion of the aquifer.
The pumping system is
similar to a dewatering system.
Groundwater is discharged through
1-inch diameter stand pipes into a
6-inch diameter header connected
to a large peristaltic pump. Stand
pipes are all at least 28 feet long to
prevent air discharge into the
recovery system. Water is
discharged to the Miles wastewater
treatment plant.
flow directions.
Settling Pond
\


Aontlon
Pond
ft.C.R.A.
C«p
do
A •ration
Pond
f"!
\
\
\
\ •
\
O :
\ _
\
\\\ > ,
Figure 3. Distribution of elevated sulfates in groundwater.

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The peristaltic pump creates
a vacuum (equal to 25 inches Hg in
the header) which induces a total
discharge of approximately 8,000
gallons per day from the recovery
wells. Discharge of individual wells
is dependent on the thickness of
screened permeable sand and varies
from less than 1 gpm to 2 gpm.
Recovery system performance is
monitored by recording total
discharge on a daily basis,
measuring the water levels in
recovery wells on a monthly basis,

Figure 4. Distribution of permeable sand in uppermost aquifer,
and mapping the groundwater depression on a quarterly basis.
Regular maintenance is required to remove iron precipitates which accumulate in the
recovery wells, standpipes, and header. Water levels rise in clogged recovery wells (Fig. 5).
Wells are redeveloped, and the header system flushed to remove the iron precipitates on
a periodic basis. Graphs of total discharge vs. time show that discharge decreases until
sludge is cleaned from the system. Although Miles redevelops the recovery wells in an
aggressive manner, the periods between required maintenance are decreasing and overall
discharge continues to decrease
(Fig.6). Iron precipitates may be
permanently accumulating in the
recovery well frlter packs. Further
iron removal may require new
wells.
CLOGGED WELL
System Effectiveness
The groundwater recovery
system effectiveness is measured in
two ways; 1) to control migration of
the degraded groundwater, and 2)
to improve groundwater quality.
tuj _
Figure 5. Elevated water levels in a clogged recovery well

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Potentiometric maps suggest the
recovery well system controls the
migration of degraded groundwater
downgradient of the former
equalization pond (Fig. 7). Water
levels are measured in monitor
wells and piezometers to verify that
a continuous depression is created
in the water table. Periods of
decreased system discharge allow
the water table depression to
become discontinuous.
GROUND-WATER WITHDRAWALS FROM THE
FORMER EQ POND RECOVERY SYSTEM
1987 1986 1989 1990 1991 1992 1993 1994
Figure 6. Recovery system discharge since 1987.
Groundwater quality has
improved near the former equalization pond. Elevated total chlorinated benzenes
concentrations in groundwater have decreased significantly in monitor wells immediately
downgradient of the former equalization pond (Fig.8). These analyses suggest the source
has been effectively encapsulated.
Quarterly groundwater analyses suggest the recovery system is improving overall
groundwater quality near the recovery well system except for selected organic compounds.
Although TOC and sulfate concentrations decrease in groundwater analyses, dissolved
chlorinated benzenes concentrations
do not decrease in groundwater
analyses from most wells. Total
chlorinated benzene concentrations
are increasing in analyses
downgradient of the recovery
system due to unknown causes
(Fig.9).
Discussion
Although elevated
concentrations of chlorinated
benzenes (at mg/L concentrations)
have decreased in groundwater
-'J.
t
¦-ff
Figure 7. Water table elevations near the recovery well system,
water levels measured 5/11/93.
4

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adjacent to the former equalization
pond, chlorinated benzene
concentrations (at Mg/L
concentrations) have not decreased
in groundwater at all points
influenced by the recovery system.
The recovery well system has only
removed significantly degraded
groundwater adjacent to the source.
The recovery well system has not
consistently lowered overall
chlorinated benzene concentrations
from the groundwater elsewhere.
TOTAL CHLORINATED BENZENES
Figure 8. Total chlorinated benzenes near the former source.
The value of this recovery system has been to remove the most significantly degraded
groundwater adjacent to the former source. The groundwater recovery system may not
remove the more widespread Mg/L concentrations of chlorinated benzenes in degraded
groundwater within the recovery system area of influence. Continued pumping of the
recovery system will limit the migration of the degraded groundwater, but the impact to
groundwater quality improvement is difficult to accurately define.
TOTAL CHLORINATED BENZENES
300-
250-
200
This groundwater recovery system is becoming maintenance intensive to operate.
Iron clogging may soon require
continual redevelopment and/or
repeated installation of added
recovery wells at prohibitive costs.
Groundwater recovery is presently
envisioned as a long term remedial
technique based on limited data.
Groundwater recovery of
recalcitrant contaminants may
actually only be useful as an initial
response to remove the mobile
portion of the dissolved
contaminants. Miles should not be
required to continue operation of
U
2
O
u
Jan 1
1988
Feb 28
1993
Figure 9. Total chlorinated benzenes downgradient of the
recovery system.

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this recovery system if groundwater recovery continues not to show improvement to
groundwater quality.
Recent research suggests that chlorinated organics are recalcitrant under aerobic
conditions but may degrade under anaerobic conditions. Increased flushing due to
groundwater recovery may impede the anaerobic processes, and slow down removal of the
remaining chlorinated benzenes. For recalcitrant contaminants, groundwater recovery may
be valuable only as the initial form of remedial activity. Continued clean up of the
degraded aquifer may require an as yet undeveloped technology.
6

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STORIES OF GROUNDWATER REMEDIATION IN LOW PERMEABILITY SOILS
Monsanto Chemical Company, Anniston Alabama
Leslie L. Herd, P.G., Geraghty & Miller, Inc., Tampa, Florida
Robert T. Jones, Monsanto Chemical Company, Anniston, Alabama
Peter L. Palmer, P.E., Geraghty & Miller, Inc., Tampa, Florida
The story line reads something like this: How do you design and install an effective
groundwater recovery system in a low permeability environment? Once the system is
installed, how do you evaluate the effectiveness of the system?
Hazardous wastes have been disposed in pre-RCRA regulated landfill cells and
production wastewater was stored in pre-RCRA regulated surface impoundments at the
Monsanto Facility in Anniston, Alabama. The landfill cells and the surface impoundments
were built on natural clays of 10'7 to 10"8 centimeters per second permeability which is
greater than 90 feet deep. Groundwater has been impacted in the upper sections of the
saturated portion of these sediments; however, the areal extent of groundwater impacts is
limited to the immediate vicinity of the source(s). The groundwater is currently being
recovered at the downgradient borders of each source area through a series of large-
diameter interceptor wells, adapted from water well drilling technology prevalent in the
area. The interceptor wells effectively operate as the "leachate collection" system for these
solid waste management units. The effectiveness of the system has been confirmed by two
independent assessment techniques. The traditional assessment technique of downgradient
groundwater monitoring has demonstrated that groundwater concentrations of constituents
in the downgradient observation wells have been decreasing over the last six years. A
second, simple yet often not used assessment technique of physical investigation of the
groundwater hydraulics indicate that water levels in piezometers located within the
corrective action systems demonstrate effective capture of the plume.
TF525\RCRAPRTN\PRTNABS	October 27, 1993

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STORIES OF GROUNDWATER REMEDIATION IN LOW PERMEABILITY SOILS
Monsanto Chemical Company, Anniston Alabama
The story line reads something like this: How do you design and install an effective
groundwater recovery system in a low permeability environment? Once the system is
installed, how do you evaluate the effectiveness of the system? The following stories
illustrate our solutions to these challenges.
THE PLANT STORY
The Monsanto Chemical Company's chemical manufacturing facility in Anniston
Alabama produces agricultural and industrial chemicals. Operations at the present plant
site began in 1917 with the formation of the Southern Manganese Corporation. The
company initially manufactured ferro-manganese, ferro-silicon, and ferro-phosphorus, and
later phosphoric acid. In 1927, the corporation entered the field of organic chemicals when
they first began producing biphenyl, which is today still one of their major product families.
In 1930, Southern Manganese Corporation became Swann Chemical Company and in 1935,
Swann Chemical was purchased by Monsanto Company.
The major product families that the plant has manufactured include: parathion,
paranitrophenol; phosphorus pentasulfide; and polyphenyls.
The Anniston plant is located in Calhoun County, in northeastern Alabama, near the
town of Anniston. The Plant is located approximately one mile west of downtown Anniston
along Highway 202. The plant site consists of four tracts of property, separated by highways,
railroads, and utility right-of-ways. In total, Monsanto owns 530 acres, of which
approximately 13 percent is being used for present operations.
TF525\RCRAPRTN\RCRAPRN.M0N	1	October 27, 1993

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Monsanto-Anniston operated two RCRA-permitted Waste Management Areas
(WMAs); closed landfill cells 4E and 5E (WMA-I); and a closed surface impoundment
(WMA-II) for the proper treatment, storage, and disposal of wastes generated during
chemical manufacturing. These units are closed and per post-closure requirements, are
being monitored through a series of groundwater monitoring wells.
Monsanto-Anniston also operated four identified pre-RCRA solid waste management
units (SWMUs); the Western Landfill, the Northern Landfill, the Plant Site Area, and the
Old Limestone Bed Surface Impoundment (OLBSI). Corrective action systems service each
of these SWMUs. Each corrective action system consists of a network of observation wells
(OW-series) and interceptor wells (IW-series). Currently, the observation wells are sampled
quarterly for the indicator parameters, parathion and paranitrophenol (PNP), and the
interceptor wells are sampled semi-annually.
THE GEOLOGY STORY
The plant is located near the eastern edge of the Alabama Valley and Ridge
physiographic province. The topography of the area is characterized by northeastward
trending valleys parallelled by ridges and mountains. The valley floors range from an
altitude of 500 to 900 feet mean sea level (msl) and the ridges range from 1,000 to 2,100
feet msl. Geologic formations in the region have been extensively folded into
northeastward-trending synclines and anticlines complicated by thrust faults that have a
general northeastward-trending strike and a southeastward dip.
The area is underlain by sedimentary and slightly metamorphosed sedimentary rocks
ranging in age from Cambrian to Ordovician. Fluvial deposits and residuum overlie these
rocks in some areas. The ridges are composed of sandstone units that are more resistant
to chemical and mechanical weathering. The valleys are composed of the less resistant
carbonate units that are more susceptible to weathering, especially in the humid climate of
TF525\RCRAPRTN\RCRAPRN.MON	2	October 27, 1993

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northeastern Alabama. The carbonate rocks in the area are deeply weathered and a mantle
of residuum (in situ decomposed rock) has developed on the outcrops (Scott, et al, 1987).
The significant geologic formations that crop out in the Anniston area are the
Cambrian Weisner Formation, the Shady Dolomite, the Rome Formation, and the
Conasauga Formation. In ascending order, brief descriptions of these formations are as
follows:
The Weisner Formation: consists of 2,500 feet of buff shale, siltstone,
sandstone, quartzite, and conglomerate.
The Shady Dolomite: consists of yellowish to light gray, crystalline, medium
to thick bedded dolomite interbedded with light to medium gray granular
limestone. The Shady Dolomite is marked by a residual clay as much as 100-
feet thick.
The Rome Formation: consists of red shale and siltstone, green shale, and
red and light gray sandstone, and a minor amount of lenticular limestone or
dolomite.
The Conasauga Formation: consists of dense to coarsely crystalline limestone,
dolomitic limestone, dolomite, and shale. A dark red residual soil reaching
thicknesses of 100-feet overlies this formation in outcrop areas.
The lower Cambrian Shady Dolomite and the overlying residuum lie beneath the
Monsanto Plant. Regionally, the Shady Dolomite consists of 500 to 1,000 feet of sandy
dolostone and dolomitic limestone (Scott, et al, 1987).
The Jacksonville Thrust Fault trends northeast, and runs through northwest Anniston
north of the plant site. The Jacksonville Fault thrusts Lower Cambrian sediments over
TF525\RCRAPRTN\RCRAPRN.MON	3	October 27, 1993

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Cambrian-Ordovician carbonates. The thrust fault and the formations in the Anniston area
dip steeply to the southeast.
Groundwater in the Cambrian sedimentary rocks of the area occurs in fractures,
sandstone units, and most abundantly in solution cavities of carbonate lithology. The most
significant aquifers in the area can be found in the Shady Dolomite and the Conasauga
Formation. High yields in the aquifer are dependant upon penetration of large fractures
and solution cavities.
In Calhoun County, the general movement of groundwater is to the south and west.
In the eastern part of the county, flow follows the trend of the topography. The
groundwater moves southward in Choccolocca Valley then westward around the south end
of Choccolocca and Coldwater Mountains.
THE LANDFILL STORY
The landfills, both the regulated and non-regulated landfill cells are located on the
northeastern slope of Coldwater Mountain. Solid wastes from production processes were
collected in dumpsters and taken to the landfill cells where the contents were disposed of
into a series of trenches, reportedly dug to a depth of five to ten feet.
The surface geology of the landfill site is composed of sandy or silty clays and clays
with permeabilities in the range of 10"7 and 10"9 centimeters per second. Borings from the
landfill area indicate that the surficial sediments extend from the land surface to greater
than 90 feet below the land surface. Below these surficial clays lies a fine-grained dolomitic
limestone of the Shady Dolomite Formation.
Hydrogeologic investigations at the landfill indicate groundwater flow, unaffected by
corrective action systems, in the upper saturated zone of the surficial sediments follows the
topography, generally to the north.
TF525\RCRAPRTN\RCRAPRN.MON	4	October 27, 1993

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Compliance monitoring wells were installed at the downgradient border of the
regulated landfill cell, WMA-I, and indicator parameters (parathion and paranitrophenol)
have not been detected in these wells.
Hydrogeologic investigations at the unregulated landfill cells, also known as the
Western Landfill and the Northern Landfill, indicated that groundwater in the saturated
surficial sediments had been impacted by the landfill at the downgradient borders. The area
of impact, however, was limited to the immediate downgradient areas.
A corrective action system would have to be designed that could recover impacted
groundwater from low permeability sediments. Treatment of the impacted groundwater
would be handled by the existing biological wastewater treatment plant onsite. The
technologies available for groundwater recovery in this type of environment typically include
the use of an interceptor trench. Several site conditions, however, made this technology less
desirable. The location of a trench along the relatively steep slope of the landfill cells and
adjacent to the highway presented some logistical considerations that impacted the projected
cost of the system. For instance, the depth of a trench (at least 65 feet deep) would
generate appreciable amounts of soil that would have to be handled. Several health and
safety considerations also affected the decision to pursue an alternative solution.
The alternative solution consisted of adapting water-well drilling technology prevalent
in these sediments in the area. A series of large-diameter interceptor wells along the
downgradient border of the landfill were designed to dewater the upper saturated sediments
down to a depth where constituents were not observed. The wells were advanced to a depth
where constituents were no longer observed in the soils and three-foot long sections of
concrete casing were installed. The annular space between the casing sections and the
borehole was filled with a fine-grained silica sand. A grout seal was installed at the top of
the well to prevent downward percolation of surface water.
TF525\RCRAPRTN\RCRAPRN.MON	5	October 27, 1993

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The low hydraulic gradient precludes continuous pumping of groundwater; therefore,
each interceptor well is equipped with a down the hole pump with automatic start/stop
switches. The switches are set to maintain the groundwater level in each well several feet
above the bottom of the well, thereby inducing groundwater flow into the well. Observation
wells were installed downgradient from the line of interceptor wells used to monitor the
effectiveness of the corrective action system.
Groundwater collected in the interceptor wells typically have high concentrations of
constituents. The landfill cells have been capped and the interceptor wells collect
groundwater that passes through or immediately beneath the landfill.
The groundwater monitored in the observation wells are typically orders of
magnitude less and is trending downward. The groundwater in these wells represent the
residual groundwater impacted and transported beyond the landfill boundaries prior to
installation of the corrective action system.
A second series of interceptor wells was installed on the plant site on the opposite
side of the highway at the toe of the plume. This is a smaller system, consisting of two
wells, located in a topographically low drainage area downgradient of the landfill cells. The
topography on the actual plant site is much flatter, however, the groundwater flow direction
still follows the topography. During the hydrogeological studies of the landfill, impacted
groundwater was detected in this area. The source of the impacted groundwater is believed
to be the landfill with preferential groundwater migration following the topographic drainage
pattern.
The groundwater recovered from this corrective action system, also known as the
Plant Site, is orders of magnitude less than the groundwater being recovered at the landfill
systems. In addition to the groundwater concentrations being orders of magnitude less, the
TFS25\RCRAPRTN\RCRAPRN.MON	6	October 27, 1993

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concentrations are trending downward which supports the belief that the interceptor wells
at the source are effectively capturing the impacted groundwater and that the Plant site
system is acting as a secondary corrective measure for plume maintenance.
SURFACE IMPOUNDMENT STORIES
Both the unregulated and regulated surface impoundments, the Old Limestone Bed
Surface Impoundment (OLBSI), and WMA-II received acidic wastewater from parathion
production. The OLBSI was an asphalt-lined surface impoundment that received wastewater
from approximately 1962 to 1980. WMA-II was a synthetic-lined impoundment that received
wastewater from 1979 to 1987. Both units are at the northern boundary of the plant facility
immediately adjacent to a major railroad corridor.
WMA-II STORY
WMA-II was closed according to the Closure Plan included in the RCRA permit.
Clean closure was not attempted; however, the contents of the impoundment and the liner
were removed and three feet of the clay base was excavated. The area was backfilled with
natural clay materials and a RCRA-approved cap was installed that consisted of a drainage
layer overlain by a geotextile fabric, and finally a topsoil layer seeded with three grass types.
The cap was designed to minimize leaching of residual source materials to the underlying
unconsolidated zone.
Two sets of compliance monitoring wells were installed downgradient of the closed
impoundment. WMA-II is located immediately adjacent to a railroad corridor, therefore,
the original set of compliance monitoring wells were installed on the other side of the
tracks. A second set of compliance monitoring wells were later installed closer to the closed
impoundment in the railroad right-of-way. Indicator parameters (parathion and PNP) have
not been detected in the original compliance monitoring wells. Parathion has been
TF525\RCRAPRTN\RCRAPRN.MON	October 27, 1993

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sporadically detected in one of the second set of compliance wells; however, the
concentration has been below the PQL.
OLBSI STORY
The OLBSI was taken out of service and the asphalt liner and liquids from the
impoundment were removed. Approximately four to five feet of the clay base beneath the
asphalt liner was also removed. Clean closure, while attempted, was not demonstrated and
the excavated impoundment was backfilled with a clay with permeabilities less than or equal
to the base subsoils. An asphalt cap was reinstalled over the backfilled clay to provide
additional protection from infiltration and to minimize the leaching of residual source
materials into the underlying unconsolidated zone.
The surface geology in the vicinity of the OLBSI is composed of sandy or silty clays
and clays with permeabilities in the range of 10'7 and 10"9 centimeters per second. Borings
indicate that the surficial sediments extend from the land sunace to greater than 80 feet
below the land surface. Below these surficial clays lies a fine-grained dolomitic limestone
of the Shady Dolomite Formation.
Hydrogeologic investigations at the OLBSI indicate groundwater flow, unaffected by
corrective action systems, in the upper saturated zone of the surficial sediments also follows
the topography, generally to the north; however, at a much slower rate than the groundwater
moving from the landfill area.
Like the landfill corrective action system, the OLBSI corrective action system would
have to be designed to recover impacted groundwater from low permeability sediments.
Treatment of the impacted groundwater would be handled by the existing biological
wastewater treatment plant onsite. Again, a series of large-diameter interceptor wells along
the downgradient border of the OLBSI was designed to dewater the upper saturated
sediments down to a level where constituents were not observed. The wells were advanced
TFS25\RCRAPRTN\RCRAPRNA.ON	8	October 27, 1993

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to a depth where constituents were no longer observed in the soils (approximately 45 feet
below land surface). The wells were constructed and equipped in the same manner as the
landfill interceptor wells. The observation wells were installed within feet of the interceptor
wells because of proximity of the railroad corridor.
Groundwater collected in the interceptor wells typically have high concentrations of
constituents. Although the OLBSI has been capped with an asphalt cover, the residual soils
beneath the unit are a continual source and the interceptor wells act as the leachate
collection system for the groundwater that passes through them from upgradient infiltration.
The groundwater collected in these observation wells were initially almost has high
as the interceptor wells; however, the trend has been markedly downward. The groundwater
in these wells represent the residual groundwater impacted and transported beyond the
original impoundment boundaries prior to installation of the corrective action system.
THE END OF THE STORY
Although all the corrective action systems appeared to be effective in the collection
of impacted groundwater and plume maintenance, an independent assessment of their
effectiveness was designed. The assessment was implemented at the OLBSI system which
focussed on groundwater levels in the vicinity of the corrective action system. In areas
where groundwater has been impacted beyond the limits of the units, the groundwater
concentrations of constituents have been trending downward in the observation wells,
indicating abatement activities upgradient. To substantiate this abatement, a series of
piezometers were installed between the interceptor wells to determine the radius of
influence induced by each interceptor well. Water levels were taken and indicated that the
wells were indeed creating an effective barrier for groundwater migration from the OLBSI.
TF525\RCRAPRTN\RCRAPRN.MON	9	October 27, 1993

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STORIES OF GROUNDWATER REMEDIATION
IN LOW PERMEABILITY SOILS
Monsanto Gk®mical Company
Annistom, Alabama
®nd
Geraghty a sad Miller, Inc.
Tampa9 Florida

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FACILITY HISTORY
Southern Manganese Corporation
1917 - 1980
Swax&i Chemical Company
1930 - 1985
Monsanto Company
1935 - Present

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LOCATION OF MONSANTO
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Generalized Stratigraphic Column
for the Anniston Alabama Area
COM&SAUGA FORMATION
dense to eoarsely crystalline limestome, dolomite limestone and shale
ROME FORMATION
red shale and ailtstone, green shale and red and light gray sandstone
SHADY DOLOMITE
yellowish to light gray orystalline, medinm-to thiok-bedded dolomite
interbedded with light to medium gray grannlar limestone
WEIBNER FORMATION
bnff shale, siltstone, sandstone, qnartzite and conglomerate

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SITE MAP
MONSANTO CHEMICAL COMPANY
Anniston, Alabama

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SCHEMATIC OROSS SECTIONAL VIEW
OF LANDFILL CORRECTIVE ACTION SYSTEM
LINE OP INTERCEPTOR WELLS
LANDFILLED
MATERIALS

/
SILTY SANDY /
CLAY	/
RESIDUUM ^ —
X
/
820
810
800
FT. AROVE
MEAN SEA
LEVEL
790
780
DENSE
CLAY
770
(il.R.Ui

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CORRECTIVE ACTION SYSTEMS
SITE MAP: Northern Landfill,
Western Landfill and Plant Site
A






t\
\M
/








N ^
1








\










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y

ii

-
J
\







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v
v]









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A®M®M SYSTEM SITE MAP:
Old Watone B0d Surface Impoundment
legend
o « PIEZOMETERS
A = INTERCEPTOR WELLS
9 - OBSERVATION tttLLS
•	= SHALLOW MONITORING WTlLS 	x-
•	= BEDROCK UONIIORING HELLS
; para thion isoconceniration contour
( >n microqfQins pe, j(,ef j
~x - FENCE
~ = Railroad

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parath.ok
Old L,n.4t„„ Bed 3„rt„„. Imp„ood„,„t .
scale, r » 60
t-ECENO
a = INTERCEPTOR WEU.S
® = OBSERVATION HEUS
® = SHALLOW MONITORING WELLS 	;
O = 8EOROCK MONITORING WLIS -y-
10- = PARATHiON ISOCONCEN TRAflON CONTOUR
( in micrograms per liter )
~x - FENCE
~ = Railroad

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TITLE: Remediation of Groundwater at Morton international, Inc.,
Moss Point, MS
-ABSTRACT-
Two (2) shallow aquifers at a large chemical manufacturing facility have been
impacted due to past waste management practices. Starting in 1986 the
sources were removed and two groundwater recovery systems installed to
prevent off-site migration of the contaminants. During the past six (6) years
concentrations of site specific constituents have been significantly reduced
in the affected aquifers, and very localized contamination continues to be

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SUMMARY OF PRESENTATION-
The presentation will identify past waste management practices that have
contaminated two (2) shallow aquifers. Corrective action to eliminate the
source(s) will be discussed, followed by a discussion of the geology of the
site, initial and on-going investigation and remedial action. A pictographic
presentation will illustrate the effectiveness of remediation. Some discussion
will focus on the frustrations encountered by the facility in trying to "find the

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PRESENTER
NAME: Joseph (Joe) J. Magazzu
TITLE: Environmental Engineer
Joe has been the Environmental Manager at the Morton International, Inc.,
facility in Moss Point, MS since 1979. He is responsible for all solid and
hazardous waste, air pollution abatement, NPDES and underground injection
activities at the site. He is a Certified Environmental Trainer (CET) and
Certified Hazardous Materials Manager (CHMM). Joe also serves on
environmental committees with the Chemical Manufacturers Association and
the Mississippi Manufacturers Association. Hobbies include gardening,

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Investigation and Remediation of the Wilson Corners Ground
Water Contamination on the Kennedy Space Center, F1
Abstract:
Contamination of the ground water at the Wilson corners site on the
Kennedy Space Center (KSC) was discovered in 1983 with the
discovery of Volatile Organic Compounds (VOC's). The largest
concentration of contamination was Trichlorethylene (TCE). A
typical solvent used as a degreasing fluid. The contamination is a
result of operations conducted at the site in support of manned
space activities. The selected treatment process is a pump and
treat air stripper. The presentation reviews the geology of the site

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REMEDIATION OF CONTAMINATED GROUND WATER AT
WILSON CORNERS ON THE KENNEDY SPACE CENTER, FL
PRESENTED AT THE EPA RCRA GROUND WATER
REMEDIATION CONFERENCE, DECEMBER 1-3,1993
JOHN RYAN
PROJECT MANAGER

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2
WILSON CORNERS GROUND WATER TREATMENT
This case study is presented to describe the actions that have been taken
by the Kennedy Space Center in the remediation of a ground water
contamination at the Wilson Corners site. The format follows the outline
presented by the EPA, in that it contains information on:
Facility operations, topography
Description of the contaminated unit
Hydrogeology
Extent of contamination
Remediation system
Problems with the system
Cost
It is hoped that this presentation can be of assistance to those
encountering this type of contamination.
1-FACILITY DESCRIPTION
Location
The Kennedy Space Center is located on the east-central coast of Florida
in Brevard County, approximately 150 miles south of Jacksonville and 40
miles east of Orlando, Florida (Figure 1). KSC covers 139,490 acres along
the north end of Merritt Island, adjacent to Cape Canaveral (geographic
coordinates, Longitude 80 42' West, Latitude 28 38' North) and is
approximately^ miles long and 5 to 7 miles'wide. KSC is bordered on the
west by the Indian River (a brackish-water lagoon), and on the east by the
Atlantic Ocean and Cape Canaveral Air Force Station (CCAFS). The
southern boundary runs east-west along the Merritt Island Barge Canal,
which connects the Indian River with the Banana River (another Brackish-
water lagoon). The northern boundary lies within Volusia County near the
city of Oak Hill. The Center contains the Merritt Island National Wildlife
Refuge (MINWR) and the majority of the Canaveral National Seashore (CNS)
within its boundaries. Titusville, Florida is immediately west of the
Indian River.
Launch Operations
KSC is the major NASA installation for launch operations and related
programs in support of manned and unmanned space missions. Present and
near-future mission plans call for the launching of manned vehicles into

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3
ejection of earth-orbiting communications and other scientific satellites,
conducting scientific experiments, and the ultimate transportation of
space station material and personnel. These objectives incorporate the
use of the manned Space Shuttle Vehicles.
Comprehensive technological programs are required for proper support of
these missions. Such programs have been developed and established at
KSC, including the following activities and capabilities:
*	assembly, integration, checkout, and preflight
preparation of space vehicles and their payloads;
*	design, development, validation, activation, operation,
and maintenance of Ground Support Equipment (GSE) and
supporting hardware;
*	tracking and data acquisition;
*	launch operations for reusable manned Space Shuttle
Vehicles;
*	recovery and refurbishment of the Space Shuttle Solid
Rocket Boosters (SRBs);
*	landing operations and refurbishment of the Space
Shuttle Orbiter, and
*	design, construction, operation and maintenance of
launch and industrial facilities.
Topography
Merritt Island is a relict barrier island reflecting the geomorphic
evolution of False Cape and Cape Canaveral. Merritt Island is separated
from the mainland by the Indian River estuary and from the current beach
ridge by the Banana River to the South and Mosquito Lagoon (denoted on
some maps as the Indian River Lagoon) to the north. Banana Creek extends
between the Indian River and Banana River in the vicinity of the Vehicle
Assembly Building and separates Merritt Island into distinct northern and
southern portions. The northern portion is actually connected to the
mainland by a narrow isthmus extending north to the Oak Hill area. In the
vicinity of Wilson Corners (the northern portion of Merritt Island) the

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dune ridges occupying the eastern side of the island east of SR 3. The
poorly defined ridge crests rise to elevations of 10 to 12 feet mean sea
elevation 5 feet MSL while the intervening swales are generally at
elevation 5 feet MSL. The dune ridges are bordered to the east by swamps
and salt marshes at the southern end of mosquito Lagoon. West of SR 3,
aflat scrub woods at elevation of 5 to 7 feet MSL slopes gently eastward
and northward to the marshes bordering the Indian River.
2-WILSON CORNERS SITE DESCRIPTION
Site Location
The Wilson Corners site is located on Merritt Island, Florida, within the
limits of NASA's Kennedy Space Center (KSC) on the east central Florida
coast east of the City of Titusville. The general location is shown on the
area maps on Figure 1. Specifically, the site lies on the north side of
State Route 402 (Beach Road) immediately west of the intersection with
State Road 3 (Kennedy Parkway). On the Florida coordinate grid, the
center of the site is at approximately 1,567,000 N and 596,000 E. Wilson
Corners is at the northernmost extent of KSC development and lies north
of the space shuttle landing strip. The specific location is shown on
(Figure 2). The site is in the midst of the Merritt Island Wildlife Refuge,
which is operated by the U.S. Fish and Wildlife Service within the KSC
boundaries. Except for a National Park Service storage yard 1,000 feet to
the north, there are no facilities or personnel stationed within 2 miles of
the site.
History
From the time of the early permanent settlements in the nineteenth
century, Merritt Island was a rural farming and citrus grove area with
scattered homesteads and settlements. Wilson Corners supported a
general store, which was constructed sometime prior to the early 1960's.
With creation of the space center, the Wilson Corners store was acquired
by NASA, and in 1963 it was remodeled into the office and laboratory
facilities for the Propellant Systems Components Laboratory. A tower
facility for the solvent cleaning of components such as rocket fuel lines
was constructed to the east of the main building; the tower was
reportedly roofed but otherwise open for ventilation of the solvents.
Numerous solvent storage tanks, mostly above ground, were located to the

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through drain fields to the east; north, and possibly west of the laboratory
building. During this period a grounds equipment maintenance facility was
also constructed to the west of the laboratory building. A potable well,
pump house and'tank were constructed at the far west side of the
approximately five-acre tract (Figure 3).
The Propellant Systems Components Laboratory operated from 1963 until
it was deactivated in 1974. The laboratory building and cleaning tower
were razed and the solvent storage tanks were removed leaving only the
pavements and concrete floor slabs. The site was abandoned for two
years, until 1976. At that time the National Park Service (NP5) placed
temporary, prefabricated office buildings on the concrete floor slab of
the old laboratory building. These structures were used by the NPS for the
management of the Canaveral National Seashore. More recently, the U. S.
Fish and Wildlife Service erected a small wood-frame office on one
corner of the large concrete slab that had been the grounds maintenance
facility.
Upon confirmation of ground water contamination at the site, NASA
ordered the site vacated. The National Park Service removed the
temporary buildings in late 1987; the Fish and Wildlife Service vacated
their office; and the site was again abandoned. With the initiation of
construction of the remediation system, the site has been fenced to
prevent inadvertent public access to this restricted area from SR 402.
3-5ITE CONDITIONS
Topography
The Wilson Corners site, which lies just west of SR 3, is in the flat scrub
woods. Construction and grading at the site have raised the elevation of
the old building slab areas in the central portion of the site to 8 feet MSL,
which is the approximate crown elevation of SR 402. Drainage swales on
either side of SR 402 are at invert elevations of 4 to 6 feet MSL and drain
to the west. A shallow "S" shaped borrow pit and mound are located in the
northeast portion of the site.
Geology
Merritt Island consists of relict shorelines and dune ridges reflecting the

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A general geologic section from east to west across the island is
presented on Figure 4. The soil materials exposed at the surface are
generally Recent,age marine and aeolian sands on the ridges and organic
silts and peat in the salt marshes. Extending to a depth of approximately
40 feet in the vicinity of Wilson Corners are marine sands, silty sands,
and concentrations of fragmented shells (shell hash) which comprise the
Pleistocene and Recent age Anastasia Formation. Within the Anastasia
Formation are discontinuous humic hardpan layers near the surface and
discontinuous lenses of coquina limestone (cemented shell hash) occurring
deeper in the formation. East of the site, near the current beach line,
sandy clay lenses are also present within the Anastasia Formation.
Underlying the Anastasia Formation and extending to depths of
approximately 120 feet are strata of the Caloosahatchee Marl Equivalent
of Upper Miocene and Pliocene age. This formation consists of clays,
calcareous silts, and silty sands with discontinuous sandy lenses. The
Caloosahatchee Marl Equivalent conformably contacts the underlying
Hawthorn Formation of Lower and Middle Miocene age. The Hawthorn
Formation consists of clays, calcareous silts, phosphatic clays, and
occasional sandy phosphatic limestone. The Hawthorn Formation
unconformably overlies the Ocala Limestone, one of several massive
carbonate strata of Eocene age that underlie most of Florida. Depth to
this limestone varies across Merritt Island from approximately 145 to
greater than 200 feet.
Ground water
Underlying Merritt Island are two major aquifers, the surficial aquifer
system and the Floridan aquifer system. A third minor group of
discontinuous, secondary aquifers are found in permeable zones of the
confining unit lying between the two major aquifers.
The surficial aquifer system, which is under phreatic conditions, is
composed of modern marine sands and the Anastasia Formation. The
hydraulic characteristics of the surficial aquifer system have been well
established by previous studies in the area (Brown, 1962; Timmons, 1982;
NASA, 1985). Hydraulic conductivity values vary from 1 to 25 feet per day
(ft/d), but a value of 15 ft/d has been established as appropriate for most
of the shallow sandy deposits. (Site-specific values are developed in
Section 5.1.2, Hydraulic Conductivity and Transmissivity.) Specific yield
estimates range from 15 to 30 percent, but a value of 20 percent has been
established as appropriate "for all long-term withdrawal from the

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barrier islands, the water quality in the surficial aquifer varies both
spatially and vertically. A freshwater lens has developed along the
central portion of-the island and displaces intruded sea water. The fresh
waters extend tor the base of the surficial aquifer system (at depths of
generally less than 50 feet) beneath the north-south trending upland axis.
The saline water/fresh water contact zones slope from the surface at the
salt marsh fringe to increasing depth toward the center of the island.
These features are shown on the geohydrologic cross section in Figure 4.
Local infiltration of precipitation is the only source of recharge to the
surficial aquifer system. Ground water movement is generally downward
under the uplands, then outward and upward to the east and west.
Discharge occurs as seepage to drainage canals and upward leakage
through the bottom of the surrounding estuarine lagoons. The depth to the
water table generally remains within 5 feet of the land surface, and the
hydraulic gradients are very sight, generally in the magnitude of 10-4 foot
vertical per foot horizontal (ft/ft). Ground water flow at the water table
generally emanates from the center of the island to the east and west
shorelines but is locally influenced by canals and waterways. Ground
water flow at the site is to the west-southwest (Figure 5).
The massive limestones of the Ocala Limestone and other underlying
carbonate formations comprise the Floridan aquifer system. The Floridan
aquifer system beneath Merritt Island is under flowing artesian conditions
(upward flow potential) with the potentiometric surface at approximately
+ 10 feet MSL. The overlying confining unit consists of the Hawthorn
Formation and the Caloosahatchee Marl Equivalent. The transmissivity of
the Floridan aquifer system is approximately 1,000,000 gallons per day
per foot (gpd/T.t); specific capacities range from less than 1 to more than
143 gallons per minute per foot of drawdown. Use of the Floridan aquifer
system is limited as the water quality is brackish, the result of sea'water
intrusion and limited local freshwater recharge. Recharge of the artesian
Floridan aquifer system beneath Merritt Island is primarily from
infiltration of precipitation in higher elevations some 50 miles to the
west; however, recharge may occur locally by downward leakage through
the confining layers wherever the surficial aquifer system water table
stands at a higher elevation than the potentiometric head of the Floridan
aquifer system. Discharge primarily occurs through limestone caverns in
the Atlantic Ocean offshore of the Daytona Beach area; however, some is
withdrawn for use in irrigation and crop freeze protection. Discharge also
occurs as upward leakage through the Hawthorn and Caloosahatchee Marl
Equivalent formations wherever the artesian head of the Floridan aquifer

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Secondary confined aquifers comprising the intermediate aquifer system
occur as discontinuous lenses of sand and limestone in the principal
confining units. Some may yield large quantities of water for short
periods of time. 'This receives recharge as leakage from the underlying
Florida aquifer system; therefore, the water quality is similar to that of
the Floridan aquifer system.
4-RESULTS OF INVESTIGATION
Llthologv of the Surflclal Aquifer System
The surficial aquifer system in the vicinity of the site, which includes
both Recent age deposits and the Anastasia Formation, consists of four
general lithologic divisions. This lithology is shown on Figure 6. From the
ground surface at an elevation of generally 5 feet MSI down to an
elevation of approximately 0 feet MSL, the materials consist of gray fine
sand (Unified Classification SP). Improved building pads and parking lots
at the site above elevation 5 feet MSL are fill of this same sand material
derived from the shallow "S" borrow pit in the northeast corner of the
site.
Underlying the surface sands is a zone of only moderately permeable
materials. The top of this zone (generally from elevation 0 feet MSL to -3
feet MSL) is a layer of dark-brown, organic-stained sand which is
partially 1 ithifled into a humic "hardpan." The "hardpan" is sporadic in
distribution and creates a discontinuous aquitard over portions of the site.
The aquitard-slows, but does not significantly inhibit surface infiltration.
Below the organic-stained sand is an approximately 3-foot thick stratum
of brown silty fine sand. In the eastern half of the site, this stratum is
underlain by 3 to 5 feet of gray-green silty fine sand (both of Unified
Classification SM materials).
Underlying the aquitard materials is a massive stratum characterized by
concentrations of coarse shell fragments (shell hash) and sand. The lower
10 feet of the shell hash stratum contains silt, which is absent in the
upper portion, to silty gravel (fragmented limestone) GM material in the
lower portion. The permeability likewise decreases in the lower 10 feet
as the amount of silt increases. The top of the shell hash stratum slopes
gently to the east from approximately elevation -6 feet MSL at the
western edge of the site to approximately elevation -14 feet MSL at the
eastern from elevation -36 feet MSL at the western edge of the site to

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The lowest stratum comprising of the surficial aquifer system consists of
green very silty,fine sand (Unified Classification SM material). The base
of this stratum varies across the site from approximately elevation -45
feet MSL to greater than elevation -50 feet MSL, with the greater depth
occurring in the vicinity of wells National Park Service Headquarters
(NPSH)-12R and NPSH-01. This stratum directly overlies the silts, clays,
and clayey-silty sands (Unified Classification ML, CL, CH, and SC
materials) of the Caloosahatchee Marl Equivalent (Upper Confining Unit).
Hydraulic Conductivity and Transmlsslvltv
Table 1 presents a summary of the hydraulic conductivity values
calculated from the on-site and nearby slug test data. The values reported
in the KSC Ground Water Survey are slightly higher than the values re-
evaluated for this site using the Hvorslev method, but the two sets of
values are the same general magnitude. Weighting the data for the
massive shell hash stratum and comparing the original and re-evaluated
calculations, a hydraulic conductivity of 13 to 15 ft/d (97 to 1 12 gallons
per day) is appropriate for the surficial aquifer system beneath the site.
With a saturated thickness of 35 to 40 feet (to the base of the shell hash
stratum), so the average transmissivity of the surficial aquifer system is,
approximately 3,400 to 4,500 gpd/ft. A transmissivity value of 4,000
gpd/ft is used for analysis of drawdown, mounding, and affected well
radii in the designed remedial system.
Hydraulic Gradient and ground Water Migration
As with most coastal areas of low topographic relief, the ground water
contour at the site is generally flat. Monitoring of the ground water table
elevations in the various monitoring wells revealed minor local variations
with a gentle gradient generally to the west-southwest. As shown on
Figure 5, the ground water elevation in the northeast portion of the site is
approximately 2.6 feet MSL and grades over a distance of 1200 feet to
approximately elevation 2.2 feet MSL in the southwest portion. This
translates to a hydraulic gradient of 3 x 10-4 ft/ft.
Porosity of the surficial aquifer system materials generally ranges from
15 to 30 percent with a mean of approximately 20 percent (NASA, 1987,
Vol. III). The ground water migration rate was calculated by Darcy's Law
corrected for porosity:

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TABLE I
HYDRAULIC CONDUCTIVITY DATA
TESTS CONDUCTED IN SHALLOW FINE-MED SANDS
o Reported in NASA KSC Groundwater Survey 11 ft/day
o Original data re-evaluated by Hvorslev Method
Tests conducted on-site:
Tests off-site in vicinity:
0.4	ft/day
17	ft/day
0.6	ft/day
6.5	ft/day
Mean of re-evaluated data =
6.1 ft/day
TESTS CONDUCTED IN SHELL HASH/COQUINA ZONE
o Reported in NASA KSC Groundwater Survey
16
21
ft/day
ft/day
Original data re-evaluated by Hvorslev Method
Tests conducted on-site:	13 ft/day
Tests off-site in vicinity:
0.3 ft/day
14 ft/day
14 ft/day
Mean of re-evaluated data =
Mode of re-evaluated data =
10.3 ft/day
14 ft/day
TESTS CONDUCTED IN COHESIVE UPPER CONFINING UNIT
o Reported in NASA KSC Groundwater Survey 0.3 ft/day
o Original data re-evaluated by Hvorslev Method

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where "K" is hydraulic conductivity of 15 ft/d, "h" represents a hydraulic
gradient of 3 x 10-4 ft/ft, and "N" represents porosity of 0.20. The
calculated ground water migration rate "V" is, therefore, approximately
0.20 ft/d or approximately 7 feet per year.
Nature of the Contaminants
As suspected from the nature of past activities at the site, the primary
contaminant in the ground water is trichloroethylene. This volatile
organic solvent is more dense than water and can migrate downward
through a fresh water aquifer in its non-aqueous phase. With the very low
hydraulic gradient and ground water flow velocity at the site, this
downward migration due to density appears to have been the predominant
mechanism of movement for the contaminants over the nearly three
decades since the first contamination events occurred. Consequently, the
entire thickness of the Surficial Aquifer System beneath the site has
become contaminated. The vertical and areal extent of the contamination
is further discussed in subsequent sections.
In addition to trichloroethylene, the compounds to which trichloroethylene
degrades, such as vinyl chloride, cis and trans-1,2-dichloroethylene, 1,1-
dichloroethylene, and 1,1 -dichloroethane, are present at the site.
Distribution of Contaminants
The investigative work performed at the site over the past seven and one-
half years has identified and defined the extent of volatile organic
contamination of the ground waters within the surficial aquifer system
beneath the Wilson Corners site. These investigations have also revealed
that contamination is confined to the surficial aquifer system and does
not extend into the underlying confining units.
From the surface and near-surface discharge points across the site, the
heavier-than-water contaminants have migrated downward to the base of
the surficial aquifer system and spread laterally to a limited extent in the
more transmissive shell hash zone. Migration of the contaminants in the
downgradient direction to the west-southwest has been very limited, as
expected with a flow velocity of less than 10 feet per year. The mean
total VOC concentrations, regardless of the depth of sampling, are shown
Figure 7. Concentration contours of 10,000 parts per billion (ppb) encircle
the central portion of the site, and concentrations diminish rapidly as you

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provide clear definition of the areal limits of contamination. The contour
line representing less than 10 ppb total VOC lies within the pattern of
existing wells, with particularly good control in the up- and downgradient
directions.
Well, NPSH-12R is located in an area of high contaminant concentrations
in the Surficial Aquifer system, but it is completed in the top of the
underlying intermediate confining unit. Ground water samples from NP5H-
12R confirm that downward migration of the contaminants has been
effectively blocked by the confining unit. Based upon test data from the
wells, Figure 8 presents an east-west vertical profile of the contaminant
plume.
Soil and Surface Water Contamination
Analysis of shallow soil samples revealed that the soils adjacent to the
abandoned cleaning tower site contained up to four parts per million (ppm)
of trichloroethylene and breakdown products. Outside this area no EPA
Method 601 or 602 parameters were detected in significant
concentrations. During the rainy season some VOCs have been detected in
surface waters which intercept the contamination plume area.
Impacts of Contamination
The site is currently unoccupied, and the former potable supply well ha§
been pulled and abandoned as part of the remedial construction efforts.
The only potable surficial aquifer system wells in the area are located
approximately 1 1,000 feet down gradient at the Fish and Wildlife Service
facility on SR 402 (see Figure 9). With a migration rate of less than 10
feet per year, the referenced contamination poses no real threat to
existing water supplies.
Contaminant Source Identification
Review of the site history and of the contaminant distribution suggests
several sources of the contamination. The cleaning tower location at the
eastern edge of the site was most probably a source of trichloroethylene
contamination. Drain fields from the laboratory complex, which were
located generally north and east of the laboratory building, apparently
received spent solvent wastes and distributed these to the subsurface. A
surface discharge line may have extended to the west of the laboratory
building. Above ground and underground storage tanks for new and spent

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leaked solvents to the ground. Several concentrated contaminant areas
have been detected on the site which have not been correlated to any
particular historical activity. These areas may represent discrete
dumping or discharge events. The identifiable contaminant source areas
are shown on Figure 10.
With abandonment of the components cleaning laboratory in 1974, the
source of contamination was eliminated. Site investigations have
confirmed that no above or under ground tanks or structures now exist
which could act as a continuing contaminant source. Therefore, the source
of contamination existed at the site from 1963 to 1974; and no
contamination is known or suspected to have occurred after 1974.
5-SPECIFIC SYSTEM DESIGN
Equipment Layout
The ten selected extraction wells are distributed over an area
approximately 750 east to west by 500 feet north to south. The large,
100-foot-by-100-foot concrete slab of the abandoned grounds
maintenance facility is located within the area of the wells and was
selected as the location for the treatment equipment. From the treatment
equipment area, electric power lines extend to each pump, and well water
transmission hoses extend from the pumps back to the equipment area.
Except for a bore-and-jack penetration under SR 402, the electric lines
and hoses are laid above ground in sectioned protective concrete troughs.
The well pumping system is, therefore, relocatable and salvageable. The
well pumping system layout is shown on Figure 11.
The treatment equipment area, shown on Figure 12, contains eight major
elements of the system: (1) well water manifold, (2) raw ground water
equalization tank, (3) stripping tower influent pump P-11, (4) air-
stripping tower, (5) irrigation surge tank (not used), (6) treatment system
effluent irrigation pump P-12, (7) irrigation circuit manifold, and (8)
motor control panel. These are described in detail in the following
sections.
The effluent spray irrigation area is divided into six separate circuits.

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All pumps are centrifugal with stainless steel and inert internal parts
rated acceptable for use with volatile organic compounds in
concentrations of up to 5 percent by volume. All pumps are mounted on
aluminum base pallets and are protected by a louvered aluminum box
cover. Well pumps (P-1 through P-10) are 1/2 horsepower with a 3 to 20
gpm flow range at a maximum differential pressure of 25 pounds per
square inch gauge (psig). The actual head on the well pumps is
approximately 5 feet suction and 8 feet discharge (lift plus friction loss).
The air-stripping tower influent pump (P-1 1) is 1-1/2 horsepower with a
20 to 75 gpm flow range at a maximum discharge pressure of 25 psig. The
actual head on P-1 1 is a positive 2 to 6 feet inlet and 26 feet discharge.
The irrigation pump (P-12) is 2 horsepower with at 20 to 75 gpm flow
range at a maximum discharge pressure of 65 psig. A typical detail for
the pumps is shown on Figure 13.
Water Transmission Hoses
The hoses have an inert inner liner resistant to high concentrations of
pure contaminants. The hoses are reinforced with two ply textile braid
and a helical wire stlffener. The outer coating is weatherproof and
resistant to prolonged exposure to direct sunlight. Well suction hoses are
1-3/8 inch ID; transmission hoses are 2-inch ID to virtually eliminate
friction losses. All hose connections are brass, cam-lock, quick-connect
fittings, and hoses are equipped with fittings every 100 feet of run length
for ease of breakdown and relocation. Well suction hoses are inserted to
the approximate top-of-screen depth.
Well Water/Meterlng/ThrottHnq/Samplinq Manifolds
The well water manifold, shown on Figure 14, allows for the independent
metering, sampling, and throttling of each well's production. Meters are
accurate over a flow range of 2 to 50 gpm with dial registration of 0.1
gallons, Throttling valves are globe valves while sampling ports are ball
valves. To prevent variable back pressure at the very low anticipated
flow rates, each well independently free-drops into the equalization tank
Equalization Tank
The above ground square equalization tank is approximately 12 feet by 12
feet by 6 feet high and is constructed of 1/4-inch aluminum plate with
internal stiffeners. The tank is covered to exclude rainwater except for
an opening along one side to allow free-fall inflow from the well water

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tank has an effective capacity of 5000 gallons, or about 1-1/2 hours of
operational storage.
Air-stripping Tower
The air-stripping tower is 2 feet in diameter, 26 feet in height and is
constructed of stainless steel for resistance to the organic solvents. The
tower is packed with 19 vertical feet of 3-1/2 inch polypropylene
"Lanpac" baffles and receives over 730 cubic feet per minute of fresh air
from the blower. The top of the tower is equipped with a demister. The
tower influent Mne is equipped with a meter accurate in the 10 to 100
gpm range and throttling and sampling valves.
The tower was designed for the maximum single occurrence of each VOC
plus a safety factor of at least 1.5. With this very conservative approach,
the actual safety margin is likely in excess of 3.
irrigation Meter Assembly and Manifold
The meter and valve assembly provides for metering, throttling, and
sampling of the treated effluent. The meter is accurate in the 10 to 100
gpm range. Throttling is controlled by a globe valve; the sampling valve is
a ball valve or hose bibb. Water is distributed to the various irrigation
circuits through a manifold shown on Figure 12.
Irrigation System
The irrigati-on circuits are plumbed with polyethylene pipe laid
underground or in the protective concrete troughs. To facilitate mowing,
pop-up sprinkler heads are utilized. The heads provide either adjustable
arc rotation or adjustable arc spray to completely cover the application
area.
Controllers
As shown on the process schematic (Figure 13), two sets of level
controllers prevent overflows or dry suction to the pumps. In the
equalization tank, a high level controller shuts off the well pumps (P-1
through P-10) to prevent tank overflow. A low level controller shuts off
pump P-1 1 before it would be devoid of intake water. In the sight glass of
the air-stripping tower, a high level controller will shut off pump PH 1 to
prevent the backup of water into the blower. A low level controller will

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Since the primary element of the treatment system is forced air in the
stripping tower, loss of differential pressure at the blower, which
indicates blower malfunction, will shut down the entire system so that no
untreated water can be delivered to the spray irrigation area.
Motor Control Center
The motor control center, provides individual motor control for the blower
and all pumps, and it provides a fully automatic system which relies on
the level controllers to balance the flows through the system.
6-Cost
The construction cost for the remedial system was $296,639. The annual
operating and maintenance cost is approximately $152,400. Maintenance
of the system is performed by the Base Operating Contractor under the
guidance of the NASA Environment Management Office. This maintenance
includes daily inspection of the facility, by a waste water mechanic. In
addition there is electrical support, grounds keeping, parts replacement
and preparation of reports for the regulatory agencies.
7-Qperatlonal Problems and Revisions
There have been few operational problems or requirements to revise the
remediation system, this is due to the presence of the waste water
mechanic that tends to the system on a daily bases. Those revisions that
have been made consist of the following:
1 -the irrigation surge tank: was intended to be used to
ensure adequate flow to the spray areas. Once the system was
started up and fine tuned, this tank was taken out of
service. The current flow rate from the tower is high enough
to maintain the system.
2-biological growth in the tower and the surge tank. Shortly after
start up of the system, the efficiency of the tower dropped,
due to biological growth. Due to the warm climate
biological grow was a problem both in the tower sight glass
and in the surge tank. This has been controlled by periodically
routing the effluent from the tower back to the surge tank and
treating the tank with hypochlorite. The water is then

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biological growth in the system. In addition, the sight glass is
now covered with plastic to preclude sunlight from
encouraging algal growth.
3-the major revision made to this system is the increase in the
number of spray effluentzones used to distribute the system
effluent. During the wet season, the treated water ponded in
the four original areas and it became apparent that the
effluent needed to be better distributed to the northern portion
of the site, as well, to alleviate the ponding in the southern
areas of the site. Two more zones were added and the ponding
has been controlled by the rotation of the system effluent
through the six effluent zones.
8-Chanaes In Plume Size and Concentration
SIZE AND CONCENTRATION
Phase One of this pump and treat system, a low volume extraction, is
being carried out using five wells with a total pumping rate of twenty two
gallons per minute. The purpose of this low volume extraction was to
remove and treat the more highly contaminated ground waters without
significant mixing. Figures 16 and 17 show cross sectional and plan
views of the original extent and the levels of the contamination in 1988.
Phase two of the remedial plan is to increase the number of pumping wells
to ten and the total pumping rate to forty gallons of water per minute.
This pumping-rate increase will help remediate the entire affected volume
of ground water. The affected volume is estimated to be roughly 25
million gallons based on a 5 to 7 acre contaminated area, a 35 to 40 "foot
saturated thickness, and a 25 to 30 percent porosity. To date the project
has not be carried to the second phase.
As of October 1, 1993, the system has pumped and treated 37 million
gallons of ground water. This action has removed approximately 4400
pounds or 435 gallons of mixed VOC contamiants.
The Figures 18 and 19 indicate the reduction of the plume both in the plan
and cross section views since the inception of the remediation. As these
figures show the plune has been contained and reduced both directions.
The pump and strip treatment has been and should continue to be

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REFERENCES
NASA, Wilson Corners Groundwater Remediation, Contamination
Assessment Report, 1989
Acknowledgments
Mr. Burton Summerfield, NASA Pollution Control Officer for the graphics.
Mr. Greg Rexroad and Ms. Susan Rogers, EG&G Environmental Engineers for
review and comments.

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NASA Biography
National Aeronautics and
Space Administration
John F. Kennedy Space Center
Kennedy Space Center, Florida 32899
AC 407-867-4049
JOHN RYAN
Environmental Analyst
Environmental Management Office
John Ryan has been with the Kennedy Space Center, NASA Environmental Management
Office, as an Environmental Analyst, since January 8,1984. He is responsible for management of
cleanup activities concerning past disposal of hazardous materials at the Center. He is currently the
Program Manager for nineteen RCRA Facility Investigations and the Project Manager for 161
preliminary site investigations.
Prior to joining NASA, he has had a diverse career with various agencies, including the
Department of Agriculture involving the development of biological controls for crop pests; the
Corps of Engineers, U.S. Fish and Wildlife Service, and U.S. Coast Guard concerning
environmental permitting of activities in wetlands; the Department of the Army managing a Military
installation environmental and waste management programs; and disposal of hazardous waste in
the western fourteen states for the Department of Defense.
He has received several Group Achievement and Performance Management System
Awards while at Kennedy Space Center, including the NASA Certificate of Commendation in
1991.
Born January 29,1949, in New York City, Ryan received a bachelor of science degree in
biology from Florida Southern College in 1972. He then attended various schools where he
continued with graduate studies in marine biology and environmental science. He is a member of
the National Ground Water Association.

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Case Study:
Groundwater Remediation System
Occidental Chemical Corporation
Mobile, Alabama
ABSTRACT
Occidental Chemical Corporation (OxyChem) owns and operates a chlor-alkali plant in
Mobile, Alabama. The chlorine manufacturing process, initiated by the previous owner in
1964, involved (until 1990) electrolysis in a mercury cell. From 1974 through 1985, the
Former Brine Sludge Lagoon was used to settle impurities, including mercury, from brine
used in the process. The settled impurities formed a mercury-containing sludge (K071
waste). The former lagoon, regulated under RCRA, was issued Post-Closure Permits in
1989. Groundwater samples from monitor wells around the unit in 1985-1986 indicated the
presence of elevated levels of mercury (as high as 2.2 mg/L) and chlorides (as high as
51,000 mg/L) in the Upper Zone (the first water-bearing unit, extending from the ground
surface to depths of 0 to 27 ft). Wastes were removed from the lagoon in 1986, and in early
1989, the lagoon was capped and a groundwater corrective action system was installed. The
corrective action included the installation of gravel-filled interception trenches with
groundwater recovery from a sump at the intersection of the trenches. Construction
difficulties included space constraints imposed by an adjacent railroad and nearby utility
poles; maintaining an open excavation prior to backfill in a narrow (2-foot wide) trench to
depths of 22-26 feet; and establishing free flow in the trench after completion. Initial
operational difficulties involved apparent pump clogging. After four years of operation, over
9.5 million gallons of water have been recovered from the system, the area covered by the
associated dissolved mercury plume has decreased from approximately 1 acre to 0.73 acre,
and maximum concentrations of total mercury and chlorides in groundwater at wells

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Case Study:
Groundwater Remediation System
Occidental Chemical Corporation
Mobile, Alabama
Linda M. McConnell, PE
G&E Engineering, Inc.
Baton Rouge, LA
Richard B. Adams, PE, DEE, CGWP
G&E Engineering, Inc.
Baton Rouge, LA
Ed Seitz
Occidental Chemical Corporation

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OUTLINE
INTRODUCTION
BACKGROUND
o Facility Description, Location, Surrounding Land Use, and Topography
o Hazardous Waste Management Unit
o Hydrogeology Beneath the Facility
o Groundwater Contamination Prior to Initiation of Remediation Program
GROUNDWATER REMEDIATION SYSTEM
o Description, Design Criteria, Parameters
o Operational Problems, Difficulties Encountered, Changes/Revisions
o Results to Date
PROGRESS IN GROUNDWATER REMEDIATION
COSTS
o Construction Costs
o Operation and Maintenance Costs
TABLES
Mercury Concentrations in Groundwater, 1985-1993
Chloride Concentrations in Groundwater, 1985-1993
FIGURES
Vicinity Map
Site Plan/Well Locations
Soil Profile Plan
Soil Profile Cross Sections
Upper Zone Potentiometric Contours, May 1993
Lower Zone Potentiometric Contours, May 1993
Upper Zone Mercury Isopleths, October 1988
Upper Zone Chloride Isopleths, October 1988
Groundwater Recovery System - Site Layout
Groundwater Recovery System - Trench, Sump, & Piezometer Details
Upper Zone Mercury Isopleths, May 1993
Upper Zone Chloride Isopleths, May 1993
Dissolved Mercury Concentrations vs Time Graph
Total Chloride Concentrations vs Time Graph
1
2
1
2
3
4
5
6
7
8
9
10
11
12
13

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Case Study:
Groundwater Remediation System
Occidental Chemical Corporation
Mobile, Alabama
INTRODUCTION
Occidental Chemical Corporation (OxyChem) owns and operates a chlor-alkali plant in
Mobile, Alabama, which manufactures chlorine, potassium hydroxide, and sodium silicate.
The sodium silicate facility is not related to the subject matter of this paper and will not be
discussed further. Elevated concentrations of mercury detected in the first water-bearing
aquifer in the vicinity of the site's former Brine Sludge Lagoon in 1985-86 led to a
groundwater assessment and groundwater corrective action program. This paper describes
the ongoing groundwater remediation program initiated at the facility - its background,
design, installation, operation, and effects.
BACKGROUND
Facility Description, Location, Surrounding Land Use, and Topography
Diamond Shamrock Chemical Company completed construction and initiated operations at
the Mobile chlor-alkali plant in July 1964. In 1986, OxyChem purchased the plant from
Diamond Shamrock- TTie plant originally produced chlorine and caustic soda (sodium
hydroxide) using the Denora mercury cell process, an inorganic chemical process which used
salt (NaCL) as a raw material and metallic mercury as a cathode in the electrolytic cells.
In 1990, the mercury cell process was discontinued, removed, and replaced, in 1991, with
(mercury free) membrane chlorine production technology.
The plant has used sodium chloride (rock salt) as a feed stock from 1964 to 1985 and 1991
to 1993. Historically, NaCl salt (rock salt) was stored in open piles on an asphalted and
curbed area and was subject to weathering loss. The rock salt was transported by barge to
the plant where it was stockpiled. The salt was dissolved to make brine. Under the old
process, filter backwash muds were pumped into the Brine Sludge Lagoon in order to settle
out impurities. The impurities formed a sludge (K071 waste) that was periodically removed
from the settling unit. Prior to 1980, the sludge was disposed onsite; since then, the sludge
has been disposed offsite at a permitted facility.
From 1985 until 1991, the chlorine process used KC1 as a raw material to produce potassium
hydroxide (caustic potash) as a co-product. KC1 was stored in closed rail cars and silos, and
KC1 waste solids were disposed offsite. Open salt storage was discontinued from 1985 until
March 1991 when the chlorine process resumed production of sodium hydroxide as a co-
product until 1993.
The plant site, which covers approximately 135 acres, is located in a heavily industrialized
area of the northeastern portion of the City of Mobile, near a tributary of the Mobile River.
The site is bounded on the north and east by miscellaneous industrial plants and swampy
areas draining to the river. To the west and south are mixed urban, commercial, and
residential areas. A vicinity map showing the plant location is shown in Figure 1.

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Figure 2 is a site plan showing significant facility features. The plant process area, covering
14 acres at the southern end of the property, contains manufacturing facilities. The property
includes an inactive, 46-acre shallow water body (former attenuation pond) to the north of
the property; an unimproved 18-acre recreational area on the western portion of the
property; a creek (Gales Branch) which traverses the property and separates the process
area from the former attenuation pond and the recreational area; and a 13-acre barge slip
extending to the east, which connects the property to Chickasaw Creek (a tributary of the
Mobile River).
The plant's location falls in the East Gulf Coastal Plain section of the Gulf Coast Plain
Province in the Southern Pine Hills physiographic division of Alabama. The site is
characterized by nearly level plains, located on an exposure of unconsolidated terrace and
alluvial deposits in the floodplain of the Mobile River.
The plant topography includes a naturally elevated field (approximately 30 ft MSL) to the
east of the process area, a fairly level process area (at 20 to 25 ft MSL), and slopes to Gales
Branch, the Barge Canal and the Attenuation Pond (all at 0 to 5 ft MSL).
Hazardous Waste Management Unit
From 1974 through 1985, the Former Brine Sludge Lagoon (see Figure 2) was used to settle
impurities from brine used in the chlorine manufacturing process. The settled impurities
formed a sludge (K071 waste). The sludge included trace amounts of mercury from the
mercury cell process and smaller quantities of other metals, primarily from impurities in the
salt. The former lagoon is regulated as a hazardous waste management unit under RCRA.
The lagoon was a 12-ft deep surface impoundment with a capacity of approximately one
million gallons. One wall of the unit was formed by natural high ground, while clay levees
were constructed on the remaining three sides to form the impoundment. The lagoon was
lined with a 20-mil unreinforced PVC liner.
In 1986, OxyChem closed the lagoon and removed (1) all brine sludge (K071) material, (2)
the synthetic liner installed during lagoon construction, and (3) impacted soil underlying the
synthetic liner. At the time, the lagoon was estimated to contain approximately 4,000 tons
of sludge. Due to mercury levels detected in the groundwater in the vicinity of the lagoon,
clean closure was not possible. As a result, a Part B post-closure permit application was
prepared and submitted to the Alabama Department of Environmental Management
(ADEM) and the U.S. Environmental Protection Agency (USEPA) in November 1986. A
plan for closure capping and groundwater remediation of the lagoon was submitted and
approved by the agencies in 1988. In early 1989, an approved clay cap was installed over
the impoundment, and a groundwater corrective action system was installed. Post-closure
permits were also issued by USEPA and ADEM in May 1989.
Hydrogeology Beneath the Facility
The plant is underlain by a series of clay and sand strata. Based on lithological information
from borings at the site, generalized soil profile cross sections were developed. Figure 3

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contains the soil profile plan, and Figures 4a and 4b present the corresponding cross
sections.
The first water-bearing unit, termed the Upper Zone, extends from the ground surface to
depths of 0 to 27 feet below ground surface, and consists of sand and silty sand with clay
and silt pockets, seams and layers and some natural organic matter. The Upper Zone has
extended areas of surficial clay or very shallow clayey sand underlain by clay, particularly
south of the Former Brine Sludge Lagoon and beneath the process area.
The Upper Zone is underlain by the Upper Confining Unit, consisting of clay, sandy clay,
silty clay, and peat. It ranges in thickness from 4 to 35 ft. Laboratory vertical conductivity
values for samples from the Upper Confining Unit clay range from 1.8 x 10"6 to 2.0 x 10"8
cm/sec.
The next more permeable zone, the Lower Zone, consists of sand and silty sand with gravel
and clay. The Lower Zone ranges in thickness from 32 to 82 feet and begins at depths of
16 to 45 ft below ground surface. The Lower Zone is underlain by the Lower Confining
Unit, 25 to 45 ft thick, composed of clay and silty clay with sand and silt layers. Subsequent
underlying layers of sand and clay have been defined to a depths of over 200 ft below
ground surface.
Figure 5 presents groundwater conditions in the Upper Zone (May 1993). The direction of
groundwater flow is toward low areas and surface water bodies and essentially reflects the
surface topography. The hydraulic gradient varies from 0.002 ft/ft across level portions of
the site to 0.10 ft/ft immediately adjacent to Gales Branch and the Barge Canal. Assuming
an average hydraulic conductivity for the Upper Zone of 1000 ft/year, a representative
hydraulic gradient of 0.005 ft/ft, and an effective porosity of 03, the average groundwater
flow rate in this zone is on the order of 15 to 20 ft/yr. Lower Zone potentiometric contours
are presented in Figure 6.
Groundwater Contamination Prior to Initiation of Remediation Program
Groundwater samples from monitor wells (MW-l, MW-2, MW-3, and MW-4 [Figure 2])
around the Former Brine Sludge Lagoon in 1985 and early 1986 indicated the presence of
elevated levels of mercury and chlorides in the Upper Zone. Concentrations of mercury in
the groundwater prior to remediation were as high as 2.2 mg/L; initial concentrations of
chlorides were as high as 51,000 mg/L
The mercury-contaminated groundwater plume was estimated to cover approximately 1 acre,
with a wetted depth of approximately 7 ft. Historic mercury and chloride concentrations in
groundwater in the vicinity of the Former Brine Sludge Lagoon are presented in Tables 1
and 2, respectively. Concentration isopleths form mercury and chlorides from 1988, prior
to initiation of the remediation program, are shown on Figures 7 and 8, respectively. Prior
to 1991, mercury concentrations reflected analyses for dissolved mercury; from 1991 to
present, both dissolved and total mercury analyses were performed.

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GROUNDWATER REMEDIATION SYSTEM
Description, Design Criteria, Parameters
The groundwater corrective action program for the Former Brine Sludge Lagoon consists
of a two-phase program: source removal and remediation. First, further contamination of
the groundwater was eliminated by the removal of all wastes, liner, and contaminated soil
from the lagoon, and subsequent capping. The second phase, which is ongoing, includes the
interception and removal of already contaminated groundwater, including treatment and
discharge through an NPDES-permitted outfall. The second phase also includes a
groundwater monitoring system that verifies the effectiveness of the corrective action.
A layout of the selected groundwater interception system is presented in Figure 9. It
includes perpendicular interception trenches filled with select sand and gravel, and capped
with clay, installed on the northern and eastern sides of the former lagoon. A recovery
sump and pump is located at the trench intersection point at the northeast corner of the
lagoon, and piezometers are located in the trench to observe drawdown effects. The trench
depth varies from 22 to 26 ft below ground surface, with a bottom slope (0.008 to 0.02 ft/ft)
toward the recovery sump. Recovery trench, sump, and piezometer details are shown on
Figure 10.
The placement of the trenches was designed to intercept groundwater, which flows in a
predominantly northeasterly direction in the vicinity of the lagoon. The system design was
based on the following parameters:
Parameter	Basis	Yalus
Groundwater flow direction Water level measurements	Toward the northeast
at monitor wells
Groundwater gradient	Water level measurements 0.011 ft/ft
at monitor wells
Transmissivity
Horizontal flow velocity
Base of shallow water-bearing
zone
Slug tests
Transmissivity &
gradient
2 ft2/day
7.6 x 10*3 ft/day
Interpolation from drilling logs Approx. 25 ft below
ground surface
The system design included a recovery sump well of 8-inch diameter PVC, with an overall
length of 26 ft-4 inches, including 16 ft of 0.020-inch slotted screen. The sump was equipped
with a submersible pump for recovering well fluids. Recovered groundwater is pumped
from the sump to a 7,000 gallon storage tank, from which it is then pumped via transfer
pump to an existing wastewater treatment sump in the plant, where it joins other plant waste
streams for treatment. The treatment system utilizes sulfide precipitation to remove
mercury from the wastewater.

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The storage tank provides equalization and surge capacity (due to non-uniform flow) so the
recovered fluids can be transferred to the treatment sump at a controlled rate. The tank
also compensates for minor unit shutdown as well as acting as a mixing chamber, minimizing
any possible impacts in the variation of concentration levels of the groundwater. Level
controls shut off the associated pump if fluid levels in the holding tank are too high.
Groundwater recovery rates of approximately 5,000 gallons per day (gpd), or 3.5 gallons per
minute (gpm) were anticipated; a 1/2 horsepower submersible pump with a design capacity
of 5 gpm (110 ft TDH) was selected.
Based on pre-installation computations, at an average pumping rate of 5,000 gpd, it was
estimated that the system would remove and treat approximately 1.7 million gallons of water
over a period of 2 to 7 years, with three groundwater turnovers. It was anticipated that
gradients, and consequently flows and yields, would increase as the water level in the
trenches was drawn down due to pumping.
Operational Problems, Difficulties Encountered, Changes/Revisions
Construction difficulties included (1) space constraints imposed by an adjacent railroad,
operating pipelines, and nearby utility poles; (2) maintaining an open excavation prior to
backfill in a narrow (2-foot wide) trench to depths of 22-26 feet; and (3) establishing free
flow in the trench after completion.
As can be seen on Figure 9, one of the groundwater interception trenches is located only
20 ft from an operating railroad. Drainage slopes, extending to a shallow ditch between the
trench and the railroad, required grading and vegetation. Contractors were required to take
extreme care with equipment placement and coordinate schedules for work adjacent to the
railroad tracks. An existing active 4-inch diameter caustic pipeline, buried approximately
5 ft below ground surface ran beneath the former lagoon, a few feet to the south of and
approximately parallel to the northern (east-west) recovery trench and thence crossing the
eastern (north-south) trench and provided an additional construction hazard. Contractors
were required to locate the pipeline and hand-excavate trench material around the pipeline.
Major regional utility service poles in the vicinity of grading for the lagoon cap and recovery
trench installation (near MW-4, Figure 9) required protective bracing during excavation and
backfill operations.
The trench design called for a 2-ft wide excavation to depths of up to 26 ft below ground
surface. The excavation was completed without shoring, keeping the cut open by
maintaining a positive head in the excavation with "revert mud." Polymer revert mud, which
was supposed to revert to the consistency of water within 24^8 hours, was used in
preference to standard drilling mud in an effort to promote groundwater flow into the
trench and to avoid possible side-wall sealing associated with normal drilling mud. A
minimum length of mud-filled cut was left open during filling with select sand and gravel.
The filling operation displaced mud in the cut. Although there was minor side-wall caving,
the trench walls remained stable and continuous. The resulting trench width approached
3 ft in many places, requiring larger volume of select sand and gravel fill than anticipated.

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After installation of the trenches, the revert mud exceeded the anticipated 48-hour time to
reversion to a water-like consistency. Testing of the mud material indicated that, even after
a distinct change in consistency, the mud retained a filmy quality that impeded flow into and
through the trenches. At the manufacturer's suggestion, the trenches were flushed with
sodium hypochlorite and fresh water, after which flow improved markedly.
Initial operational difficulties involved apparent recovery pump clogging by solids. The
revert mud film was also suspected of contributing to the problem. The 5 gpm recovery
pump, which had very small stainless steel impellers, was replaced with an 18 gpm pump
with more opened plastic impellers. The new pump increased velocity in the transfer piping
and kept solids in suspension. With minor periodic interruptions, the pumping has
proceeded without incident since 1989. In 1992, actual monthly average pumping rates
ranged from 1.81 to 3.77 gpm.
Results to Date
After four years of operation, over 9.5 million gallons of water have been recovered by the
system, and maximum concentrations of total mercury and chlorides in groundwater at wells
surrounding the facility have declined to 0.032 mg/L and 7,750 mg/L, respectively. Records
of the mercury and chloride concentrations in groundwater in the vicinity of the Former
Brine Sludge Lagoon are presented in Tables 1 and 2, respectively.
Figures 11 and 12 present recent (May 1993) concentration isopleths for mercury and
chlorides, respectively. Based on the dissolved mercury isopleths, the mercury-contaminated
groundwater plume covers approximately 0.73 acre. Graphs of dissolved mercury concentra-
tions versus time and total chloride concentrations vs time are presented in Figures 13 and
14, respectively.
PROGRESS IN GROUNDWATER REMEDIATION
Considerable groundwater has been recovered from the recovery trench since its
construction.- Based on findings to date, it may be concluded that the remediation system
is operating as designed, contaminants are being recovered, and concentrations of
contaminants in the groundwater are decreasing. However, the rate of mercury recovery
(Figure 13) and the results of mercury adsorption/desorption tests conducted on samples
of soils from the site suggest an asymptote of mercury reduction may be reached and (2)
there is the possibility of long-term residual desorption of trace concentrations of mercury.
Accordingly, it is not possible to predict the time to achieve remediation goals.
COSTS
Construction Costs
Construction costs for the groundwater remediation system were approximately $200,000.
These costs included:
o trench, sump, and piezometer installation
o 7,000-gallon storage tank, wallod concrete containment area

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o groundwater recovery pump, transfer pump, sump pump
o associated electrical control panels, switches, and wiring
o approximately 750 ft of 2-inch diameter PVC piping, pipe supports, and hangers
Not included are costs associated with design engineering and construction management.
Operation and Maintenance Costs
Annual operations costs have been approximately $20,000 per year, including sampling and
analytical costs, unit inspections, and permit-required reports to ADEM. Not included are
costs for groundwater treatment and other related RCRA Facility Investigations required
by the post-closure permit
Annual maintenance costs have been approximately $2,500 per year, including re-
pair/replacement work on groundwater recovery and transfer equipment, monitor wells
maintenance, and recovery area grounds upkeep.

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TABLE 1
KERCURV CONCENTRATIONS IN GROUNDWATER (bb/L)
1985 THROUGH 1993
J9iil
BLi.
MU-3
nw-4
Date
Total
Dissolved
Total
Dissolved

Dissolved
Total 1
12/10/85
HA
1
0.5600
NA
0.500
NA
0.400
NA
12/31/85
NA
0.9400
NA
0.300
NA
0.700
NA
01/07/86
NA
0.6100
NA
0.870
HA
0.690
NA
01/21/86
NA
0.7500
NA
1.430
NA
1.360
NA
08/24/87
NA
2.1000
NA
0.7900
HA
0.4100
NA
12/18/87
NA
2.1000
NA
0.8200
NA
0.7400
NA
04/19/88
NA
1.6000
NA
1.1000
NA
0.1000
NA
05/23/88
NA
1.0000
NA
0.1200
HA
0.7400
NA
05/23/88
NA
1.4500
NA
0.7100
HA
0.8450
NA
06/09/88
NA
0.6300
NA
0.2100
NA
0.7300
NA
06/09/88
NA
0.2300
NA
0.2800
NA
0.1800
NA
10/14/88
NA
1.7000
NA
1.1000
NA
0.6100
NA
03/23/89
NA
1.4000
NA
0.2800
NA
0.1300
NA
05/02/89
NA
0.7100
NA
0.1800
NA
0.0040
NA
09/22/89
OA
0.1450
M
0.1360
NA
0.1530
NA
11/27/89
M
0.07M
BA
0.6310
NA
0.0760
NA
03/01/90
U
0.0440
NA
0.2890
NA
0.6S30
NA
05/17/90
GA
0.0048
OA
0.0820
HA
0.1190
NA
00/02/90
OA
0.0028
NA
0.0880
NA
0.1200
NA
10/11/90
NA
<0.0020
NA
0.0030
NA
0.1040
NA
11/13/90
OA
0.0030
NA
0.0130
NA
0.0300
NA
02/26/91
0.1216
0.0003
0.0456
0.0002
0.1864
0.1460
0.0844
05/07/91
0.0511
<0.0002
0.0048
0.0003
0.0465
0.0197
0.0710
08/07/91
0.0494
<0.0002
0.0277
0.0003
0.2200
0.0235
0.0777
11/12/91
0.081
0.0334
0.0311
0.0038
0.261
0.0985
0.0574
03/30/92
NA
0.00045
NA
0.00055
NA
0.021
NA
05/20/92
0.0211
<0.0002
0.0359
<0.0002
0.114
0.0262
0.0633
08/24/92
NA
0.0012
NA
0.0036
NA
0.060
NA
11/13/92
0.0038
<0.00020
0.0080
0.0036
0.035
0.029
0.0U
02/17/93
0.011
<0.00020
0.0074
0.0031
0.021
0.020
0.0079
05/24-26/93
<0.00020
<0.00020
0.0012
0.0005
0.0321
0.0210
0.0054
Dissolved
0.023
0.076
0.110
0.170
0.1100
0.0720
0.0800
0.0600
0.1180
0.0600
0.0500
0.0800
0.0810
0.0090
0.1240
0.1260
0.2610
0.1470
0.1410
0.0690
0.0580
0.0024
0.0489
0.0136
0.0094
0.021
0.0041
0.032
0.013
0.0070
0.0029

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TABLE 2
TOTAL CHLORIDE CONCENTRATIONS 1M GROUMNMTER (BO/L)
1985 THROUGH 1993
DATE
KW-1
MU-2
MU-3
HU-4
12/10/85
35100
6330
18000
1900
12/31/85
31900
5770
17300
17900
01/07/86
23630
4190
22130
18400
01/21/86
21450
9220
23060
18110
08/24/87
51600
22900
20100
15700
12/18/87
39500
18600
24900
10600
04/19/88
28000
26000
63000
10600
05/23/88
22700
7000
30200
7100
05/23/88
35500
22000
34000
19000
06/09/88
20000
8000
20000
9000
06/09/88
26500
9000
20800
3350
10/U/88
37500
27000
44500
5400
03/23/89
28000
19400
6300
3960
05/02/89
24200
10600
2080
2500
09/22/89
7810
4090
4010
4320
11/27/89
5620
6530
2860
7250
03/01/90
7720
6570
5100
10770
05/17/90
5350
3920
5350
7450
08/28/90
3600
4100
2900
5600
11/13/90
1770
1720
808
1820
02/20/91
788
808
5203
4168
02/26/91
675
552
1513
2424
05/07/91
357
728
2204
4913
08/07/91
186
1700
4750
3700
11/12/91
300
3600
6150
4100
03/30/92
230
1300
2700
4400
05/20/92
154
2400
5000
5500
08/24/92
270
2000
3300
4800
11/13/92
210
1600
2400
6000
02/17/93
230
1400
2000
5000
05/24-26/93
250
850
4200

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LEGEND
+
+¦
~
*
¥
PREVIOUS SHALLOW MONITORING
WELL LOCATION
PREVIOUS DEEP MONITORING
WELL LOCATION
SOIL BORING FROM PREVIOUS
STUOY (GROUTED)
SHALLOW MONITORING WELL LOCATION.
LOWER ZONE INVESTIGATION
INTERMEDIATE MONITORING WELL LOCAllON,
LOWER ZONE INVESTIGATION
DEEP MONITORING WEI t tOCAMON.
LOWER ZONE INVESTIGA1 ION
VERY DEEP MONITORING WLLL LOCATION.
LOWER ZONE INVESTIGATION
laet 250
SCALC
G&E
ENGINEERING, INC.
ENVlRONMENTAl & GLOUCMNlCAl
CONSUI1ANTS
Holon Roug* luumono
OCCIDENTAL CHEMICAL CORPORATION
NIAGARA FALLS. NtW YORK
RFI WORKPLANS
OXYCHCM MOBILE PLAN1
MOBILL. ALABAMA
IlIU

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Speaker's Brief Biographical Information
Conference:
USEPA Region IV Technical Conference on Groundwater
Remediation/Stabilization, Atlanta, December 1-3, 1993
Presentation
Title:
Authors:
Speaker:
Case Study:
Groundwater Remediation System
Occidental Chemical Corporation
Mobile, Alabama
Linda M. McConnell, PE, G&E Engineering, Inc.
Richard B. Adams, PE, DEE, CGWP, G&E Engineering, Inc.
Ed Seitz, Occidental Chemical Corporation
Linda M. McConnell
Linda M. McConnell is Vice President of G&E Engineering, Inc. A
registered professional engineer, Ms. McConnell has over 18 years
engineering and environmental experience. Her primary areas of
responsibility include RCRA permitting, investigations, and corrective
actions. She has also prepared several risk assessments and applica-

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Case Study
Olin Corporation
Mcintosh, Alabama
Effectiveness of the RCRA Groundwater
Corrective Action Program
October 1993
1 Introduction
This report presents an analysis of the RCRA Corrective Action Program (CAP) at Olin's
Mcintosh, Alabama, facility. The CAP is a groundwater remediation program using pump-
and-treat methods to reduce mercury and organics in groundwater to the groundwater
protection standards required by a RCRA post-closure operating permit. This report will focus
on the mercury contamination in groundwater and will discuss the progress in remediation in
terms of mercury. The organic contaminant remediation is progressing in parallel to the
mercury.
2 Description of the Facility
The Olin Corporation Mcintosh plant is located approximately one mile east-southeast of the
town of Mcintosh, in Washington County, Alabama (Figure 1). The property is bounded on
the east by the Tombigbee River, on the west by U. S. Highway 43, on the north by the Ciba-
Geigy Corporation plant site, and on the south by River Road. The Olin Mcintosh plant is an
active chemical production facility located on approximately 1,500 acres, with production
areas occupying approximately 60 acres. The Mcintosh plant today produces chlorine, caustic
soda, sodium hypochlorite and sodium chloride and blends and stores hydrazine compounds.
Current active facilities at the plant include: a diaphragm cell chlorine and caustic production
process area; a caustic concentration process area; a caustic plant salt process area; a hydrazine
blending process area; shipping and transport facilities; process water storage, transport and
treatment facilities; and support and office areas.
The production area is relatively flat, about 40 to 50 feet above mean sea level (msl). The
most distinctive topographic feature is a steep bluff located approximately 4,000 feet east of
the production area. This bluff defines the edge of the low-lying floodplain area, which is
about 25 feet lower in elevation than the upland areas immediately to the west.
2.1 Area Land Use
Residential land use (4 percent of area within a 3-mile radius of the site) includes individual
dwellings and groups of two to about twenty dwellings. The commercial activity (less than 1
percent of the area) is generally related to basic domestic needs and services located along
Highway 43. Industrial use occupies 4 percent of area within the 3-mile radius. The two
main industries are the Olin and Ciba-Geigy facilities. A compressed air power plant
(Alabama Electric) and a cement company are also located within the 3-mile radius. Public

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Olin Corporation - Mcintosh, Alabama
Page 2
and cemeteries. Forested uplands make up the largest land use area (65 percent). Floodplains
and streams, including the Tombigbee River, the basin and Bilbo Creek, make up about 27
percent of the three-mile-radius area.
2.2 Site History
Olin operated a mercury cell chlor-alkali plant (constructed in 1951) on a portion of the site
from 1952 through December 1982. In 1952, Calabama Chemical Company began operation
of a chlorinated organics plant on property immediately south of Olin. In 1954, Olin acquired
Calabama and in 1955 began construction of a pentachloronitrobenzene (PCNB) plant on the
acquired property. The plant was completed and PCNB production was started in 1956. The
Mcintosh plant was expanded in 1973 to produce trichloroacetonitrile (TCAN) and 5-ethoxy-3-
trichloromethyl-l,2,4-thiadiazole (Terrazole). The PCNB, TCAN and Terrazole
manufacturing areas were collectively referred to as the crop protection chemicals (CPC)
plant. In 1978, Olin began operation of a diaphragm cell caustic soda/chlorine plant, which is
still in operation.
The CPC plant and mercury cell chlor-alkali plant were shut down in late 1982. The CPC
plant was decommissioned and dismantled and the site was capped under a plan submitted to
and approved by ADEM. .The chlorine plant was decommissioned and dismantled in several
phases from 1982 until 1986. Figure 2 presents the location of these areas as well as all Solid
Waste Management Units (SWMUs) at the site.
In March 1982, Soil and Materials Engineers, Inc. (S&ME) performed a hydrogeological
investigation of the Mcintosh site to assess the migration and extent of organic contaminants in
the groundwater (S&ME, 1982). The investigation included the installation of 32 monitoring
wells and groundwater sampling of both new and the existing 43 wells. The field investigation
was completed in August 1982, with the final report submitted to ADEM and EPA in
November 1982. The report established the direction of groundwater flow and defined the
hydrogeologicalj)arameters of the area. The study also identified two plumes of chlorinated
organic contaminants (predominantly chloroform, benzene, chlorobenzene and
dichlorobenzene) in the Alluvial Aquifer, one moving east-southeast, the other west-southwest.
The two plumes' movement in different directions was the result of a groundwater divide that
existed before implementation of the RCRA corrective action program.
The hydrogeological data indicated the Alluvial Aquifer is separated from the deeper Miocene
Aquifer by a low-permeability clay aquitard. The report further indicated that this aquitard
inhibits downward migration of the contaminant plumes. To further define the migration of
the plumes identified by S&ME, Olin Corporation installed 14 additional monitoring wells
between February and March of 1983.
During the period from 1982 to 1986, Olin closed the RCRA-regulated units at the Mcintosh
plant. Several of the units are regulated under a RCRA post-closure operating permit. Since
1984, Olin has conducted its RCRA groundwater detection monitoring program. Ten
additional monitoring wells have been installed on the eastern perimeter of the plant to further
define the migration of contaminants to the east/southeast. The location of all wells is shown
on Figure 3.
In July 1987, construction was completed on the groundwater corrective action program (CAP)
required by the post-closure openi :ing permit. The five-well system became operational in

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Olin Corporation - Mcintosh, Alabama
Page 3
Each well has a fully penetrating, 10-inch-diameter, Schedule 40 PVC screen and a 10-inch-
diameter, Schedule 40 PVC casing. The wells were drilled to the top of the Miocene clay,
approximately 90 feet deep. The five pumping wells operate 24 hours per day (with minor
outages for maintenance and emergencies). The pump discharges are equipped with sampling
points, instantaneous flow measurements and control, flow totalization, and pump discharge
pressure instrumentation. Each pumping well is equipped with its own treatment system.
The RCRA post-closure permit requires groundwater monitoring for clpsed RCRA units,
including the weak brine pond, the stormwater pond and the brine filter backwash pond. The
post-closure permit also requires corrective action for releases of hazardous waste constituents
from any solid waste management units (SWMUs) at the facility. There are no active RCRA
units at the facility.
3 Regional Geology
Washington County is located in the Southern Pine Hills District of the East Gulf Coastal Plain
Province. The Mcintosh area is underlain by alternating beds of unconsolidated-to-
consolidated sedimentary rocks that are collectively hundreds of feet thick (Turner and
Newton, 1971). These rocks dip southwesterly at 30 to 50 feet per mile. The general dip of
these rocks is locally interrupted by folds, faults and salt domes. The Mcintosh salt dome is
the most distinctive structural feature of the area. The Olin site lies within the Mobile graben,
a complex north-south oriented fault system that extends in a north-south direction from west-
central Clarke County to east-central Mobile County.
The near-surface sediments of the Mcintosh area are Recent alluvium and Quaternary alluvial
terrace deposits that are collectively as much as 100 feet thick in places (Turner and Newton,
1971). As much as 30 to 40 feet of these strata are exposed in various drainage ditches in the
area and along the west bank of the Tombigbee River east of the site. Based on information
from water wells and tests holes at the Olin site, the thickness of these sediments ranges from
about 80 to 100 feet. Quaternary sediments were deposited unconformably over the
underlying Miocene sediments. These alluvial sediments consist of beds of sand, gravel, silt,
and clay, along with various combinations of these materials. Permeable units of sand and
gravel that exist within this section are aquifers. One of these sand units is located beneath the
plant site, directly overlying the Miocene strata, and varies in thickness from 55 to 80 feet.
This sand unit is referred to as the Alluvial Aquifer (Q2). This Quaternary sand unit is
overlain by 10 to 60 feet of silt and clay. The quality of natural formation water in the
Alluvial Aquifer is generally suitable for domestic and industrial uses. However, iron
concentrations are typically in excess of 0.3 mg/1.
The Miocene series is composed of alluvial sediments that were deposited in complex,
nonmarine environments. West of Mcintosh, Miocene strata outcrop in a large part of
Washington County and are exposed in road cuts and along stream valleys. In the Mcintosh
area, Miocene strata are covered by the younger Quaternary alluvial sediments. The Miocene
series ranges in thickness from less than 275 feet over the Mcintosh salt dome to as much as
600 feet away from the dome. This geologic unit is composed of beds of fine-to-coarse-
grained sand, gravelly sand, sandstone, and beds of light gray and varicolored clay.
The sands and gravel in the Miocene series are the most important groundwater source in the
Mcintosh area. The Miocene series beneath the site is divided into four units. The lower

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Olin Corporation - Mcintosh, Alabama
Page 4
site. The Tm4 unit is overlain by the lower Miocene confining unit (Tm3), which is believed
to be laterally continuous and sufficiently impermeable to retard upward vertical movement of
groundwater from the lower Miocene Aquifer. The upper Miocene Aquifer (Tm2) is a highly
permeable sand and is referred to as the Miocene Aquifer in this report. The Miocene Aquifer
is overlain by the upper Miocene confining unit (Tml).
The Miocene Aquifer receives considerable recharge in the large outcrop areas located west
and northwest of Mcintosh. In these outcrop areas, groundwater in the aquifer occurs under
unconfined conditions. Northwest of the town of Mcintosh, the Miocene Aquifer probably
receives considerable recharge by downward vertical leakage from the overlying Alluvial
Aquifer where these aquifers are separated by thin and relatively permeable silt and clay beds.
However, as groundwater in the Miocene Aquifer moves downgradient, it becomes confined
by thicker clay, silt and silty clay beds. The two aquifers are separated by an estimated 80 to
100 feet (the upper Miocene confining unit) at the Olin Mcintosh facility.
Geologic formations of Oligocene and Eocene age underlie the Miocene formations in
Washington County and are sources of groundwater in northern Washington County. These
formations are not sources of potable groundwater in the Mcintosh area. Highly mineralized
groundwater under considerable confining pressure occurs in some aquifers within these
formations. It is postulated that near some fault zones, this highly mineralized groundwater
may have risen upward along and through the fault zones into overlying freshwater aquifers
(Barksdale, 1929, Newton and others, 1972).
4 Site Stratigraphy
Near-surface strata consist of Quaternary alluvial terrace and floodplain sediments deposited by
the Tombigbee River. The Quaternary sediments range in thickness from 80 to 100 feet and
consist of beds of sand, gravel, silt and clay, which form the Alluvial Aquifer system. The
Alluvial Aquifer is underlain by Miocene sediments. The Miocene series is composed of
alluvial deposits.of fine-to-coarse-grained gravel, sand and sandstone and beds of gray-to-
varicolored clay. The Miocene series varies in thickness from less than 275 feet above the
Mcintosh dome to as much as 600 feet away from the dome. The Quaternary alluvial
sediments are divided into two units, designated Q1 and Q2. The Tertiary (Miocene) units
addressed in this study are designated Tml and Tm2.
The Olin site is located within the outcrop area of the upper clay unit (Ql). The lithology of
Q1 is variable, but is composed primarily of red-brown, yellow-brown, and gray, silty/sandy
plastic clay; the silt and sand content varies and generally increases with depth. Thin,
probably discontinuous sand and silt lenses occur interbedded with the clay. The thickness of
Ql varies from less than 10 feet to about 60 feet, as illustrated on the cross sections.
The Alluvial Aquifer (Q2) in the production area varies in thickness from an average of about
55 feet to 80 feet, thinning in the west plant area to approximately 37 feet at the location of
monitor well DH3. The Alluvial Aquifer is divided into two zones. The upper zone of the
Alluvial Aquifer is composed primarily of very fine to fine-grained, silty quartzose,
subangular-to-subrounded sand. The lower zone of the aquifer is composed of fine-to-very-
coarse, orange-brown, quartzose, cherty, subangular to subrounded sands containing varying
amounts of fine-to-large gravel. Although composed predominantly of sands, Q2 also contains
some thin beds of clay or silty, gravelly cl '. One of these beds, a gravelly, silty plastic clay

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Olin Corporation - Mcintosh, Alabama
Page 5
from approximately 3 feet to 10 feet thick beneath the southern part of the production area.
However, this fine-grained unit apparently pinches out or becomes sandier in other parts of the
plant site.
In water well and stratigraphic test hole logs, the Miocene confining unit (Tml) is described as
consisting of clays, sandy clays, or clayey sands. Although the lithology may be complex, it
is dominantly clay, with various amounts of discontinuous sand, silt, or sometimes fine gravel.
Monitor well DH2 is screened in a sand unit that was initially interpreted to be part of the
Miocene Aquifer (Tm2). S&ME (1982) later concluded that this well is screened in a
discontinuous sand contained within the upper Miocene confining unit. Boring logs from wells
that penetrate the upper Miocene confining unit indicate that this unit is laterally continuous
beneath the site and approximately 80 to 100 feet thick. Figure 4 is a structure contour map
that illustrates the surface configuration of the top of the Miocene confining unit. The upper
clay consists of blue-gray, sometimes mottled, silty, hard plastic clay with minor amounts of
sand. The vertical permeability of the this upper clay is extremely low, with vertical hydraulic
conductivities (K) of less than 1 x 10-5 feet per day (less than 1 x 10-8 cm/sec) (S&ME,
1982).
5 Site Hydrogeology
The uppermost aquifer at the site is the Alluvial Aquifer described above. It is separated from
the lower Miocene Aquifer by the upper Miocene confining unit. discussed above. This
section describes the hydrogeology of both aquifers, although the RCRA Corrective Action
Program (CAP) addressed remediation of only the Alluvial Aquifer.
5.1 Alluvial Aquifer
The Alluvial Aquifer is composed primarily of sands and varies in thickness from about 55 to
80 feet in the plant area, thinning to less than 40 feet at locations in the west plant area. The
Alluvial Aquifer is generally unconfined throughout the area. The specific yield is estimated
to be 0.20, based on grain size analysis.
Figure 5 depicts the typical potentiometric surface of the of the Alluvial Aquifer, based on
water elevations collected during 1986 and 1987 prior to implementation of the corrective
action program. Figure 5 indicates that groundwater entered the site from the north (there is a
localized recharge from a hydraulic mound near monitoring well PL4D). Recharge was from
direct infiltration where the Alluvial Aquifer outcrops to the north of the Olin facility (S&ME,
1982). A groundwater divide was present near the production area separating the southerly
flow into southeast and southwest components. The occurrence of this groundwater divide
appears to be related to the structure of the top of the upper Miocene clay. Structural lows
occur both to the southwest and to the southeast. Groundwater entering the site west of the
structural high preferentially flowed to the southwest and groundwater entering the site east of
the structural high preferentially flowed to the southeast. The southwest component was
influenced by a hydraulic mound located in the western portion of the site and caused by ponds
resulting from beavers' dam building in low areas. Groundwater elevations near the center of
this mound were approximately 20 feet higher than elevations in wells located approximately
1,000 feet to the east. The hydraulic mound diverted the westerly flow to the south.

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Olin Corporation - Mcintosh, Alabama
Page 6
River, where discharge occurred. Near the center of the facility, the groundwater divide was
evident by westward flow in the former mercury cell plant, CPC plant, and strong brine pond
areas and eastward flow east of the old plant (CPC) landfill. Although the exact east-west
location of the groundwater divide has varied with local infiltration rates and seasonal
fluctuations, its occurrence is well documented by the hydraulic head measurements from 1980
to 1986. The divide was first described and related to the structure of the Miocene clay during
the S&ME investigation (S&ME, 1982).
Five corrective action wells currently in operation at the site recover groundwater from the
Alluvial Aquifer. Extraction of groundwater from these wells has caused localized depressions
in the potentiometric surface beneath the site. Figure 6 presents a typical, current
potentiometric map for the site.
The average hydraulic conductivity of the Alluvial Aquifer has been estimated based on single
well tests as 15 ft/day. The hydraulic conductivity value from the pump test was estimated as
578 fit/day, which is considered an upper range value since the area of the test is known to be
highly transmissive. Since pump tests generally yield more reliable estimates of hydraulic
conductivity, the average of 15 ft/day and 578 ft/day, which is 296 ft/day, was used as the
estimate for the site hydraulic conductivity. The effective porosity was estimated to be 25
percent.
Based on the above hydraulic conductivity and gradients based on the potentiometric maps, the
groundwater velocity at the site varies from about 0.16 ft/day to about 12 ft/day. These values
provide a general estimate of groundwater velocity in the Alluvial Aqyifer. The groundwater
flow velocities will also vary with the heterogeneity of the aquifer.properties and localized
variations in the lateral gradients.
5.2 Miocene Aquifer
The upper Miocene Aquifer (Tm2) contains two main artesian sands that are separated by a
clayey unit ranging from 10 to 20 feet thick. The sands are considered as one hydrogeologic
unit due to a natural hydraulic connection and connection by gravel-packed wells. Tlie
combined transmissivity of the two sands is considered to be in excess of about 25,000 square
feet per day (ft2/day) (S&ME, 1982).
The regional gradient of the Miocene Aquifer is to the east-southeast (DeJarnette, 1989).
However, Olin continuously pumps two Miocene Aquifer process water wells. The
transmissivity of the Miocene Aquifer zone was estimated to be 187,000 gallons per day per
foot (gpd/ft) or 25,000 ft2/day. The storativity was estimated to be 0.001.
In addition to the effects of Olin's pumping wells, the Miocene potentiometric surface will also
be affected by the regional groundwater gradient and pumping wells from other areas such as
the Ciba Geigy facility to the north.
6 Solid Waste Management Units
Figure 2 presents a site map indicating the location of all Solid Waste Management Units

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SWMUs, both closed and active. Several of the former RCRA units and SWMUs are believed
to have been significant sources of groundwater contamination at the site. These are indicated
in this section.
6.1 SWMUs Closed Or Clean-closed Under 40 CFR 265
Ten SWMUs have been closed (1 unit) or clean-closed (9 units) under 40 CFR 265. Under
current regulations (40 CFR 270.1(c)), surface impoundments, landfills, treatment units, and
waste piles that were clean-closed under 40 CFR 265 are subject to the clean closure
equivalency standards. At the Olin Mcintosh facility, the units subject to equivalency
demonstrations include the three clean-closed surface impoundments (the stormwater pond, the
brine filter backwash pond, and the pollution abatement (pH) pond) and the one clean-closed
waste pile (the mercury waste pile storage pad). The clean closure equivalency demonstration
document was submitted to EPA October 1, 1993.
6.1.1 Stormwater Pond
The stormwater pond is a clay-lined earthen structure approximately 140 x 365 feet, which
contained a maximum volume of 500 cubic yards of settled solids. The pond received
stormwater runoff from the mercury cell chlor-alkali processing area perimeter. Since
stormwater pond solids were contaminated with mercury, the pond was designated a hazardous
waste unit for D009 wastes. The pond was originally constructed with approximately 1.5 feet
of natural clay of low permeability as a liner. The clay liner was compacted to 95 percent
Proctor density.
This unit was clean closed and is not being used. It has been concluded that this unit has never
been a significant source of groundwater contamination.
6.1.2	Brine Filter Backwash Pond
The brine filter backwash pond was an earthen structure approximately 160 x 240 feet, lined
with a geosynthetic membrane. The pond received wastewaters that included washdown, filter
backwash and process water. The maximum inventory of settled solids was estimated to be
approximately 600 cubic yards.
This unit was clean closed and is used as needed as a nonhazardous surface impoundment. It
has been concluded that this unit has never been a significant source of groundwater
contamination.
6.1.3	Pollution Abatement (pH) Pond
The pH pond was a wastewater impoundment approximately 140 x 290 feet. The bottom of
the pond was constructed of a backfilled, low-permeability clay approximately 2.0 feet thick.
This pond was designed and constructed to handle corrosive wastewaters having a pH less than
2.0 or higher than 12.5. Wastewaters received for treatment included washdown from process
areas, cooling tower blowdown, various process streams, and contaminated stormwater runoff.

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The unit was clean-closed, is now lined with a synthetic membrane, and is used as a
nonhazardous wastewater holding pond. This unit was a significant source of low pH
contamination to the groundwater and probably caused increased mercury and dissolved solids
concentrations in groundwater beneath it.
6.1.4	Weak Brine Pond
The weak brine pond was an earthen structure approximately 340 x 340 feet that was primarily
a process brine unit, but also received several D009 and K071 waste streams from operation of
the mercury cell chlor-alkali plant, including filter backwash that contained mercury.
The weak brine pond was also utilized during the closure of the three on-site surface
impoundment units discussed above (i.e., the stormwater pond, the pH pond and the brine
filter backwash pond). The material removed from each of these impoundments was deposited
in the weak brine pond, stabilized, and solidified with cement dust. The total volume of
consolidated waste in this unit is approximately 33,000 cubic yards.
Closure for this unit consisted of liquids removal, on-site treatment through an existing
activated carbon system and discharge through Outfall 001 in accordance with the NPDES
requirements. After removal and treatment of the liquids, chemical stabilization/solidification
materials were added to the pond bottom sludges, along with dry soil pushed in from the
dikes, to form a stable foundation for the final cover and cap material.
After the pond contents were stabilized, the former pond was capped. A composite support
base of dike soil, native soil and clay was constructed using a 12-inch base of native soil and
dike material followed by a 6-inch cover of compacted clay material having a reported
maximum permeability of 1 x 10-7 cm/sec. The clay was also compacted to a minimum 95
percent Proctor density, with the compaction and permeability being verified in the field by an
independent soils testing laboratory. A 30-mil synthetic liner was then placed over the support
base to provide an impervious membrane over the underlying material. A 12-inch sand
drainage layer was placed over the synthetic liner to function as a drainage system to remove
any water that resulted from rainfall and percolation through the overlying layers. The sand
drainage layer was then covered with a geotextile fabric net and capped with a 6-inch layer of
compacted clay having a maximum permeability of 1 x 10-7 cm/sec. A final cover of 6 inches
of topsoil was installed, with seed (30 pounds/acre) and fertilizer being applied to establish
rapid cover and prevent erosion of the cap system. The top cover was sloped at a five percent
gradient. The cap was encircled by concrete-lined perimeter ditches sloped to drain into the
plant wastewater discharge.
This unit is considered to have been the source of most mercury and dissolved solids
contamination in the groundwater at the site.
6.1.5	Mercury Waste Pile Storage Pad
The mercury waste pile storage pad was a concrete pad, approximately 40 x 60 feet, located to
the south of the former mercury cell plant area. The pad was classified as a RCRA hazardous
waste unit for D009 wastes from 1980 to 1984. Half of the unit was used for drum storage
while the other half was used for storage of material contaminated with mercury from the
mercury cell chlor-alkali process operations (e.g., piping, etc.). .Most of the material was

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process was discontinued. The remaining wastes were removed during clean closure in
November 1984. It has been concluded that this unit has never been a significant source of
groundwater contamination.
6.1.6 TCAN Hydrolyzer
The TCAN (trichloroacetonitrile) hydrolyzer was a glass-lined agitation tank designed to
hydrolyze the reactive residue from the TCAN distillation column. The residue was loaded in
the hydrolyzer after being treated with a 20 percent sodium hydroxide solution for
decomposition of the reactive component (TCAN). The nonreactive waste was then drained
into 55-gallon drums for off-site disposal.
All wastes were removed from the TCAN hydrolyzer tank in February 1982 and the unit was
placed in standby status. The unit was then closed in December 1982 by rinsing with a sodium
hydroxide solution followed by a high-pressure, hot water rinse. All waste residues were
collected and solidified for disposal in an off-site hazardous waste landfill. It has been
concluded that this unit has never been a significant source of groundwater contamination.
6.1.7 Mercury Drum Storage Pad
The mercury drum storage pad was used to store drums that contained D009 wastes including
filters, sump sludges and other process waste containing mercury. The unit consisted of a 40 x
60-foot concrete storage pad used for drum storage of mercury-contaminated solids. The unit
was clean closed by removing all the waste, followed by decontamination. It has been
concluded that this unit has never been a significant source of groundwater contamination.
6.1.8 Chromium Drum Storage Pad
The chromium drum storage unit is a 30 x 50-foot concrete pad that was used for storage of
containerized, chromium-contaminated solids and liquids. Maximum inventory of the unit
reached approximately 6,600 gallons. The unit was closed in January 1986. Materials were
removed and transported to an off-site hazardous waste treatment or disposal facility. It has
been concluded that this unit has never been a significant source of groundwater
contamination.
6.1.9 PCB/Hexachlorobenzene Storage Building
The PCB/hexachlorobenzene building was a 60 x 120-foot steel frame building with ribbed
siding. The building was used mainly for the storage of hexachlorobenzene (K085), a waste
material generated in the manufacture of PCNB. Closure consisted of removal of materials
and transportation to an off-site hazardous waste treatment/disposal facility. It has been

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6.1.10 Hazardous Waste Drum (Flammable) Storage Fad
The flammable waste drum storage facility is a 30 x 40-foot steel frame building with a
concrete floor and partial siding. The building was used primarily for the storage of ignitable
(D001) wastes. This unit was clean-closed in January 1986 by removing all waste from the
site and transporting it to an off-site hazardous waste treatment and disposal facility. It has
been concluded that this unit has never been a significant source of groundwater
contamination.
6.2 SWMUs Not Regulated Under 40 CFR 265
6.2.1	Sanitary Landfills
Between 1977 and 1984, Olin operated two sanitary landfills that received general
nonhazardous waste and plant refuse (Figure 2). Records show that waste disposed of in the
two sanitary landfills included paper, glass, boxes, wood, plastic, grass clippings, pipe,
concrete, and sanitary sludge. The first unit was constructed in 1976 and opera tad from 1977
to 1978. It was approximately 150 x 200 feet and contained about 4,000 cubic yards of
material. The second unit was operated from 1978 to 1984. The second unit was
approximately 600 x 800 feet and contained about 18,000 cubic yards of material. It has been
concluded that this unit has never been a significant source of groundwater contamination.
6.2.2	Old Plant (CPC) Landfill
The site of the old plant (CPC) landfill (Figure 2) was utilized from 1954 until 1972 to
neutralize acidic wastewater from CPC plant operations. Neutralization was conducted by
flowing the wastewater over piles of oyster and clam shells. The flow was then directed by an
overflow ditch to the production wastewater ditch. Plant personnel indicate that the former
landfill also received organic wastes from the CPC plant. From 1972 to 1977 the site was
used for disposal of general plant debris such as paper, cardboard, wood, small metal
containers, scrap plastic and rubber items from the entire plant. The landfill area is
approximately 300 x 400 feet and is estimated to have an 8,000-cubic-yard capacity. In 1977,
prior to RCRA, the landfill was closed with a clay cap, topsoil, and grass, as approved by the
AD EM. The cap was upgraded in 1984 to address erosion problems that had occurred.
During the upgrade, a 2-foot-thick layer of compacted clay was placed; a 3- to 6-inch layer of
topsoil was placed over the clay cap and the area was vegetated.
The old plant (CPC) landfill is considered to have been the source of most of the organic
contamination in groundwater.
6.2.3	Diaphragm Cell Brine Pond and Overflow Basin
The diaphragm cell brine pond is approximately 384 x 205 feet, with a 38,000-cubic-yard
capacity. This pond is used for weak brine solutions prior to recycling the brine to brine
wells. The brine cell pond and overflow basin were built in 1976. The overflow basin is
smaller, approximately 384 x 144 feet, with a capacity of 26,600 cubic yards. It has been

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6.2.4 Ash Pond (Active)
The active ash pond was built in 1981 and is currently used for nonhazardous boiler ash. It is
approximately 480 x 870 feet, with a 232,000-cubic-yard capacity. It has been concluded that
this unit has never been a significant source of groundwater contamination.
6.2.5	Ash Ponds (Inactive)
There are two inactive ash ponds located on the facility. The old ash pond was used as a
settling pond for nonhazardous, coal-fired boiler ash. It was built in 1976 and is
approximately 200 x 300 feet, with a 31,000-cubic-yard capacity. It is now used as a standby
unit. The day ash pond was used for dewatering nonhazardous boiler ash. The pond is
300 feet in diameter, with a 50,000-cubic-yard capacity. The day ash pond was built in 1979.
It has been concluded that this unit has never been a significant source of groundwater
contamination.
6.2.6	Lime Ponds
There are two former lime ponds, the east and west ponds, which were not regulated under 40
CFR 264 or 40 CFR 265 (Figure 2). The ponds were approximately the same size, but the
west pond contained approximately 5,300 tons of lime waste and the east pond approximately
4,200 tons. The ponds contain lime (from the absorption and capture of residual chlorine gas)
and lime sludges. These two ponds operated from 1968 to 1976 and were closed in 1979
(prior to RCRA) with a clay cap, topsoil and grass. It has been concluded that this unit has
never been a significant source of groundwater contamination. However, mercury has been
detected in the groundwater in the vicinity of these lime ponds. The weak brine pond, in
which mercury-containing brine was handled, is the suspected source of mercury to the
groundwater in the area. Based on the pre-corrective action potentiometric surface, the wells
situated around the lime ponds were located hydraulically downgradient of the weak brine
pond.
6.2.7	Hexachlorobenzene Spoil Area
The hexachlorobenzene spoil area site apparently was used in the past (date unknown) to
dispose of soils from earth work in the former PCNB production facility. The area was
discovered on October 11, 1990 while grading adjacent to the day ash pond. On October 26,
1990, the EPA and Olin reached an agreement through an administrative order of consent
(AOC) for removal of the hexachlorobenzene-contaminated soil. The AOC required that any
soils within the site that had hexachlorobenzene concentrations higher than 200 mg/kg be
removed and transported off-site for disposal at an approved hazardous waste facility in
compliance with EPA's off-site policy. A total of 11,407 tons of soil were excavated,
transported, and disposed of from October 27, 1990 to November 6, 1990. The excavated soil
was sent to Chemical Waste Management's hazardous waste-permitted landfill in Carlyss,
Louisiana. It has been concluded that this unit has never been a significant source of

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6.3 Additional SWMUs/AOCs Listed in the RFA
Olin was issued a federal EPA RCRA post-closure permit on July 7, 1986. On September 1,
1986, ADEM issued a state hazardous waste permit to Olin. EPA retained authority for the
1984 Hazardous and Solid Waste Amendments (HSWA) portions of the permit, which
included the HSWA Corrective Action Program. The first phase of the HSWA Corrective
Action Program is a RCRA Facility Assessment (RFA). The RFA at the Mcintosh facility
was conducted by an EPA contractor and consisted of a preliminary review (PR) of files from
EPA Region IV and ADEM and a visual site inspection (VSI) on June 17 and 18, 1991. A
draft RFA report was provided to Olin on October 30, 1991. Olin made comments, and a
final RFA report was provided to Olin on February 4, 1992. The RFA lists 52 SWMUs and
six areas of concern (AOCs). Additional sampling was recommended at the Solid Waste
Management Units (SWMUs) discussed below (other SWMUs had recommendations other
than sampling). The soil sampling was conducted as part of the CERCLA Remedial
Investigation/Feasibility Study conducted at the site.
6.3.1	Old Plant Landfill Drainage Ditch
During operations of the old plant (CPC) landfill as a wastewater neutralization unit (1954 to
1972), there was a drainage ditch that connected the former landfill to the wastewater ditch.
The drainage ditch was unlined except with natural clay. It was filled in concurrently with
closure of the CPC landfill in 1977. Due to the extensive earth work related to construction of
the pH pond and closure of the landfill in the area, there is no surficial evidence of the ditch.
Sampling indicated low levels of contaminants in soil. It has been concluded that this unit has
never been a significant source of groundwater contamination.
6.3.2	Crop Protection Chemicals (CPC) Plant
This unit is the former location of the plant that was constructed in 1952 and initially
manufactured nronochlorobenzene, adding pentachloronitrobenzene (PCNB) in 1956. In 1973,
the plant was expanded to produce trichloroacetonitrile (TCAN) and 5-ethoxy-3-
trichloromethyl-l,2,4-thiadiazole (Terrazole_). The PCNB, TCAN and Terrazole
manufacturing areas were collectively referred to as the Crop Protection Chemicals (CPC)
plant. The CPC plant was shut down in 1982 for market economic reasons. In 1984 the
business was sold and the plant area was decommissioned, dismantled and covered with an
approximate 2-foot recompacted clay cap and topsoil. The capped area was then vegetated.
TTie plan for decommissioning and dismantling die CPC plant area was approved by ADEM in
1983 and the work was completed in accordance with that plan. Soil sampling under the
RI/FS indicated elevated levels of semi-volatile organics in soil (no mercury was detected), but
modeling indicated that the contaminants would not migrate from the soils at concentrations
that would affect groundwater above protection levels.
6.3.3 Mercury Cell Plant
The former mercury cell plant is an area approximately 180 x 250 feet that was the site of the
structures and operations for the former mercury cell chlor-alkali plant. The mercury drum
storage pad, which was clean-closed, and the mercury recovery vystems were SWMUs located

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down in 1982. The area was decommissioned and then capped in 1986. Decommissioning
included removal of all aboveground structures. The concrete pads and foundations were left
in place; the sumps and trenches were backfilled with clay, and the area was covered with
asphalt. Decommissioning of the mercury cell plant, which was a process unit, was not
subject to regulations of AD EM or EPA. Soil samples under the RI/FS indicated a wide
variation in mercury concentrations, however, the TCLP test indicated that the mercury was
not significantly mobile and would not affect groundwater above the groundwater protection
standards.
6.3.4	Well Sand Residue Area
Well sands were generated during the period from 1952 to 1968 from development and
operation of the brine wells for the mercury cell chlor-alkali process. These sands were
residues of the natural insoluble material in the salt dome and were deposited in mounds in the
brine field area. The well sand in these mounds is a cemented, granular material that has the
consistency of sandstone. After 1968, Olin changed the method of removing brine from the
salt dome cavities, leaving the residues in the cavity and thus eliminating their accumulation at
the surface. Sampling under the RI/FS indicated elevated levels of mercury in the cemented
well sand, but non-detectable levels of mercury in the TCLP extract indicated that the mercury
was immobile and not a source of groundwater contamination.
6.3.5	Strong Brine Pond
The strong brine pond was constructed in 1952 and is a former process unit that was
approximately 340 x 340 feet, constructed partially above-grade in natural clay. The strong
brine pond was located adjacent to the weak brine pond described above, but the functions and
regulatory status of these two ponds differed, as summarized below:
¦	The weak brine pond was used to manage process brine and hazardous waste
streams while the strong brine pond was used only to manage process brine.
-Thus, the weak brine pond was a regulated unit under RCRA and was closed
under RCRA Part 265 regulations and had potential for higher mercury
concentrations in any seepage.
¦	The strong brine pond was removed in 1985 at the same time the weak brine
pond was being closed under RCRA. Solids from the strong brine pond were
placed in the weak brine pond before its contents were solidified.
¦	The weak brine pond was closed in place under RCRA. The pond contents
were solidified and capped with a RCRA multi-layer cap. The weak brine pond
is regulated today under the RCRA post-closure operating permit.
Removal of the strong brine pond was conducted by dewatering and scraping out the material
in the pond. As mentioned above, the material was then placed in the weak brine pond. The
strong brine pond area was then graded flat, capped, and vegetated. Even though the strong
brine pond was a process unit, it was closed in conjunction with the weak brine pond (a RCRA
unit). Sampling under the RI/FS indicated that the strong brine pond area is not a source of

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7 Extent of Groundwater Contamination Before Corrective Action
Figures 7 through 9 present isocontours of mercury concentrations in groundwater both before
corrective action (i.e., groundwater pumping and treating) was initiated in September 1987 and
currently. These figures present typical extents based on the highest concentrations from given
wells regardless of the location of the well screen. This is important in considering
contamination at the Mcintosh plant because of the dense brine present in areas near and
downdip of the weak brine pond, i.e., wells screened near the top of the Miocene clay surface
where the dense brine has come to rest will have higher concentrations than adjacent wells
with shallower screens. This is illustrated on Figure 11 which presents time-series plots for
three well pairs (shallow and deep). The deeper wells have significantly higher concentrations
of mercury because of the presence of the dense brine layer which has a high concentration of
mercury.
The plume of contamination extends east and west of the plant area (the source area) because
of the hydraulic groundwater divide described above and because of the dense brine layer's
tendency to flow by gravity along the surface of the Miocene clay.
8 RCRA Groundwater Corrective Action Program
The corrective action program began operating in September of 1987. The system was
designed using a groundwater model, the USGS McDonald-Harbaugh model MODFLOW.
The design criteria included containment of the plume within three months of well start-up, the
capture of contamination that had appeared at the southern property line (well El), and clean-
up to RCRA groundwater protection standards within 30 years. The system includes five 10-
inch diameter PVC interceptor wells that screen the saturated thickness of the Alluvial
Aquifer. The wells are designated as CA and their locations are shown on Figure 3.
Each well is equipped with its own treatment system. The discharge from corrective action
well CA1 is pumped to a natural draft air stripper to reduce the volatile organic concentrations.
Corrective action well CA1 is not equipped for mercury removal because it is located beyond
the boundary of the extent of mercury contamination as shown on Figure 7. Discharge from
the air stripper flows to the plant effluent ditch. The discharge from CA2 is pumped to a
forced draft air stripper for volatile organic reduction. The stripper then overflows to a single
gravity box filter with 8,000 pounds of activated carbon for mercury removal. Final discharge
from the carbon bed flows to the production effluent ditch. Treatment facilities for CA3 are
similar to CA2, except that the CA3 discharge from the carbon bed is routed through a
separate pH adjustment system before entering the plant effluent. Water from CA4 requires
treatment for volatile organics with a forced draft air stripper. No mercury removal is
required at CA4, and the effluent from the stripper is to NPDES-permitted Outfall 001C.
CA5 is also discharged through a forced draft air stripper to reduce volatile organic
concentrations. The stripper then overflows to a single gravity box filter with 8,000 pounds of
activated carbon for mercury reduction. The discharge from the carbon bed is routed to the
same pH adjustment system as CA3 effluent before entering the production effluent.
The discharge from the treatment systems for wells CA1, CA2, CA3, and CA5 is through
NPDES Outfall 001. The discharge from the treatment system for well CA4 is through
NPDES Outfall 001C. The treated effluent flows through the wastewater ditch and ultimately

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Olin operates the wells and treatment systems as integral parts of its chemical manufacturing
operations. Olin utilizes one operator per shift to operate the treatment systems, the corrective
action wells, and all other NPDES treatment systems throughout the plant. Additionally, Olin
has developed and implemented a preventative maintenance program for the corrective action
wells and treatment systems.
Since implementation of the CAP, the interceptor wells have been operating within the
following pumping rates:
Corrective Action Well Design Pumping Range Approximate Pumping Range
(gpm)	(gpm)
CA1	150	100-150
CA2	100	80-100
CA3	100	100-110
CA4	60	40-60
CA5	180	150-180
The RCRA Corrective Action Program (CAP) has operated efficiently and with few problems
since its start-up. Most operational problems with the wells have been associated with partial
blockage of well screens with iron bacteria. This blockage gradually decreases well yield. If
the yield decreases to 70 to 80% of its design flow, the well is acid- and/or hypochlorite
washed to restore yield. This treatment has been successful in restoring yield in all wells that
have sustained a partial blockage.
The few problems with the treatment systems have been associated with the carbon beds
removing mercury from the well discharge. The beds have a long life (1 to 2 years), and
because of this time in service, carbon fines have carried through the bed, settled in the outlet
chamber, and been subject to resuspension into the treated water flow. This can possibly cause
some periods of increased mercury in the discharge. This has the potential to affect
compliance with Olin's NPDES permit and must be corrected quickly by removing the fines.
The major "problem" with the CAP is the rate of aquifer restoration inherent in all pump-and-
treat remedial actions. If sources have been remediated and the contamination is in the
aquifer, this rate cannot be appreciably increased because of the properties of contaminants and
aquifers, and the time over which the contamination took place. Pump-and-treat systems do an
excellent job of containing plumes of dissolved contaminants. They also remove a substantial
amount of contamination from the aquifer. However, they do not rapidly decrease the
concentrations of contaminants in groundwater. Contaminants released into groundwater many
years ago diffuse into the fine-grained soils of the aquifer. Many contaminants, such as
mercury and chlorinated organics at Mcintosh, adsorb to these fine-grained soils and are
released back into groundwater slowly. Even if groundwater velocities are increased by
pumping more groundwater, the increase will occur predominantly in the courser soils, i.e.,
the paths of least resistance, and the contaminants adsorbed or residing in the pores of the finer
soils will not partition into the groundwater any quicker. Solutions to this "problem" are not
readily available. Many contaminants are not amenable to bioremediation. In situ
bioremediation is gaining some favor for contaminants that are amenable, but understanding of

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9 Results to Date from the RCRA Corrective Action Program (CAP)
Results from the RCRA Corrective Action Program (CAP) can be indicated by a reduction in
either the extent of the plume or in concentrations on monitoring wells over time. Figures 7
through 9 present the extent of the plume, showing the location of isocontours of mercury in
groundwater for concentrations of 2, 10, and 100 ug/1, respectively. The isocontours are
presented for data collected before corrective action was initiated and for data collected during
1993 (current case on the figures). Figures 10 through 14 present time series plots of mercury
concentration for certain monitoring wells and the five corrective action wells (Figure 10).
The monitoring well plots are associated with the dense brine area (Figure 11) or with the
isocontour figures (Figures 12 through 14).
Another key parameter for assessing the effectiveness of a pump-and-treat system is capture
zones created by the pumping wells. Figure 5 presents a potentiometric surface plot before the
pumping wells began operation and Figure 6 presents a plot from 1993 data. The
potentiometric surface depicted in Figure 6 shows that corrective action wells CA1 and CA2
have established a large single cone of depression. CA3, CA4, and CA5 have also established
individual cones of depression.
Water elevations in monitor well PL10S, which is situated between CA4 and the Tombigbee
River, show little change. The influence of the adjacent Tombigbee River probably has
masked any effects from the pumping. Water elevations in background monitor well WP9A
have decreased approximately 2 feet.
Olin's quarterly RCRA monitoring programs consist of collecting samples from 37 monitor
wells and analyzing the samples for mercury (from all 37 wells) and organics (from 21 of
these wells).
Although the system has only been operating for about five years, the following observations
can be made regarding the system's effectiveness:
¦	The system has significantly lowered the water table, and is effective at
controlling contaminant migration from any known sources. Distinct cones
have been developed in the Alluvial Aquifer at the five corrective action wells
(Figure 6).
¦	Distinct cones of influence have been developed at Wells CA1 and CA2 (Figure
6). These wells would capture any westward and southwestward movement of
the mercury and organic plumes.
¦	The CAP is effective at controlling migration of the mercury plume to the south
as shown by the time versus concentration curves. Monitor well El (Figure 12)
had increasing concentrations from about 1984 to 1988, followed by a steep
decline. This decline is attributed to the effect of corrective action well CA5,
situated about 600 feet to the northeast of El, and started up in 1987.
¦	The CAP has had limited hydraulic effects to the east of PL10S, in the
southeastern area of the facility, due to its close proximity to the river.
Mercury concentrations have ranged from 1.0 to 3.8 mg/1 and chloroform from

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constituent. However, there are no known sources in the area and it is expected
that concentrations will eventually decrease with continued pumping.
¦	The mercury concentration data from the weak brine pond area show slight
decreasing trends in the monitor wells screened in the upper zone of the Alluvial
Aquifer, which indicates that contamination is being removed. These trends are
shown on the time versus concentration curves for MP9, BR7, and BR8 (Figure
10).
¦	There are no apparent trends in mercury concentrations for wells screened in the
lower zone of the Alluvial Aquifer in the weak brine pond area (Figure 11). It
is concluded that dense, mercury-containing brine that sank to the top of the
Miocene clay constitutes a secondary source of mercury in the area.
Accumulated brine at the base of the aquifer would explain the higher chloride
and mercury concentrations in the lower zone as compared to the upper zone
Alluvial Aquifer wells. The existing corrective action system, which includes
wells screened over the entire saturated thickness of the Alluvial Aquifer, would

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.4
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Olin Corporation - Mcintosh, Alabama
General Plot Plan
Hazardous Waste Drum
(Flammable) Storage Pad
(Cleaned Closed)

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fl
3
Olin Corporation - Mcintosh, Alabama

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Olin Corporation - Mcintosh, Alabama
Structual Contour Map
Miiocene Clay Surface
feet above MSL
HAZARDOUS WASTI DRUM
(FLAMMAILI)STORAdl PAD
Note Contours are generalized for presentatcn purpotos.

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Olin Corporation - Mcintosh, Alabama
Potentiometric Surface Contours
Before Corrective Action
K«fN«RI
Note Contour* are generalized for presentation purposes
. A HAZARDOUS WASTI MUM
14 (FUUMMABLE)STORAQE pad
(dimcletid)

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Olin Corporation - Mcintosh, Alabama
Potentiometric Surface Contours
HAZARDOUS WASTE DRUM
(FLAMMAfiLC)STOftAOE PAD
Nate Contour* are generalized foi presentation purpose®

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Olin Corporation - Mcintosh, Alabama
Mercury in Groundwater -100 ug/l Contours
Before and After Corrective Action


PROPERTY LINE
Note Contours are generalized for presentation purposes
-	Before
-	Current

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Olin Corporation - Mcintosh, Alabama
Mercury in Groundwater -10 ug/l Contours
Before and After Corrective Action
Note Contours are generalized for presentation purposes
- Before
m -Current

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Olin Corporation - Mcintosh, Alabama
Mercury in Groundwater - 2 ug/l Contours
Before and After Corrective Action
Note Contours are generalized (or presentaton purposes
-	Before
-	Current

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Figure 10
Time Series Plots
Corrective Action Pumping Wells
Mercury Concentrations, ug/l
Corrective Action Well 1
0.6
0.5
0.4
0.3
0.2
0.1
Jan-87 Jan-89 Jan-91 Jan-93
Corrective Action Well 2
50
40
30
20
10
0
Jar»-87 Jan-89 Jan-91 Jan-93

Corrective Action Well 3
12

10

8

"6
n t
4 „
v / \ ^ A. Jt
2

n



Jarv87 Jan-89 Jan-91 Jan-93

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Figure 11
Time Series Plots
Wells Illustrating Hg Associated with Dense Brine
Mercury Concentrations, ug/i
Shallow Wells	Deep Wells
Monitoring Well BR-7D
300
Jan-82 Jan-85 Jan-88 Jan-91 Jan-94
Monitoring Well BR-8
250
200
150
100
50
0
Jan-82 Jan-85 Jan-88 Jan-91 Jan-94
Monitoring Well BR-8D
300
250
200
150
100
50
0

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Figure 12
Time Series Plots
Wells Illustrating Change in 100 ug/l Contour
Mercury Concentrations, ug/l

Monitoring Well E-1
250
a
200
K
150
JVt
100
T \
50

A
• • ¦ V.	
U

Jarv87 Jan-89 Jan-91 Jan-93

Monitoring Well E-6
250

200
4 A
150
r M t
100
t aL
50

n

U


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Figure 13
Time Series Plots
Wells Illustrating Change in 10 ug/l Contour
Mercury Concentrations, ug/l
Monitoring Well PH-7
Jan-87 Jan-89 Jan-91 Jan-93
Monitoring Well PH-2D

Jan-87 Jan-89 Jan-91 Jan-93

Monitoring Well E-1
250
A
200
A
150
/ft
100
f \
50
jJ \ji
n
ti—mm
\J

Jan-87 Jan-89 Jan-91 Jan-93

Monitoring Well WP-3
250

200
I
150
A
100

50
A/W n

y si k
U
V '

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Biography
of
Bradley A. Jackson, Remedial Project Manager
U.S. Environmental Protection Agency
Waste Management Division
Education:
Bachelor of Science, Biology; University of West Florida, Pensacola, Florida; April 1983.
Work Experience:
U.S. Environmental Protection Agency, Region IV; Waste Management Division, South
Superfund Remedial Branch; November 1989 - Present. Duties include project management,
technical review, public relations, contract management, CERCLA enforcement activities.
NUS Corporation, Atlanta, GA; EPA Field Investigation Contractor;'January 1984 - November
1989. Duties included project management, CERCLA site inspections and reporting, site
evaluation for National Priorities List, staff supervision.
EPA Library Region 4
025
09


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SCALE
80 FEET
Delta Gas wen
Railroad Track
	 Fence
		 Fence Gale
Adiacent B smessei
Y///A Concrete Siructure
• Well Location
uw-n Monitoring Well IGenhhcation
Source: GCO Well Installation Plan, April 1990
FIGURE 2
MONITORING WELL LOCATIONS
GOLD COAST OIL SITE

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TOTAL VOC CONCENTRATION
MONITORING WELL NO. 13
GOLD COAST OIL SITE
CONCENTRATION (UG/L)

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An Abstract
Groundwater Remediation
of the
Gold Coast Oil Superfund Site
Miami, Florida
by
Bradley A. Jackson, Remedial Project Manager
U.S. Environmental Protection Agency
Waste Management Division
The cleanup of the Gold Coast Oil Site is truly one of tlu, success stories of the Superfund
program. The Site is the former location of a used-solvent reclamation facility located in Miami,
Florida. The Site overlies the Biscayne aquifer which is the sole source of drinking water for
the Miami area. The aquifer is composed primarily of sand, limestone, and sandstone. The
water table of the aquifer is only a few feet below ground surface, leaving the aquifer relatively
unprotected, and susceptible to contamination.
Following the closure of the facility, the following sources of contamination were identified at
the Site: 1) a storage area of approximately 2,500 corroded and leaking drums that contained
sludges from the solvent reclamation process, contaminated soil, and paint sludges; 2) 26
horizontal storage tanks containing hazardous substances; and 3) extensively contaminated surface
soils and contaminated groundwater. Numerous hazardous organic compounds and heavy metals
were detected in surface soils at the site with levels ranging up to the hundreds and thousands
of parts per million, respectively. The levels were well above acceptable health-based limits.
Groundwater contamination from hazardous organic compounds was also detected in a
60-foot-deep on-site well. Subsequent groundwater investigations confirmed the presence of
extensive groundwater contamination in the upper 50 to 60 feet of the aquifer. The contaminant
levels detected were also well above acceptable health-based standards.
Cleanup activities in 1982, 1989, and 1990, focused on removal of surface debris, bulk liquid
wastes, contaminated sludges and soils, and leaking drums. During these activities, five tank
truck loads of contaminated bulk liquids; 1,660 cubic yards of contaminated sludges and soils;
and 2,500 leaking drums were removed from this one and one-half acre site for proper disposal.
A groundwater treatment system began operation in June 1990 and has treated approximately
77,500,000 gallons of contaminated groundwater. Through these cleanup activities, soil
contamination has been reduced to within acceptable health-based levels and groundwater
contamination has been reduced to a level which is very close to achieving the cleanup standards

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\
INNER TIER i NT L UENT
EOU/NEU L
TANK j
C. >
SOD 1UM
HYDROX i DE
DAY TANK
J GRAVITY
i SE f1 AR AT GR j

sludge (
"ULtJ!".;	r
T ANK '
IEP
oEOHEtiC ! NG BATCH RE AC ! OR
( 5BR I
DECANT
:OLLECTION
TANK \
inner tier eefluent
TO tf 1 POLiSHINC POND
LARDOI-.
ADSORPTION
A I
:ripper
LEGEND
EOU= EOUAL IZA1 I ON
NEU = NEUTRAL IZAT I ON
- - - = SLUDGE
	 = GROUNDWATER
FI CURE 3
INNER TIER

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/
SOURCE MATERIALS
250		500
APPRO* IMA1E SCALE IN FEET
LEGENO
OT-1 -if~ OUTER TIER EXTRACTION WELL
I T-1
+
INNER TIER EXTRACTION WELL
FIGURE 1

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CERCLA Groundwater Remediation Project
Capture zones for the system are estimated from drawdowns in 8
monitor wells surrounding the inner tier. Typical drawdowns
range from one to five feet. Drawdowns measured in October, 1993
averaged 3.32 feet. These drawdowns indicate that the inner tier
system is capturing the contaminated groundwater at the source
area
The inner tier treatment; system was designed to treat the highly
contaminated groundwater from the inner tier area. The overall
effectiveness of the system is measured by volatile organic
compound and TOC concentration reductions.
Based on overall average influent and effluenu values, the inner
tier system has averaged a 94% reduction of targeted volatile
organic compounds, 99% of TIC volatile organics, and 93% of TOC
concentrations.	Targeted volatile organic concentrations
averaged 3 92 ug/'l in the influent and 22 ug/1 in the effluent
The average TIC volatile concentrations are 1619 ug/1 in the
influent and 16 ug/1 in the effluent. TOC concentrations
averaged 1,974 mg/1 in the influent 128 mg/1 in the effluent.
Operational Problems
Both the inner and outer tier systems have proven to be effective
and reliable m operation. The ::: ly ~a;cr problems encountered
were with the inner ti.er pumps and _ -iss 'jpsets in the SBR.
The original pumps in the inner ' . wells experienced severe
clogging problems due to iron pr- :: c :*. .at;on It was believed
that the pumping action was cans:.".} ' . rcr. to precipitate out.
The pumps were replaced in 1990 w:* • . lider pumps. Although the
bladder pumps have performed we). : : <* q-er.t replacement of the
bladders is necessary. Two-inch •* *. : . v submersible pumps are
currently being tested in two of	. r.r.er tier wells. To date
they appear to be providing reliable 1 r.i effective performance.
The sequencing batch reactor performed very well for the first
eight months of operation Starting in the ninth month, it began
to experience biomass upsets with increasing frequency. Within
several weeks, the upsets were occurring on a weekly basis. It
was originally thought that high levels of ethylene glycol in the

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CERCLA Groundwater Remediation Project
The 9 inner tier wells are located directly downgradient of the
source materials (Figure 1). They are installed in saprolite to
a total depth of 42.5 feet and are spaced on approximately 80
foot centers.
The inner tier wells are constructed of 2-inch stainless steel
casing with 10-foot stainless steel screens. Seven of the inner
tier wells use pneumatic bladder pumps and controls. Two-inch
electric submersible pumps are currently being tested in the two
other wells. The inner tier influent is transmitted below grade
in polypropylene piping to the treatment system.
The inner tier treatment units (Figure 3) include flow
equalization, iron removal, biological treatment in an activated
sludge Sequencing Batch Reactor (SBR), air stripping, and carbon
adsorption.
The inner tier influent is pumped to a 4500 gallon equalization
tank where sodium hydroxide is added in the tank to neutralize
pH. The groundwater is then pumped to a gravity separator where
iron precipitates out as a flocculate. Polymer is added at the
separator to improve separation. Sludge from the separator is
dewatered in a filter press and then disposed of ac an off-site
landfill.
Groundwater flows from the plate separator to the SBR. The SBR
uses an activated sludge biological process to remove organics
from the water. The operation is a batch process, where aeration
and settling, both occur in one vessel.
From the SBR, the biologically treated groundwater is pumped to a
30 gpm air stripping tower, and finally to an activated carbon
adsorption unit. The treated inner tier groundwater is also
discharged to the first polishing pond of the plant's wastewater
treatment plant.
SYSTEM OPERATION
Outer Tier
The primary goal of the outer tier extraction system is to
control further migration of the contaminated groundwater toward
the site perimeter. The system was designed to use the minimum

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CERCLA Groundwater Remediation Project
and semi-volatile organics, and metals in the groundwater
samples. Concentration ranges for selected chemical constituents
identified during the Remedial Investigation are provided in
Table 1.
The chemicals detected Ln the groundwater were similar to those
identified in the burn pit materials and process sludges that had
been buried at the site, indicating that these materials were the
likely source of the groundwater contamination. Groundwater
contamination was higher in samples collected adjacent to the
burn pit area, and lower or below the detection limit near the
downgradient site perimeter. Site related contamination were not
detected in samples collected from the off-site wells.
The Remedial Investigation for the site identified the need for
two operable units at the site. Operable Unit 1 (OU-1) addressed
the stabilization and remediation of contaminated groundwater at
the site. The Feasibility Study and Record of Decision for OU-1
were issued in 198S. The OU-1 Remedial Design and Remedial
Action, which are the primary topics of this paper, were
completed in 1989.
Operable Unit 2 addressed the remediation of the source materials
and contaminated stream sediments. The remedy consisted of
excavation and treatment of the burn pit materials, process
sludges, and-stream sediments. The burn pit materials and stream
sediments were solidified with Portland cement. The process
sludges were incinerated on-site, and the residual ash
solidified. All stabilized materials were then buried back in
the original excavation. The Operable Unit 2 Remedial Action was
completed in September, 1992.
SYSTEM DESIGN AND CONSTRUCTION
The objectives for the OU-1 remediation as defined in the
Remedial Design Report were to (1) control further migration of
the contaminated groundwater toward the site perimeter, and (2)
remove contaminated groundwater for subsequent treatment and
discharge. To accomplish this, two separate extraction and
treatment systems were designed. The first system, called the
outer tier, was designed to capture and treat the groundwater at

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CERCLA Groundwater Remediation Project
Glenn G. Boylan, P.E.
Everett W. Glover, P.E.
Brian P. Anders, E.I.T.
ABSTRACT
A CERCLA groundwater extraction and treatment project has been
completed at an industrial facility in Region IV. The two
primary objectives of the project were stabilization and
remediation of the contaminated groundwater.	The CERCLA
Five-Year Review has just been completed for the site, and shows
that the groundwater at the site has been stabilized and the
treatment system is effectively removing organic compounds from
the groundwater.
The project involved the design and construction of two
extraction and treatment systems. The first system, called the""
outer tier, was designed to stabilize the groundwater at the
downgradient property line to prevent migration off-site. The'
groundwater captured by the outer rJ =>r has relatively low
concentrations of contaminants and is treated by air stripping
and carbon adsorption.
The second system, or inner tier system, was designed to capture
the more highly contaminated groundwater just downgradient of the
buried source materials. The treatment for the inner tier water
consists of a combination of physical, chemical, and biological
processes.
The systems have proven to be reliable. The only significant
problem encountered to date has been recurring biomass upsets in
the biological reactor. This problem was solved by minor changes
to the sludge wasting rate.
Physical and chemical data monitored for both systems show that
the remedial goals are being met. The outer tier wells are
creating a hydraulic barrier to groundwater flow, keeping the
contamination on-site. The inner tier wells are capturing the
highly contaminated groundwater at the source, and the inner tier

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THOMAS F. SCIPLE is Environmental Supervisor with Ciba-Geigy
Corporation (Ciba) in Mcintosh, Alabama, where he is responsible
for permit and permit compliance in air, water and solid waste
areas. Mr. Sciple has been employed with Ciba for 25 years; of
which 22 years have been in the Environmental Field with
experience in Research, Development, Operations, Regulatory and
Legal. Mr. Sciple is a member of various Air, Water and Waste
Management Associations including Chemical Manufacturing
Association's (CMA) Ground Water Task Group, Synthetic Organic
Chemical Manufacturing Association (SOCMA), AlaChem Association,
The Business Council of Alabama, Alabama's Air Toxic Advisory
Committee, Alabama's Waste Minimization Advisory Committee,
Alabama's Clean Air Act Implementation Committee, Alabama's
Comprehensive Ground Water Program Advisory Committee and The
Alabama Emergency Management Commission.
PATRICK D. HALLETT is an Environmental Associate with Ciba in
Mcintosh, Alabama, where he provides technical and management
support for the RCRA groundwater management program and other
environmental management issues. Mr. Hallett has worked in the
environmental field since 1981 and has been involved with RCRA

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GROUND WATER REMEDIATION ACTIVITIES AT
THE CIBA MCINTOSH, ALABAMA SITE
Presented by Patrick D. Hallett
Environmental Associate, Mcintosh Site
Facility History
The Mcintosh facility, formerly owned by Geigy Chemical Corporation, began
operations in October 1952, with the manufacture of one product. Through 1970,
Geigy expanded its Mcintosh facilities by adding the production of herbicides,
insecticides, agricultural chelating agents, sequestering agents for industry and
fluorescent brighteners used in laundry products.
In 1970, Geigy merged with Ciba (Chemical Industry in Basel, Switzerland),
forming the CIBA-GEIGY Corporation (Ciba). Since then Ciba has continued to
expand its operations with the production of resins and additives used in the
plastics industry and small volume specialty chemical products (i.e. water
treatment chemicals and fire fighting foams). The present facility occupies
approximately 1,500 acres and employs around 1,200 workers.
Site Location and Topography
The Ciba plant is located approximately 50 miles north of Mobile in southern
Washington County northeast of Mcintosh, Alabama. The developed plant site is
situated between the Southern Railroad nght-of way on the west and extends
nearly to the escarpment separating the upland terrace from the floodplain of the
Tombigbee River. The property boundary's »?xtend beyond the railroad westward
toward U.S. Highway 43. The northern ~jiVjo of the property merges into a pine
forest and to the south, the property is hounded by Olin Corporation. The
southeastern portion of the Ciba property extends to the banks of the Tombigbee
River. The nearest population center to the site is the Town of Mcintosh, which is
located approximately two miles to the southwest.
The Ciba facility is located in the Southern Pine Hills District of the East Gulf
Coastal Plain Physiographic Province and s north of and on the western margin of
the Mobile-Tensaw River Delta. The Ciba facility is situated on a low terrace
adjacent to the Tombigbee River Floodplam. Trie well-developed floodplain in the
vicinity of the site is characterized by broad meanders and oxbow lakes.
Corrective Action Background
The EPA Region IV conducted an investigation in the late 1970's and early
1980's of the Ciba site. As part of the investigation, EPA sampled water wells on
the Ciba property. The sampling indicated the presence of Lindane in one well

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sample. As a result of this information and supplemental data from surface water
and soils samples, the Ciba Mcintosh site was included on the National Priorities
List (NPL) in September 1983.
Ciba established a ground water monitoring program in 1981 in response to
the then, new, RCRA regulations. The monitoring indicated the presence of ground
water contamination in the alluvial aquifer. Ciba contracted the services of a
consultant to conduct a series of studies investigating ground water quality and
aquifer characteristics. Those efforts resulted in the formulation of the ground
water corrective action program which focuses on hydraulic control of the alluvial
aquifer and source removal or control. In October 1985, EPA issued Ciba a RCRA
Permit, which included a Corrective Action Plan prepared by Ciba proposing to
install a series of pumping wells to form a hydraulic barrier at the site. The
interceptor well system began operating in late 1987.
The Corrective Action Plan also included provisions for a Site Investigation
(i.e., Remedial Investigation/Feasibility Study) to identify and characterize past
disposal areas that may act as sources of ground water contamination. Other
elements of corrective action included closing RCRA permitted hazardous waste
management facilities that may have contributed to environmental contamination.
These RCRA facilities included surface water impoundments used to treat or store
wastewater or sludge, as well as two landfills. The RI/FS, driven by both RCRA and
CERCLA authority, subsequently identified fcleven additional past disposal sites in
the upland area of the Ciba property. The contaminants associated with these past
disposal sites include pesticide residues, by-products and intermediates from
pesticide manufacturing. One objective of the RI/FS is source removal or control to
eliminate the continuing contribution of contaminants to the alluvial aquifer. This
task is currently in the Remedial Design phase and is being handled as a CERCLA
activity.
Geology and Hvdroaeoloav
Southwestern Washington County is underlain by recent alluvium,
Pleistocene age low terrace deposits and sediments comprising the Miocene Series
Undifferentiated. These strata consist of alternating deposits of sand, clay, silt and
gravelly sand. A nearly continuous surficial clay layer is underlain by deposits of
silt, sand, gravel and clay. The surficial clay layer ranges in thickness from a few
feet to over 50 feet. The contact with the underlying sand is characterized by
sandy clay, sand and small caliber gravel. These Pleistocene age deposits range in
thickness from.60 to approximately 100 feet. The Pleistocene deposits
uncomformably overlie more than 700 feet of alternating layers of Miocene age
sand, gravel and clay. The Upper Miocene clay, with a thickness ranging from
approximately 30 feet to over 100 feet at the site, acts as an effective aquitard
between the alluvial aquifer and the Miocene aquifer system.
Ground water is found in the semi-confined alluvial aquifer approximately 35
feet below land surface. Ground water is available from three aquifer systems:

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(1)	- The Recent and Pleistocene terrace and alluvial deposits present under
semi-confined conditions;
(2)	- The underlying sand and gravel deposits of Upper Miocene age (Upper
Miocene aquifer) under locally confined conditions; and,
(3)	- The highly mineralized Lower Miocene aquifer (Miocene aquifer) under
confined conditions.
The shallow alluvial aquifer is separated from the Upper Miocene aquifer by a
clay aquitard with a measured permeability of 10"8 cm/sec. This aquitard has been
shown through pumping tests to be an effective barrier to the contaminated alluvial
aquifer at the site. Periodic sampling of the Miocene aquifer has not indicated
contamination.
The water table in the Alluvial aquifer normally slopes gently south-southeast
towards the Tombigbee River. This natural pattern is modified in some portions of
the plant site by the pumping of plant water supplies and recharge from the river
water reservoir. In addition, the Ground Water Corrective Action Program has
produced a dynamic water surface which has reversed the natural ground water
flow patterns along the southern portion of the site.
Interceptor Well System
A groundwater interceptor well system was installed at the site following
extensive hydrogeologic investigations and numerical modelling. The interceptor
well system consists of ten extraction wells located along the southern tier of the
Ciba property. The wells were initially designed to pump approximately 2.3 MM
gallons of groundwater daily, with individual pumping rates ranging from 50 gallons
per minute (gpm) to 450 gpm. The well system currently removes approximately
1.4 MM gallons~per day with individual pumping rates ranging from 50 gpm to
approximately 185 gpm. The ground water is then conveyed to the on-site
wastewater treatment facility where it is treated in the activated sludge system
prior to being discharged to the Tombigbee River through the site's permitted
NPDES discharge point.
The natural flow direction of the ailuvial aquifer is to the south-south east, as
is illustrated in the water surface map constructed in 1987, prior to initiating
pumping. Utilizing data derived from pumping tests, our consultants (P.E.
LaMoreaux and Associates) produced a numerical model of the configuration of the
alluvial aquifer at various pumping rates and simulated the areal extent of draw
down. A water surface map was produced after the interceptor system was in
operation. The map clearly illustrates the effectiveness of the system in capturing
the ground water in the alluvial aquifer in the portion of the property south of the
waste management areas. Surface water maps depicting the reversal of the
hydraulic gradient are produced semi-annually and provided to the State and EPA.

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As noted above, the pumping rates of the individual wells and the overall
system have been adjusted since the system began operating in late 1987. The
reduced pumping is the result of adjusting the system to minimize pumping volume
while ensuring the reversal of the hydraulic gradient. In several instances, such as
well PW-9, the pumping capacity is impacted by the presence of iron precipitating
bacteria. The predominant iron bacteria is the genera of Leptothrix . Persistent bio-
clogging reduces the yield and has resulted in the need for frequent well
maintenance to ensure sufficient yield to maintain a reversal of the hydraulic
gradient.
A well treatment involves the addition of acids and recirculating the acidified
column water. A treatment may take two or three days. The treatment typically
includes the following steps:
-	Removing the pump and noting the column pipe condition;
-	Adding muriatic acid (hydrochloric acid), (approximately 60 gallons);
-	Adding hydroxyacetic acid, (approximately 2 gallons);
-	Circulating the acid mixture in the well with a submersible pump for
approximately 2 hours;
-	Repeating the process in the afternoon;
-	Allowing the acid mixture to sit undisturbed overnight;
-	Repeating the process a second day and re-installing the pump on the third
day.
The treatment schedule varies by wen. Two wells require an abbreviated
one-day treatment quarterly, while the remaining eight wells require treatment on a
semi-annual basis.
Annual maintenance costs for the well treatment currently are approximately
$250,000.00.
Ground Water Quality
The Ground Water Protection Standard for the Ciba site was negotiated in
1985 based on ground water quality data gathered since 1981. The Standard is
composed of the "Primary Drinking Water Standards", "indicator parameters" and
25 additional compounds identified through analysis of 40 CFR 261, Appendix VIII
constituents. Of this list, 14 constituents comprise the predominant set of alluvial
aquifer contaminants. Since the ground water interceptor system began operation
in late 1987, the concentrations of all the listed contaminants have been

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substantially reduced. The initial list of 29 constituents detected above background
in the wells has been reduced to less than ten. Nonetheless, the Ground Water
Protection Standard has not yet been achieved in the Compliance wells located
downgradient of the waste management units that have most likely contributed to
the ground water contamination.
Ciba prepares time-trend graphs of selected constituents to track the
progress of the corrective action on ground water quality. It is clear from these
graphs of the indicator parameters (i.e., specific conductance and TOX) and alpha-
BHC that the concentrations in the ground water have been substantially reduced
since the surface impoundments were closed in 1988 and 1989. In general, the
trend continues to indicate a reduction in contaminant concentrations but at a
much more gentle slope. The on-going remedial activities, focusing on source
removal or control, is expected to result in further reductions in contaminant
concentrations. These activities are scheduled to move into the Remedial Action
phase in 1996.

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Figure 14
Time Series Plots
Wells Illustrating Change in 2 ug/l Contour
Mercury Concentrations, ug/i
Monitoring Well WE-3
Jan-87 Jan-89 Jarv-91 Jan-93

Monitoring Well E-3
8

6


4
1

2~


r\
i

Jan-87
Jan-89 Jarv91 Jan-93
Monitoring Well E-1
250

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RADIATOR SPECIALTY COMPANY
GROUNDWATER ASSESSMENT and INTERIM REMEDIATION PROGRAM
by
Richard L. Harmon, P.G., and Chris Cutler
ABSTRACT
The Radiator Specialty Company (RSC) Indian Trail, North Carolina Facility is located in the
contact zone between the Carolina Slate Belt, and the Charlotte Belt, within the Piedmont
Physiographic Province in which groundwater flow is fracture controlled. RSC has recently
completed Phase V of an on-going groundwater assessment program, and submitted Addendum
8 to the Facility's Post Closure Permit Application. Concurrent to these activities, RSC is in
the process of implementing an interim groundwater recovery and pretreatment system. This
system includes four (4) recovery wells, an extensive header pipe system, and packed air
stripping tower. Effluent from the system is discharged to the Union County POTW.
INTRODUCTION
At the Indian Trail, North Carolina facility, Radiator Specialty Company (RSC) manages three
(3) distinct operational divisions. These Divisions consist of the manufacturing of household
and automotive chemical products, hose packaging and the distribution of RSC product lines
worldwide. The Chemical Production Division blends aftermarket automotive chemicals in a
variety of consumer packages. The CRP Hose division packages a myriad of hoses for
numerous applications. The Distribution Division ships finished goods to customers
worldwide.
This facility was constructed in 1971 on approximately 180 acres of wooded farm land within
a rural community south of Charlotte, North Carolina. Since it's opening, this facility has
grown to currently employ over 270 people.
Regulated Units
Resource Conservation and Recovery Act (RCRA)
In August 1987, the North Carolina Department of Human Resources (since combined
into the North Carolina Department of Environment, Health and Natural Resources)
approved a revised Closure Plan for closing the two (2) surface impoundments located
on the east side of the site. This plan as implemented included removing the liquid and
sludge from these impoundments for transport via railroad tank cars to the DuPont
Chamber Works in Deepwater, New Jersey for disposal. Once this material was
removed from the site the impoundments were capped with clay and seeded with grass.
In January 1989, RSC submitted a Post-Closure Permit Application to the State
regulatory authority. In conjunction with the RCRA permitting activities, RSC initiated
a Groundwater Assessment Program to delineate the extent of the contaminated
groundwater on-site.

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Solid Waste Management Units (SWMUs)
On October 17, 1989, NUS Corporation under contract to the EPA issued the Final
Environmental Priorities Initiative Preliminary Assessment of Radiator Specialty
Company Indian Trail facility. In this report, NUS defined eight (8) Solid Waste
Management Units (SWMUs). These units included: the two (2) RCRA regulated
closed impoundments; the product mixing/recycling units; the tank farm; the product
transfer line pad; the solid waste container; the solid waste compactor; and the product
transfer pump pad. Of these eight (8) units, two (2) are currently regulated by the
Resources Conservation and Recovery Act (RCRA), and six (6) were recommended for
no further action. This NUS report specified additional assessment activities at only the
following two (2) of these units; the tank farm and the transfer line pad. While the tank
farm is listed as one (1) unit by NUS, this unit consists of two (2) above ground tank
farms (Tank Farms A and B), and one (1) former underground storage tank (UST) farm
(Tank Farm C).
Based on this report, RSC proceeded with facility improvements including installation
of a covered dumpster area, a covered product transfer pump pad, installation of a vapor
extraction system within Tank Farm B and excavation and removal of contaminated soil
adjacent to the transfer line pad. Additionally, RSC has replaced all the in-ground
piping with overhead systems, and constructed a covered truck unloading area.
As a result of these activities, the EPA has removed the dumpster area (i.e the solid
waste container and the solid waste compactor) and the product transfer pump pad from
the SWMU list. Due to the close proximity of the five (5) remaining units, RSC is
currently assessing and remediating these areas simultaneously.
Regional Geology
The RSC site is located along the boundary between two geologic belts within the Piedmont
Physiographic Province. These two (2) units consist of the Carolina Slate Belt (CSB) to the
east; and the Charlotte Belt to the west. The Piedmont Province generally consists of a
northeast/southwest trending region extending southward from the Hudson River in New York
to Alabama. The Piedmont topography is typically described as a slightly elevated region with
low to moderate relief, generally dissected with valleys created by streams flowing on rocks
of varying erosional resistance. Ridges and up-lands have been developed by slower
weathering of more resistant rock types. Most rock types in this region are covered by thick
residual soil; however, thin weathered zones are not uncommon. Soil typical of this region was
generally developed through the in-situ weathering of fractured and faulty rock structures
(Thornburg, 1965).

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Carolina Slate Belt
The CSB is generally described as consisting of low-rank metamorphosed volcanic and
sedimentary rocks, situated in the east-central portion of the Piedmont of North
Carolina. Where Coastal Plain sediments overlap it to the east and the Charlotte Belt,
consisting of higher rank metamorphic and igneous rocks, borders it to the west.
Rocks comprising the CSB consist primarily of laminated and non-laminated
metamorphosed pelitic rocks. Rock color varies from bluish-gray when fresh, to brown
and reddish-orange when weathered. When present, laminated bedding planes are
typically well developed and exhibit bedding plane cleavage. Igneous intrusions have
been observed throughout the Belt. These intrusions are typically comprised of diabase
and metagabbro. The diabase occurs most commonly as dikes. General mineralogy is
plagioclase, clinopyroxene, and chlorite, with biotite and quartz occurring as void
fillings. The metagabbro is generally xenoblastic, but abundant sericite and epidote
obscure structure and mineralogy (Randazzo, 1972).
Quartz veins are present throughout the CSB. These veins (i.e. dikes and sills) are
typically intruded into fractures in the country rock. Large muscovite flakes are
commonly seen along these intrusions, possible indicating recrystallization of country
rock during time of intrusion. Quartz is usually milky in appearance (Randazzo, 1972).
A major structural feature of the CSB is the Gold Hill Shear Zone. The Gold Hill Shear
Zone is thought to be a thrust fault generally described as trending north fifteen (15)
degrees east, and extending southward from near Southmont, Davidson County, North
Carolina to the eastern edge of Indian Trail, North Carolina. Previous studies indicate
the rocks along the western margin of this Shear Zone are characterized by higher
ranking metamorphism, including the occurrence of both slate and phyllite. Local fault
planes, quartz veins and minor joints are also commonly associated with this major
Shear Zone trend (Randazzo, 1972; The Geologic Map of North Carolina, 1985).
Charlotte Belt
The neighboring Charlotte Belt is described as metamorphosed diorite, grandodiorite,
and tonalite intruded by gabbro, granite, diabase, syenite,and quartz batholiths, dikes
and sills. Each rock unit is generally massive with weak foliation. Most units grade
from one rock type to another over distances often ten feet to a few miles. Sharp
contacts are rare except along perimeters of intrusions where banding and contact
metamorphism may be observed (Randazzo, 1972). The Charlotte Belt is generally
described as a granite/diorite complex. Relationships of the granite and diorite in
complexes of this nature are obscure. Many areas in the Charlotte Belt suggest granite
has intruded the diorite, while at others the diorite appears to have intruded the granite.
The mineralogy of granite and diorite are essentially the same. They include three (3)
-»

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major rock-forming components: quartz (silica), feldspar (potassium, sodium, calcium
and aluminum), hornblende, and/or biotite (iron and magnesium). The different rock
types are identified by the percentages of quartz relative to other felsic minerals.
Granite contains 20 percent to 60 percent quartz while diorite contains less than 10
percent. Due to the similar mineralogical make-up of the parent rock, soil development
for the two are nearly identical (Stucky and Steel, 1953).
Site Specific Geology
Numerous subsurface investigations have been performed at the facility. These investigations
indicate the study area lies near the contact between the CSB and the Charlotte Belt. Test
borings indicate the site is generally underlain by two distinct separate rock types, phyllite and
diorite. Data suggest that the phyllite was intruded by the diorite, with evidence of possible
contact metamorphism exhibited in rock cores from various wells on-site. Similar orientation
of the fractures in both the phyllite and the diorite suggest a tectonic relationship with major
known structure trends (i.e. the Gold Hill Shear Zone).
Due to the hydrogeologic similarities between the phyllite and the diorite, the site has been
classified into three (3) hydrogeologic units. These units consist of saprolite. partially weather
rock (PWR), and bedrock.
The saprolite has been defined as material which could be bored with conventional hollow-stem
augers and exhibited less than 100 blows per foot, using the Standard Penetration Resistance
Test as described in ASTM D 1586. The saprolite consisted primarily of silty clay and ranged
in thickness from approximately 2.5-feet to approximately 25-feet across the site. Some silty
fine sand lenses were encountered within this material; however, they appear to be non-
continuous and merely an in-situ weathered product of mineralogical or grain size variations
in the parent rock.
The material encountered beneath the soil horizons was typically referred to as partially
weathered rock (PWR). PWR is a geotechnical engineering classification for material which
exceeds 100 blows per foot using Standard Penetration Testing procedure as described in
ASTM D 1586. For the purposes of this investigation, the base of this material has been
defined as hard, fresh to slightly weathered competent rock. The PWR encountered on-site is
mineralogically similar to the soil mantle; yet generally rock fragments, boulders, rock layers,
etc. are more prevalent due to lesser exposure to chemical and mechanical weathering effects.
The thickness of PWR observed from 8-feet to approximately 43-feet.
For the purposes of this investigation, bedrock has been defined as competent rock, described
as hard, fresh to slightly weathered. The bedrock underlying the PWR, is a hard, slightly
weathered to fresh laminated phyllite and diorite. The phyllite encountered typically exhibits
bedding planes of approximately 0.125-inches in thickness with a dip of approximately 75°.
Phyllite is typically defined as argillaceous rock intermediate in the metamorphic grade

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between a slate and a schist. Phyllite is typically differentiated from other argillites in the field
by its silky sheen observed along the cleavage planes imparted by the mica crystals. This unit
also exhibited two (2) sets of fractured joints: which include a slightly more predominant
subvertical set with dips of approximately 60° to 75°, and a subhorizontal set of fractures with
dips of approximately 0° to 20°. The subvertical fracture set appeared to parallel the bedding
planes of the formation.
The diorite component of the bedrock is a hard, slightly weathered aphanitic to phaneritic
diorite, typically possessing three (3) poorly developed fracture joint sets. These fracture joint
sets consist of: 1) a closely spaced, sub-horizontal fracture set with dips of approximately 10°
to 20°; 2) a closely spaced, sub-vertical fracture set with dips of approximately 30° to 60°; and
3) a less predominant vertical fracture set with dips of approximately 80°.
A fracture trend analysis conducted at the site indicates that both the phyllite and diorite units
mapped on-site are highly fractured. Figures 2-1 and 2-2 present both a revised Joint Rose and
a Contoured Stereo Net of 165 fracture sets mapped in the study area. Steep angle fracturing
was observed in both geologic units with less than 2 percent of the total of 165 points
expressing dips of less than 28°. Five (5) minor joint sets were observed in the stereo-net.
These sets each contained greater than 8 percent of the total. These five (5) sets are as
follows:
N10E78NW	N20E80NW
N40W80SW	N24W82NE
N36W84NE
These joint sets appear to correlate fairly well with two of the three fracture set dip angles
observed in the core samples collected across the study area.
AQUIFER DESCRIPTION
The aquifer underlying the study area is typical of the composite weathered residuum-
crystalline fractured rock aquifers located within the Piedmont region of North Carolina. The
aquifer is unconfined, existing under phreatic, or water table conditions. Under these
conditions, the water table surface is in equilibrium with atmospheric pressure and is not
confined by low-permeable layers between the surface of the water table and the surface of the
ground. Groundwater under water table conditions is typically recharged by direct infiltration
from precipitation. This water flows through the pore spaces of the geologic media to its
ultimate discharge in topographic low regions where the water table surface intersects the
surface of the ground. As a result of these typical flow patterns, the potentiometric (water
table) surface expressed by water table aquifers typically appears as a subdued replica of the
land surface topography.

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NUMBER OF LINEATIONS = 165
AZIMUTH INTERVAL = 10°
ORIENTATION OF JOINTS IN OUTCROP NEAR RSC
eject:
Radiator Specialty Co,
Indian Trail, NC
Title:
Join":
\C s e
Job:
Figure:
2-1
_L
ca.e:
MTS
PO Ba* *>087
Rtieign. nC
Triangle
Environmental goo-wt-siis

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LEGEND
CONTOURED STEREO NET
0% - 1.5%
1.5% - 5%
[7
/
5% - 8%
>8%
TOTAL 165 LINEATIONS
oject:
Radiator Specialty Co.
Indian Trail, NC
Title:
Steieo Net
Job: 1
Figure:
2-2
Scale:
NTS
?0 Bo* *<087
_	Biiexjn. nC 27629
Triangle	9i9-476-$us
EiwIROHMSHTAL 300-3*9-5115
!nc	
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Figure 2-3 presents a map of the potentiometrifc surface underlying the study area. This map
was generated from water table elevations collected on September 14, 1993 from monitoring
wells in which the well screen interval intersects or very nearly intersects the water table
surface. This map suggests that the shallow groundwater within the study area flows radially
away from the location of the former impouncjments.
Assessment Activities to Date
Since initiating assessment activities in 1989 REC has completed five (5) extensive phases of
the groundwater investigation. These combined! assessment activities included the construction
of 60 monitoring and/or interim recovery wells tanging in depth from 15 feet to 500 feet below
grade. During these activities, approximately 90 discrete aquifer zones were sampled to
characterize the groundwater chemistry.
Numerous innovative methods were employed in sampling these zones including discrete zone
packer testing, temporary well point construction and permanent Type II and Type III
monitoring wells. Specialty Type III monitorimg wells were designed and constructed using
as many as six (6) strings of casing installed in|a telescopic manner. Auger, core, mud-rotary
and air rotary drilling technologies were utilized [throughout various phases of this groundwater
assessment.
All drill cuttings, drilling muds and formation Waters generated during assessment activities
were contained and sampled. Based on analytical results RSC either recycled these materials
into existing product lines or shipped them off-site for proper disposal.
Remediation Activities To Date
To date RSC has implemented four (4) ongoing remedial systems. Two (2) vapor extraction
systems were installed to remediate SWMU regulated soil contamination. RSC is also
recovering non-aqueous phase liquid (NAPL) from Tank Farm C and recycling this material
into various product lines.
Additionally, RSC has constructed and is in the process of implementing an interim
groundwater recovery and treatment system. This system consists of four (4) interim recovery
wells located along the primary fracture set. Pumps within these wells are connected via
double-walled header piping to a pretreatment system constructed on-site. Due to potential
variations inherent to operation of an interim system, RSC has designed a piping network
which may be readily altered. This system consists of a series of manholes and vaults
connected with large diameter PVC pipe. Numerous smaller diameter header pipes may be fed
through these conduits to accommodate increased flow from existing or new recovery wells.

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x>
\
Sewer Line
l. MP"
^
-t-
\\
v
\ ,
/
o6^
.X\ * i
V- \ ' ,664.82
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Legend
Direction of Shallow Component of
Groundwater Flow
Water Table Potentiometric Contour
(Sept. 14, 1993)
$ Monitoring Well
& Recovery Well
ojoct:	j^e: Water Table
Radiator Specialty Co. f 1 T>ot-p>jitjLQjnetric Map
Indian Trail, NC	! Job:
Figure:
2-3
Scale:
1"=200'
Tkt/wcta
PO. So* *108J
gjjngft. NC 27639
91+476-SIIS
aEwoonauntal gooat+siis
1U !nc

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The header pipes from the entire recovery system feed an equalization tank where the
recovered water is homogenized prior to pretreatment. From the equalization tank the
homogenized water is pumped through a packed air stripping tower and discharged to the
municipal sewer system.
The recovery/pretreatment system is operated from a central control panel. From this location
RSC personnel can monitor the entire system. In the event of an inner header piping leak, low
water level in any recovery well, or pretreatment system failure, the entire system automatically
shuts down and RSC personnel are notified by visual and audible alarms. In addition to
automated failsafes RSC personnel visually inspects the entire system daily.
Discharge Permitting
After pretreatment, the water is discharged to Union County's Publicly Owned Treatment
Works (POTW). In 1991, RSC in association with Union County, and the North Carolina
Division of Environmental Management (DEM) negotiated a pretreatment permit for the
discharge of 90,000 gallons of pretreated water per day with effluent monitoring, and control
limitations.
Regulatory Status
RSC has recently completed Phase V of the groundwater assessment program and Addendum
8 to the facility's Post Closure Permit Application. Pending approval of the Permit, RSC will
continue with the groundwater remediation associated with the RCRA regulated groundwater
plume in addition to assessing and remediating the SWMU related groundwater contamination.

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REFERENCES
ASTM, 1990, Annual Book of ASTM Standards. Vol. 04.08, American Society of Testing and
Materials
North Carolina Geologic Survey, 1985, "Geologic Map of North Carolina".
Randazzo, F., 1972, Petrography and Stratigraphy of the Carolina Slate Belt, Union
County, North Carolina, pp. 2-32.
Stuckey and Steel, 1953, Geology and Mineral Resources of North Carolina, 35 p.

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Christopher C. Cutler
Radiator Specialty Company
600 Radiator Road
Matthews, NC 28105
Chris Cutler is currently employed with Radiator Specialty Company as Environmental
Supervisor. Chris received a B.S. from East Carolina University in Greenville, North
Carolina and is currently pursuing a M.B.A. at Queens College in Charlotte, North
Carolina. While at RSC Chris has assisted in the development and implementation of
numerous industrial compliance activities.
Richard L. Harmon, P.G.
Triangle Environmental, Inc.
4201-J Stuart Andrew Blvd.
Charlotte, NC 28217
Rick Harmon is currently employed with Triangle Environmental, Inc. as a Senior
Hydrogeologist. Rick received a B.A. in Geology from Humboldt State University in
California, and is currently practicing as a licensed geologist in the State of North Carolina
and Delaware with over 9 years experience in hydrogeological site assessments in
conjunction with RCRA, CERCLA and UST regulations. Specific tasks include the design
and implementation of numerous site assessment projects including the use of fracture trace
studies, specialized monitoring well designs, various methods of discrete zone sampling,
and aquifer testing including constant head permeability tests, constant discharge pumping

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ABSTRACT
Title: "Sanders Lead Company, Inc., Recovery/Re-use Program for
Inorganic Contaminated Ground Water"
Presented To: EPA/Region IV Conference
In 1988 Sanders Lead Company initiated actions due to RCRA
requirements to identify any constituents of concern (COC's).
at Sanders7 Troy secondary lead smelter. Lead is recovered at
Sanders' secondary smelter from lead-acid batteries and sold
back into lead consuming industries.
Due to past battery breaking methodologies, acid, contaminated
with lead and cadmium leached into soil at the Troy location and
created a plume which was confined to an upper sandy/clay. This
geological area (upper zone) was not a ground water use zone, but
the plume did present a future concern to other sources if
migration was allowed to continue. All waste units were closed,
and through RCRA Permit Conditions, a well recovery program with
monitoring well network was designed, placed, and the plume was
defined. Recovery wells were installed and in 1990 ground water
was recovered at a yield rate of one gallon per minute per ten
(10) units. This water is then re-used in non-potable areas,
contained, treated and discharged to the local POTW.
Data from 1989 through 1993 demonstrates plume management and
control. Details of the automatic system are presented in the

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NOTE
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CONCENTRATION ISOPLETH MAP
UPPER AQUIFER TOTAL LEAD
COMPARISON OF FIRST QUARTER
1989 AND FIRST QUARTER 1993
(SmIm)
SANDERS LEAD CO. INC.
mOY. ALABAMA
SCALE. 1" =¦ 400'	|**ALW
PREPARED BY:
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CONCENTRATION ISOPLETH MAP
UPPER AQUIFER TOTAL CADMIUM
COMPARISON OF FIRST QUARTER
1989 AND FIRST QUARTER 1993
SANDERS LEAD CO.. INC.
TROY, ALABAMA
SCALE. 1" - 400'
'Atwl-fratl'
PREPARED BY:

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MANHOLE VAULT
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SEE DETAIL 8
DETAIL A
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DETAIL B
LINER CONNECTION DETAIL

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©ELECTRICAL TRENCH DETAIL
FOR CONCRETE SUB

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-EXISTING GROUND
SURFACE
ELECTRICAL CONDUIT
(NUMBER AND SIZE AS REQUIRED
FOR 230V ELECTRICAL SERVICE
TO WELL VAULTS)
CONCRETE
CONOUIT
SUPPORT
|-a 4"—j | ¦ 4*—j | ¦ 4*—»j
ELECTRICAL CONDUIT
i\TRENCH CONSTRUCTION DETAILS
TO FOR NON—TRAFFIC AREAS

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TICHT JOINT
/Tnpipe connection at detention tank
V37 AND EMERGENCY HOLDING TANK

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to wwm «*n HCfcfiff* UM.
PLAN
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OF EXISTING CONCRETE SLAB

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TRENCH CONSTRUCTION DETAIL FOR
DISCHARGE FROM CORRECTIVE ACTION WELLS
CA-1, CA—3, CA-4

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-EXISTING GROUND SURFACE

4" PVC SECONDARY CONTAINMENT-
1PE (WHERE REQUIRED)
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COMPACTCD'
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i_

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V^J CORRECTIVE ACTION WELL

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SANDERS LEAD COMPANY, INC.
GROUND WATER RECOVERY PRESENTATION
Presenters: 1) E. Roy Baggett, B.S., M.S., Manager of Environmental
Affairs, Sanders Lead Company, Wiley Sanders Truck Lines, KW
Plastics, Troy, Alabama and KW Plastics, Bakersfield, California
Mr. Baggett has since 1970 been employed in the Environmental
Management field. From 1970 through 1972 Mr. Baggett worked under
an EPA Region IV, Solid Waste Management Act Grant; 1972-1978, Mr.
Baggett worked with the State of Georgia EPA as an inspector and
emergency response coordinator. 1978-1982 - Mr. Baggett worked as
a consultant for various hazardous waste projects. 1982-1988 -
Mr. Baggett was employed in his own private consulting business.
In 1988 to present he came to Sanders Lead as a RCRA Part B
Coordinator and in 1989 was made Manager of Environmental Affairs.
In his twenty three year career, Mr. Baggett has worked with over
250 emergency responses. He has worked with numerous industrial
processes and has sought and obtained numerous operating permits.
At Sanders, a Part B has been issued, along with HSWA attachments
and the corrective action program with over 60 monitoring wells.
Since 1988 data from Sanders Corrective Action Program has
demonstrated plume capture and management.
2) J. Chris Rutherford, Project Coordinator, Sanders Lead Company
Mr. Rutherford graduated in 1987 with a Bachelor of Science degree
while concentrating his studies in the fields of Geology and
Biology. Since 1988 Mr. Rutherford has been employed in the
environmental management and consulting area. From 1988 to 1990,
Mr. Rutherford worked for OGDEN Environmental and Energy Services
Company as~ a site project manager for several environmental
investigations and remediation projects. From 1990 to the
present Mr. Rutherford has worked for Sanders Lead Company as an
environmental project coordinator and hydrogeologist.
3) Mark Hobbs, Branch Manager, OGDEN Environmental and Energy
Services Company
Mr. Hobbs obtained a Bachelor of Science degree from the
University of South Carolina in 1985. Since 1985 Mr. Hobbs has
been employed in the environmental management and consulting
field. From 1985 to the present Mr. Hobbs has worked for OGDEN
Environmental and Energy Services Company as an Environmental
Branch Manager directing the work efforts of 20 plus engineers,
geologists, and technicians in environmental investigations and
remediation projects
STATti PROGRAMS SECTION
WAC,TF P-CGRAMS BRANCH
V.. a.-' . . vi ^ /
¦ PA-i'*v''

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Cardinal,

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ThermalKEM Inc., Rock Hill, SC - ThermalKEM, SCD 044 442 333
PRESENTATION TITLE: A Case Study of Groundwater Remediation at the ThermalKEM,
Rock Hill, South Carolina Facility.
ABSTRACT: ThermalKEM Inc. is the owner and operator of a hazardous waste treatment
and storage facility located in Rock Hill, SC. On June 28, 1988, EPA issued a Corrective
Action permit pursuant to the Hazardous and Solid Waste Amendments of 1984. The permit
identified three solid waste management units (SWMUs) and ThermalKEM has since
identified three additional areas of concern (AOCs). The contamination at the facility
resulted from the waste and product handling practices of the previous owners. A bedrock
groundwater remediation well (EW-1) has been in operation since 1988 to contain and
remediate dissolved groundwater contamination. This well has also served to contain a fuel
oil pure product plume existing on the site. The pumping regime of EW-1 has been
modified several times to improve remediation capabilities. Several remediation methods
have been investigated or pilot tested to recover fuel oil from the fuel oil product plume. A
second bedrock well (PW-1) was pumped from 1988 until 1992 to remediate an additional
area of groundwater contamination. An additional extraction well is being designed to act
with EW-1 to remediate and prevent potential off-site migration of dissolved or pure phase
groundwater contamination.
PRESENTER: Alice B. Clark, Senior Hydrogeologist, ENSR Consulting and Engineering,
Acton, MA.
(LO^
PRESENTER BIOGRAPHY: Alice B. Clark received her B.A. in Engineering Sciences from
Harvard University and her M.S. in CivtJ Engineering from the Water Resources and
Environmental Engineering Division, M.l.T She has eight years of experience in the
hazardous waste field and is currently employed by ENSR Consulting and Engineering in
Acton, MA. Her major areas of expertise include hydrogeologic characterization,
hydrogeologic and contaminant modeling, and spatial and temporal statistical applications
to hazardous waste investigations. Ms. Clarfc may be contacted at ENSR Consulting and

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A Case Study of Groundwater Remediation
at the ThermalKEM, Rock Hill, South Carolina Facility
by
Alice B. Clark1, Lisa J. Wolf1, John Bierschenk 1, Ralph S. Baker1, Arthur Lazarus
Linda Eickhoff1, Janice Baker2, Luis DeAndino3 and William Zeigler3
The purpose of this paper is to present the groundwater remediation technologies pilot tested
and implemented at the ThermalKEM, Rock Hill, South Carolina Facility. Groundwater
contamination at the site is believed to be the result of poor waste storage and disposal practices
of previous site owners.
I. Description of Facility
ThermalKEM, Inc. (ThermalKEM) is the owner and operator of a hazardous waste treatment and
storage facility located in Rock Hill, SC (Figures 1 and 2). The facility consists of a RCRA-
permitted hazardous waste incinerator, hazardous waste tanks and container storage units. All
waste receipt, mixing and storage, and incineration activities are conducted in roofed buildings
with concrete floors and walls. All processing areas have fugitive emission controls. Secondary
containment is employed for all hazardous waste operations with the exception of ash storage.
Ash roll-off containers are not used to store waste with free liquids, therefore, secondary
containment is not required. Ash roll-off containers are kept covered and are inspected daily.
All tanks are above ground and nitrogen blanketed, and a leak detection al- n system is in place
for tanks and feed lines. The current operations are not thought to represent potential sources
of contamination to the environment.
The current owners have operated the site since 1983. Quality Drum Company and Industrial
Chemical Company owned and operated the site from 1966 to 1983. Prior to 1966, the site was
undeveloped. During its period of operation, Quality Drum/Industrial Chemical received spent
solvents from off-site facilities and recovered these solvents by distillation. Still bottoms
generated by the solvent recovery operations were sent off-site to a nearby landfill. In 1980,
shortly after the landfill was closed, Quality Drum/Industrial Chemical installed a hazardous waste
incinerator at the site for still bottoms treatment. In addition to this incinerator, Quality
Drum/Industrial Chemical also staged and stored drums containing hazardous waste on the
ground and stored hazardous waste in above-ground tanks. These tanks were not designed to
Subpart J design standards, but consisted of any salvage tanks that Industrial Chemical could
find (i.e. wrecked tank wagons, etc.). In addition to these units, stormwater runoff from tank and
container storage areas, and non-contact cooling water from stills, drained into an unlined ditch
1	ENSR Consulting and Engineering, Acton, MA
2	ENSR Consulting and Engineering, Raleigh, SC
3	ThermalKEM Inc., Rock Hill, SC

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on the site, referred to herein as the Solvent Recovery Containment Ditch. Also, fuel oil was
stored in two underground tanks.
In May 1983, Stablex Inc. acquired the site. At that time there were some 26,000 drums of waste
staged directly on the ground on the site and 200,000 gallons of waste stored in above-ground
tanks, which may have been structurally deficient. The Solvent Recovery Containment Ditch was
also still in use.
In December 1985, Stablex Inc. was purchased by the American NuKEM Corporation and
changed its name to ThermalKEM Inc.
II. Site Hydrogeology
Geology
The ThermalKEM facility is underlain by two primary hydrologic units: gabbroic bedrock, and
surficial soils derived from the gabbro and/or alluvium (Figure 3). Weathering of the gabbro has
yielded a dense, cohesionless subsoil, saprolite, which immediately overlies the gabbro.
Advanced, in-situ weathering of the saprolite has, in turn, produced a cohesive silty clay or
clayey fine sand. The transition between the cohesive soil and saprolite, and between the
saprolite and bedrock is gradational. Sand and gravel inclusions evident within the cohesive
subsoil may reflect localized heterogeneity of the gabbro or reworking of the cohesive soils with
alluvial deposits.
Fill material, topsoil and the cohesive soils overlying the saprolite, classified herein as residual
soils, range from 0 to approximately 21 feet in thickness. The saprolite layer is comprised of an
upper and slightly denser lower unit, and ranges in thickness from less than 10 feet to
approximately 22 feet. Degree of bedrock fracturing is variable across the site, with primary
structural strike and dip direction being north-northeast and south-southeast, respectively, and
fractures reportedly extending to a depth of 135 feet below grade (NTH, 1987). Across the site,
the water table (10 to 20 feet deep) may intersect the cohesive residual soils, the saprolite or the
bedrock.
Aquifer Hydraulic Properties and Characteristics
The fine, siity clay and siity sand soils which characterize the unconsolidated material also define
its hydraulic properties. The saprolite has a high porosity (27 to 40 percent) and, therefore, high
capacity for water storage. Estimates of hydraulic conductivity (K) for the saprolite are
approximately 3 to 4 x 10"* centimeters/second (cm/s)(NTH, 1984; SEC, 1988).
The bedrock is approximately an order of magnitude more permeable than the saprolite, exhibits
porosities ranging from 10 to 30 percent and is highly fractured. Fractures are likely to be the
primary water-conducting voids in the bedrock. Estimates of K for the bedrock are approximately
2 to 2.5 x 10"3 cm/s (NTH, 1984; ENSR, 1992b). In general, fracturing of the bedrock in the
vicinity of the ThermalKEM site allows for water production of 5 to 10 gpm in shallow wells (ie.,
50-100 feet deep) and 25 to 50 gpm in deeper wells (i.e. 400-700 feet deep)(NTH, 1984).
However, individual well production is highly dependent upon well placement relative to fractures

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(i.e. EW-1, open in the bedrock from approximately 30 to 64 feet deep, can produce 74 gpm
(SEC, 1988)).
Groundwater Flow Patterns
The ThermalKEM site is located near the confluence of Fishing Creek and Wildcat Creek. The
groundwater flow patterns at the ThermalKEM site can be described on both the regional and
local scale. Surface topography indicates that regional groundwater flow is to the south, toward
and along Wildcat and Fishing Creeks. Where unaffected by on-site pumping, localized
groundwater flow in the saprolite is primarily from west to east towards Wildcat Creek (Figure 4).
Pumping from a bedrock remediation well (EW-1), located approximately at the middle of the
active portion of the site, at approximately 15 gpm caused a capture zone in the saprolite which
laterally extended from MW-118 to the southwest toward MW-103 to the northeast. The
downgradient stagnation point of the capture zone in the saprolite extended from wells BP-1,
MW-113, and MW-114 (Figure 5).
Where unaffected by EW-1 pumping, bedrock groundwater flow is generally to the east toward
Wildcat Creek and upward; pumping from the bedrock has reversed the natural vertical gradient
within the well's zone of capture. With EW-1 pumping at approximately 15 gpm, the cone of
depression extended from as far south as MW-105, potentially as far north as MW-100, and
potentially as far downgradient as well MW-115B, but certainly to well MW-113B. The observed
north-south orientation of the cone reflects preferred fracture strike direction (Figure 6). Under
recent elevated pumping rates of approximately 20 to 25 gpm at EW-1, data indicate that the
capture zone likely extends downgradient to MW-115B in the bedrock.
Groundwater/Surface Water Interaction
The nature of groundwater/surface water interaction along Wildcat Creek was evaluated using
stream gauging, water level monitoring, piezometric maps, and cross-sectional flownets.
Analysis of stream gauging data suggests that groundwater discharges to the creek. Connection
between the unconsolidated aquifer and Wildcat Creek is further indicated by unconsolidated
piezometric surface maps and flownets which show that shallow groundwater discharges to
Wildcat Creek. -Deeper groundwater may flow beneath and along the creek for some distance
before eventually discharging to the creek, in any case, the lateral vicinity of the creek is a
groundwater divide and groundwater from the ThermalKEM site does not migrate significantly
to the far side of Wildcat Creek.
III. Description of Solid Waste Management Units and Areas of Concern
On June 28, 1988 the EPA issued a Corrective Action permit pursuant to the Hazardous and
Solid Waste Amendments of 1984. The permit identified three solid waste management units
(SWMUs) requiring investigation and possible corrective action. Also, through the course of
investigation conducted by ThermalKEM at the facility since issuance of the Corrective Action
permit, ThermalKEM has identified three additional areas of concern (AOCs) that were
investigated. These SWMUs and AOCs (Figures 7, 8 and 9) are referred to herein as:
•	Incinerator Building Sump (SWMU 8)
•	Truck Wash Station and Sump (SWMU 19)

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•	Container Storage Area (SWMU 11)
•	Solvent Recovery Containment Ditch (AOC)
•	Fuel Oil Area (AOC)
•	Old Burn Pits (AOC)
Only the Solvent Recovery Containment Ditch, the Fuel Oil Area, and the Old Burn Pits represent
areas of potential groundwater contamination.
Solvent Recovery Containment Ditch
The Solvent Recovery Containment Ditch was located just south of the existing drum process
and blend tank buildings. This ditch had been created by Industrial Chemical, presumably to
contain spills or leaks from storage tanks used in their solvent recovery operation. The ditch was
approximately 2 feet wide, 2 feet deep and 100 feet long. In 1983, visibly contaminated soils
were removed from the ditch and the ditch was filled with clean soil. Groundwater investigations
in the vicinity of the ditch confirm the presence of volatile organic constituents (VOCs) in the
groundwater as well as the possibility of light, non-aqueous phase liquids (LNAPLs).
Fuel Oil Area
Fuel oil contamination was first detected in the groundwater in piezometer P-2 during a routine
water level reading in June 1990. The source of this fuel oil could have been a leaking fuel line
which was promptly detected and repaired the previous year, or could be associated with two
old underground fuel oil tanks operated under Industrial Chemical's ownership of the site. The
tanks were in the vicinity of the existing fuel oil plume but were removed soon after Stablex's
purchase of the site.
Old Burn Pits
In the 1960's or early 1970's, Industrial Chemical disposed of still bottoms by open pit burning
in what is herein referred to as the Old Burn Pits. In 1985, via a sitewide magnetometer survey,
Stablex discovered buried remnants of drums and materials in the Old Bum Pit area. Stablex
immediately remediated the Old Bum Pits, under S.C. DHEC supervision, and back-filled the pits
with clean soils.
In April, 1985, the first groundwater samples from a newly installed monitoring well (MW-100),
upgradient of the Old Burn Pits, in the vicinity of the office building, began showing elevated
levels of trichloroethene (TCE), tetrachloroethene (PCE) and other solvents. Industrial Chemical
had operated Production Well 1 (PW-1), also located near the office building, at a rate of
approximately 25 gpm. The contamination at MW-100 may have been caused by Industrial
Chemical's pumping of groundwater at Production Well 1 (PW-1) prior to Stablex's purchase of
the site and remediation of the Old Bum Pits. In 1988, ThermalKEM converted PW-1 into a
remediation well and PW-1 continued to pump at low rates (0 to 5 gpm) to remediate the
contamination at MW-100. Pumping at PW-1 was discontinued in 1992 when concentrations in
MW-100 showed a significant decrease. The discontinuation of pumping at PW-1 also allowed
for increased pumping at the other site remediation well (EW-1), as discussed below.

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By June 1990, constituents similar to those detected in MW-100 appeared in downgradient wells
MW-103 and BP-1. The similarity of constituents detected in wells BP-1, MW-103 and MW-100
suggests that the contamination in all three wells may have come from the Old Burn Pits.
IV. Scope and Extent of Groundwater Contamination
The discovery of groundwater contamination on the site resulted from a series of subsurface
hydrogeologic investigations which Stablex voluntarily initiated upon acquisition of the site. Since
1983, groundwater monitoring has helped to identify the extent of contamination and constituents
present at each area of concern, as outlined below.
Solvent Recovery Containment Ditch
Wells OB-110A, 110B, 8A, MW-104, 113B and 115B show volatile constituents expected to be
associated with the Solvent Recovery Containment Ditch. As the history of solvent disposal at
the Solvent Recovery Containment Ditch would indicate, the constituents discovered in this area
include several volatile organic compounds (VOC's), the class of compound which characterizes
most solvents. The highest concentration levels and frequency of detection occur at OB-110A,
the well nearest the old ditch. OB-8A shows slightly lower levels of the same constituents found
at OB-110A. Metals were also detected in the Solvent Recovery Containment Ditch area.
Given all of the data, it is likely that pure phase constituents exist in the Solvent Recovery
Containment Ditch area. Light Non-Aqueous Phase Liquid (LNAPL) is likely present at OB-110A,
but is not expected to extend to EW-1 based on EW-1 recovery data.
The constituent levels in the wells provide an indication of the extent of the dissolved
contaminant plume. The presence of the more mobile VOC's at MW-104 and recently at MW-
113B and MW-115B, indicates that the edge of the plume may have migrated downgradient to
MW-104 in the saproiite portion of the aquifer and to MW-115B in the shallow bedrock system.
Recent total volatiles concentrations at the three monitoring wells are similar (0.1 to 0.8 parts per
million (ppm)). No site-related contamination nas been detected in the creek. Figures 10 and
11 shows total volatile organics through time at welte OB-8A, OB-110A, MW-104,113B and 115B.
The remediation operation of EW-1, whtcn « expected to contain the Solvent Recovery
Containment Ditch plume, is discussed in more deuut betow.
Fuel Oil Area
Monitoring of the fuel oil area has focused on defining the extent and thickness of the pure
product plume. To date, pure product has been recorded in wells P-2, TW-1, PW-1A, PW-2A,
OB-11, 12 and 13, and OB-21, 22 and 23.
Based on water and product level measurements and product baildown tests performed in the
wells containing floating product, the minimum and maximum lateral extent of the floating
product has been estimated, as shown in Figure 12.
At downgradient wells MW-111 through 114, screening level analyses of groundwater samples
are performed regularly to ensure the dissolved plume has not migrated this far downgradient.

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At present, the pure product fuel oil and likely the dissolved plume are effectively contained by
the pumping of extraction well EW-1. The remediation of the pure product fuel oil is discussed
in more detail below.
Old Burn Pits
The primary VOC plume constituents detected at monitoring wells MW-100, MW-103, BP-1 and
BP-1B, near the Old Burn Pits, are 1,1,1-TCA, PCE, and their degradation products (1,1-DCE,
1,1-DCA, trans-1,2-DCE, TCE, methylene chloride and vinyl chloride). TCE has shown the
highest concentration, appearing in MW-100 as high as 41 parts per million (ppm) (greater than
1% of its pure-phase solubility in water), possibly indicative of DNAPL. However, TCE
concentrations in MW-100 have declined to below 1% of solubility since April 1987, and have
consistently declined further since then. Figure 13 shows the change in TCE concentrations with
time at MW-100. Due to the decline in concentration levels at MW-100, pumping from PW-1,
which was remediating the MW-100 area, was discontinued in 1992. This also allowed for
increased pumping at remediation well EW-1, as discussed below.
While BP-1 and BP-1B represent the most downgradient monitoring points for this source,
constituent levels at BP-1 and BP-1 B are generally less than 100 and 600 ppb, respectively. No
site-related contamination has been detected in the creek.
V. Groundwater Remediation Systems
Initial Remediation
Upon acquisition of the site in May 1983, Stablex cleaned and closed the Solvent Recovery
Containment Ditch by October 1983. Underground fuel oil tanks were removed by June 1984.
Waste in other above ground tanks was cleaned out by September 1984. Surface soil,
contaminated by poor waste storage practices, was removed by October 1983. RCRA facility
standards were implemented, such as appropriate operating records, a waste analysis plan, an
inspection program and proper training. Additionally, the incinerator was upgraded to 40 CFR
Subpart O standards.
A subsurface investigation, which consisted of a comprehensive magnotometer survey over the
entire site, was performed in 1985 (NTH, 1985a). This survey revealed two areas of buried
materials. A total of eight intact buried drums were found and excavated in an area near MW-
103, and four old burn pits were excavated, cleaned to background soils, and filled with clean
soil. Both operations were witnessed and approved by SC DHEC.
Extraction Well EW-1
In 1986 and 1987 studies were conducted to design an extraction well (EW-1) to contain and
remediate the groundwater plume emanating from the Solvent Recovery Containment Ditch area.
Extraction well EW-1 was placed on-line in July, 1988. EW-1 is a 64 foot deep open-hole
bedrock well, located downgradient of the Solvent Recovery Containment Ditch as shown in
Figure 8. Investigations of the extraction well's hydraulic effects were conducted in late 1988.
A pump test at 20 gpm showed EW-1 to have a capture zone including all groundwater known

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at that time to be affected by the Solvent Recovery Containment- Ditch and likely a portion of
Wildcat Creek (Figure 14).
EW-1 was pumped at between 5 and 18 gpm from April, 1989 until March, 1992, when its
pumping rate was adjusted to a fairly constant 14 gpm. Between May, 1991 and March, 1992,
EW-1 was operated consistently in the 7 to 10 gpm range. Water levels throughout the site were
observed on June 25, 1991 to determine the cone of influence of EW-1 at the 7 to 10 gpm
pumping rate (Figure 15).
Groundwater extracted from both EW-1 and PW-1 (described below) is treated in the on-site
groundwater treatment plant by chemical precipitation of iron and manganese, sand filtration of
inorganics, and removal of organics by three activated carbon canisters connected in series.
The treated groundwater is then diverted to the facility wastewater treatment process unit where
it is used for scrubber water. The volatile removal efficiency is greater than 99%.
Production Well PW-1
PW-1, an open-hole bedrock well about 150 feet deep, was installed in 1979 and was operated
as a production well with an estimated pumping rate of 25 gpm until 1988 when a city water
supply line was connected to the site (Figure 9). When contamination was discovered in nearby
well MW-100, PW-1 was used to withdraw contaminated groundwater from the vicinity for
diversion to the on-site wastewater treatment plant. During use as an extraction well, PW-1 was
pumped at a rate varying from 0 to 5 gpm. PW-1 was taken off-line in 1992, because
concentrations at MW-100 had decreased to near or below detection levels. This also allowed
the pumping rate at EW-1 to be increased to 25 gpm, to extend its zone of capture, as described
below.
Fuel Oil Area
Initial remediation efforts in the fuel oil area focused on an extraction well system located in the
saprolite formation where the fuel oil was believed primarily to reside. In February. 1991, a pilot
purge well study was conducted to investigate the feasibility of removing the product via shallow
pumping wells (Kunkle, 1991). Two purge wells were installed, PW-1A and PW-2A (Figure 9),
and screened at depths of 10 to 20 feet and 20 to 30 feet, respectively, and pumped at between
4 and 8 gpm. Capture zones of 5 and 20 feet, respectively, were produced at the two purge
wells. It was therefore concluded that more effective methods of removing product from the
formation might be available, and alternative strategies were pursued, as described below.
VI. Modified Remediation Systems
Fuel Oil Area Remediation
Since the pilot purge wells alone did not remove significant quantities of fuel oil or induce large
capture zones, enhanced methods were pilot tested. In August through October, 1992, three
phases of recovery were explored (Figure 16) (ENSR, 1993). In Phase I, a total fluids pump was
employed at well VE-1, an extraction well specifically installed for this pilot study and screened
for 25 feet across the water table. The objective of Phase I was to measure the pre-
enhancement rate of total fluid (product and water) recovery from the extraction well.

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In Phase II, VE-1 was sealed and vacuum was applied to it providing a combined soil vacuum
extraction (SVE) and total fluid recovery system. The objectives were to assess whether vapor
extraction would enhance liquid recovery, and to evaluate the effectiveness of a soil vapor
extraction (SVE) system to reduce soil gas concentrations.
In Phase III, a multiple well recovery approach was attempted. Existing observation wells having
different diameters, screened at different intervals and located in different places within the area
were employed singly and in combination for fluids recovery. The objective was to use the
existing wells to show empirically how well diameter, location and screened interval might affect
product recovery, and to predict total liquid flow rate from these wells for treatment system
design.
Based upon the objectives and results of the pilot test, ENSR concluded that application of a
vacuum via a soil vapor extraction (SVE) system had a measurable positive effect on total fluid
recovery but would not significantly enhance the fuel oil recovery operation. Comparison of
liquid recovery before vaccum enhancement (< 1 gallon per day (gpd)) and after (average of 1.75
gpd) reflects a significant (42%) increase. However, product recovery was greatest from the
multiple well test (average of 12 gpd).
Effectiveness of soil vapor extraction (SVE) to reduce soil gas concentrations was demonstrated,
but limited by the uneven influence of applied vacuum within the saprolite formation.
As stated above, significant fuel oil recovery was obtained from the multi-well test, representing
one day of continuous pumping from each well. The majority of the product and water
recovered during the pilot test was probably removed from those wells which intersect secondary
fractures. During long-term pumping, a portion of the free product remaining in fractures and
larger pores of the saprolite could migrate slowly into the larger fractures and might ultimately
be recovered.
Effectiveness of vacuum on enhancement of both fuel oil recovery and soil vapor extraction is
influenced strongly by the fracture and pore size distribution within the saprolite, which control
its permeability and liquid retention properties.
EW-1 Operation and Dissolved Constituent Remediation
As of August, 1992, when ThermalKEM submitted a revised RFI Work Plan to EPA (ENSR,
1992b), EW-1 (pumping at approximately 14 gpm) was thought to be successfully preventing off-
site migration of constituents from the Solvent Recovery Containment Ditch area and also
remediating the constituent levels. EW-1 's cone of depression was also preventing the fuel oil
product plume from migrating downgradient, and four monitoring wells (approximately 200 feet
upgradient of Wildcat Creek) monitored monthly showed that the dissolved fuel oil plume had
not migrated beyond them.
In June, 1992 three shallow bedrock wells (30 to 45 feet deep) and one saprolite well (10 feet
deep) were installed near Wildcat Creek to further delineate the extent of dissolved contamination
and define more fully the three-dimensional groundwater flow pattern near the creek. Bedrock
monitoring well BP-1B was installed, adjacent to previously existing saprolite well BP-1, in the
area downgradient of the old burn pits. Bedrock monitoring well MW-113B was installed,

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adjacent to existing saprolite well MW-113, downgradient of the Solvent Recovery Containment
Ditch area approximately 250 feet upgradient of Wildcat Creek. Bedrock monitoring well MW-
115B and saprolite well MW-115 were installed downgradient of the Solvent Recovery
Containment Ditch area approximately 75 feet upgradient of Wildcat Creek (Figure 8). Quarterly
monitoring of these wells in July, 1992, October, 1992, and January, 1993 revealed positive
results for organics in all three bedrock wells and the previously existing saprolite well BP-1, but
not in saprolite wells MW-113 and MW-115. Excluding one value of 1.4 ppm for trans-1,2-
Dichloroethene at BP-1B in July, 1992, concentrations at BP-1B were all below 600 ppb;
concentrations at BP-1 were all below 100 ppb; concentrations at MW-113B and MW-115B were
all below 200 ppb. The EPA was notified in writing of these results in February, 1993. The
constituent levels detected in these downgradient wells are one to two orders of magnitude lower
than the levels recently detected near the Solvent Recovery Containment Ditch. Though the
downgradient extent of the Solvent Recovery Containment Ditch plume is yet undetermined, no
contamination which is expected to have migrated from the site has been detected in the creek
(ENSR, 1992b).
In response to the observation of dissolved organic constituents in the groundwater near Wildcat
Creek, ThermalKEM increased the pumping rate at EW-1 to approximately 35 gpm in April, 1993,
in order to increase the capture zone and prevent migration to the creek. Water level data
collected at this pumping rate and compared to data at lower rates indicate that MW-115B and
BP-1B were likely included in EW-1's capture zone at this elevated pumping rate.
In July 1993,10 to 15 feet of fuel oil floating product from the Fuel Oil Area were detected in EW-
1 and its pumping rate was reduced to approximately 20 to 25 gpm. At this time, a decrease
in product entering the treatment system was observed ar.-i the well continued to pump with
satisfactory operation of the treatment system. Water level data indicate that EW-1's capture
zone at 20 to 25 gpm likely encompasses MW-115B and BP-1B.
integrated Site-wide Remediation
Given the desire for certainty of complete dissolved and pure product constituent capture and
for an efficient remediation system, a site-wide remediation program with components which
interact well withfeach other has been developed. The conceptual plan includes an additional
extraction well to be installed in the shallow bedrock near the Old Bum Pits. This extraction well
would be operated along with EW-1 to protect the creek from the migration of dissolved
constituents from all of the areas of potential groundwater contamination discussed above
(Figure 17). EW-1 would also continue to prevent the fuel oil product plume from migrating to
the creek.
VII. Results of Remediation
Extraction Well EW-1
Since commencement of operation, EW-1 's effectiveness has been monitored through analysis
of water samples taken from the influent to the groundwater treatment system. Influent
concentrations to the on-site wastewater treatment system from PW-1 and EW-1 show that the
system is effectively recovering contaminated groundwater. Even while PW-1 was in operation,

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the majority of the influent concentration was attributed to EW-1, because of its higher pumping
rate.
Figure 18 shows the treatment system's influent concentrations of total volatiles. Total volatiles
have been recovered at three ppm, on average. The recovered concentration levels do not
appear to be decreasing through time, which is attributed to the high contaminant concentrations
which still exist immediately upgradient of the pumping well (EW-1).
Concentrations of total volatiles at the wells impacted by the Solvent Recovery Containment
Ditch (OB-8A, 110A, MW-104, 113B and 115B) are shown in Figures 10 and 11. Figure 10
indicates that total volatile levels have decreased slightly over time near the source (OB-8A, OB-
110A). MW-104, slightly farther downgradient, had shown the same trend, but has not show any
consistent decline within the last four quarters of monitoring. Figure 11 shows that contaminants
have reached MW-113B and 115B at relatively low levels.
Production Well PW-1
As described above, PW-1 was operated until contaminant levels in well MW-100 were near or
below detection limits. At that point PW-1 was taken out of operation. A time history of TCE
concentrations at MW-100 is shown in Figure 13, demonstrating the steady decline of the
contaminant of highest concentration and greatest concern.
Fuel Oil Release
It is believed that operation of extraction well EW-1 is effectively halting migration of both pure
and dissolved fuel oil away from the Fuel Oil Area. Pilot purge wells PW-1 A and PW-2A did not
exhibit large capture zones. Phases I through III of the ensuing fuel oil recovery pilot study,
described above, removed almost 300 gallons of fuel oil over a three week period. ThermalKEM
is currently pursuing more effective remedial alternatives for removing larger quantities of the
resident product, as described above, while continuing to pump EW-1 to contain the product,
and continuing to monitor for potential off-site migration (Figure 19).
VIII. Conclusion
In summary, EW-1 has been successfully preventing off-site migration of constituents from the
Solvent Recovery Containment Ditch area travelling m me upper, saprolite aquifer (Figure 5), and,
as discussed above, it is likely that current EW-1 operation is also preventing off-site migration
of the Solvent Recovery Containment Ditch contaminant plume from the bedrock aquifer (Figure
6). EW-1 has also been successfully removing constituents at a consistent rate (Figure 18).
Finally, it is believed that operation of extraction wefl EW-1 is effectively halting migration of both
pure and dissolved fuel oil away from the Fuel Oil Area.
DC Costs of Remediation
It is important for industrial site managers, agency personnel and consultants to observe the
relative costs of various remedial techniques and various remediation approaches. When the
costs, benefits and consequences of the remedial activities at a site are presented together, all

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parties gain important information and experience. Table 1 shows the incurred remediation costs
at the site.
X.	Acknowledgements
The authors wish to acknowledge Mark B. Sweatman, G.R. Kunkle and Associates, who
managed most of the site investigation and remediation prior to 1988. Also, we thank Jeff Munic,
ENSR Consulting and Engineering, for his contribution to the 1992 Fuel Oil Recovery Pilot Study.
XI.	References
NTH, 1983. Report on Geotechnical Investigation. Neyer, Tiseo & Hindo, Ltd., Farmington Hills,
Michigan.
NTH, 1984. Report on Preliminary Hvdrooeologic Investigation. Neyer, Tiseo & Hindo, Ltd.,
Farmington Hills, Michigan.
NTH, 1985a. Report on Geophysical Investigation. Neyer, Tiseo & Hindo, Ltd., Farmington Hills,
Michigan.
NTH, 1985b. Report on Installation. Neyer, Tiseo & Hindo, Ltd., Farmington Hills, Michigan.
NTH, 1986. Groundwater Recovery System-Conceptual Design Field Investigation. Proposal,
Neyer, Tiseo & Hindo, Ltd., Farmington Hills, Michigan.
NTH, 1987. Conceptual Purge Well Design Study. Neyer, Tiseo & Hindo, Ltd., Farmington Hills,
Michigan.
SEC, 1988a. Monitoring Well Construction Report. Sirrine Environmental, Greenville, S.C.
SEC, 1988b. Initial Evaluation of Purge Well and Aguifer Conditions. Sirrine Environmental,
Greenville, S.C.
GRK&A, 1991a. Hvdrooeolooic Study Report (Preliminary RFh of Fuel Oil Contamination. G.R.
Kunkle and Associates, Inc., Brighton, Michigan
GRK&A, 1991b. Report on Pilot Purge Study Well Installation and Groundwater Quality. G.R.
Kunkle and Associates, Inc., Brighton, Michigan.
GRK&A, 1991c. Interim Corrective Measures Study (ICMS). G.R. Kunkle and Associates, Inc.,
Brighton, Michigan.
GRK&A, 1992. Letter Report on Lineament Survey for the Area Surrounding the ThermalKEM.
Inc. Facility. G.R. Kunkle and Associates, Inc., Brighton, Michigan.
ENSR, 1991. Soil Sampling Analysis and Evaluation at the Container Storage Area. Rock Hill.
SC. ENSR Consulting and Engineering, Acton, Massachusetts.

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ENSR, 1992a. Letter Report on Characterization of Background Soil for Investigation of
Container Storage Area. ThermalKEM. Rock Hill. SC. ENSR Consulting and Engineering, Acton,
Massachusetts.
ENSR, 1992b. RCRA Facility Investigation WorkPlan. ENSR Consulting and Engineering, Acton,
Massachusetts.
ENSR, 1993. Fuel Oil Area Remediation Pilot Study. ENSR Consulting and Engineering, Acton,
Massachusetts.
Baker, R.S. and J. Bierschenk, 1993. Vacuum-enhanced Recovery of Water and NAPL: Concept
and Field Test. Presented at Eighth Annual Conference on Contaminated Soils, Univ. of MA,
Amherst, MA, Sept. 20-23, 1993 (manuscript in review).
Cherry, et al., 1991. Identification of DNAPL Sites: An Eleven Point Approach.
US EPA, 1983. Soils Levels.
USGS 7.5 Minute Topographic Map, Edgemoor Quadrangle, South Carolina.
USGS 7.5 Minute Topographic Map, Rock Hill West Quadrangle, South Carolina.

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8L09156
A Case Study of Groundwater
Remediation/Stabilization at the
ThermalKEM, Rock Hill, SC Facility
Presented By: Alice Clark
in
ENSR Consulting and Engineering

-------
8193164
2

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SUB 156
3
Figure 2. ThermalKEM Site and
Vicinity, Rock Hill, SC
Seureo:US.QS 7S nemos artastfaoognpfitc) quad at
RockHBJWoa-Soulli ^anitta-YerttCa.
Ia--. : '-hr-ad-
1 mito

l-h'i	rT
Sceto

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8103156
Figure 3. Geologic Profile B - B'
4

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950812A
IfCFXP
yw-i07
UNCONSOUOATED ¥CLL
UW-106
BEDROCK ttELL
\ MttMOl
HYBRID
W-1
©	UNKNOKN
1 	SSO	 P1EZOUETWC ELEVATION CONTOUft (ft US.)
CONTOUR INTERVAL - I FOOT
200 	0	200
APPROXIMATE SCALE IN FEET
1" = 200-0"
400
FIGURE 4
PIEZOMETRIC SURFACE
5-3-85 BACKGROUND
THERMALKEM FACILITY
ROCK HILL, SC

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EXPIANAT10N
tPSOCJA) CREEK SURFACE WATER ELEVATION ON 7/8/02
—O GROUNDWATER now DUTCCTtON
EQUP01EN1KMAL CONTOUR
natM GROUNDWATER ELEVATION (FT USL) MEASURED ON
tauv 7/8^2, 12-1100, IN SAPRCUTE UONITORMC WEIL
CONTOUR M1ERVA1. - 0.25 FT
• FREE PRODUCT PRESENT M MOM TORINO WEU
. WATER l£\«. (FT US.) MEASURED AT HUE OTHER
THAN WITHIN 12-1106 ON 7/«/82
'	CAPTURE ZONE UMT
»-4JJ dk CREEK DISCHARGE MEASURES ALONO STREAM OAUOtNO TRANSECTS
B - BORING
BP - BURN PfT
UW - MONITORING WEU
OB - OBSERVATION WEU
P - PIEZOMETER
PW - PURGE WELL
JW - TEST WELL
W - WELL
WP - WEU POINT
~ - BEDROCK WEU
• - UNCONSOLIDATED SAPROUTE WELL
0 - HYBRID OR UNCLASSIFIED WELLS,
m - ABANDONED BORING LOCATION
SCALE IN FEET
1" = 200'-0"
\1 // FIGURE 5
\' PIEZOMETRIC SURFACE IN
UNCONSOLIDATED SAPROLITE
IBM—OBPiP *p~ ON WP \ !, WELLS ON 7/6/92
""	#/tHERMALKEM FACILITY
ma * im oomcsmcm
sor of arttnc.
fUV. - 527 §7

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950814A
Mr-tat A
(ana)
0MMO7

EWLANATMN
CREEK SURFACE WATER ELEVATION ON 7/I/V2
	— GROUNDWATER aOB DIRECTION
wn egupotenhonal contour
GROUNDWATER ELEVATION (FT US.) MEASURED ON
isuuv j/f/ti. 12-13:00. M SAPHOUTt U0MT0RMG «EII
CONTOUR WTEHVAL - 0.2S FT
• FHEE PRODUCT PRESENT M M0MT0RM0 «EU
. WATER LE\CL (FT USU) MEASURED AT HUE OTHER
THAN WTHM 12-13:00 ON 7/B/B2
i CAPTURE ZONE UttT
»-*« dk CREEK DISCHARGE MEASURED ALCNO STREAM OAUONO TRANSECTS
200
MSStE.
B - BORING
BP - BURN PIT
UW - UONITORING WELL
OB - OBSERVATION WEIL
P - PIEZOMETER
PW - PURGE WELL
TW - JEST WELL
W - WELL
WP - WELL POINT
A - BEDROCK WELL
• - UNCONSOLIDATED SAPROUTE WELL
6 - HYBRID OR UNCLASSIFIED WELLS
¦ - ABANDONED BORING LOCATION
Juxri) •
(no a)
Mr-ioi
LSTICAM CAUCUS
IHAKSCCT I
0
200
400
SCALE IN FEET
1" = 200-0"
nv-oous "q~ on r»
wa - lot oomam
cuv. - u;i7
\ // FIGURE 6
PPIEZOMETRIC SURFACE IN
1 ON BEDROCK WELLS
ON 7/6/92
MALKEM FACILITY
OCK HILL, SC

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S1931M
Solid Waste Management Units (SWMUs)
•	Incinerator Building Sump (SWMU 8)
•Truck Wash Station and Sump (SWMU 19)

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Areas of Concern (AOCs)
•	Solvent Recovery Containment Ditch
•	Fuel Oil Area

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LEGEND
B - BORING
BP - BURN PIT
UN - MONITORING WELL
OB - OBSERVATION WELL
p - ptczoucrm
PW - PURGE wax
TW - TEST WELL
W - WELL
WP - WELL POINT
A - BEDROCK WELL
• - UNCONSOUMTEO SAPROUTE WEU
9 - HYBRID Off UNCLASSIFIED WELLS
¦ - ABANDONED BORING LOCATION

y
IBM-CHISELED ON TOP
WALL - l£FT DOWNSTREAM
9DC OF BRIOGE
ELEV. - 127.87
200
0
200
400
SCALE IN FEET
1" = 200'—0"
FIGURE 7
SITE PLAN
THERMALKEM FACILITY

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950807A
LEGEND
B - BORING
BP - BURN PIT
UW - UONITORtNC WELL
OB - OBSERVATION WEIL
P - PIEZOMETER
PW - PURGE wax
TW - TEST mm
W - WELL
WP - WELL POINT
A - BEDROCK WELL
• - UNCONSOLCATED 5APROUTE WELL
9 - HYBRID OR UNCLASSIFIED WELLS
m - AP TD BORING LOCATION


200
0
200
400
SCALE IN FEET
1" = 200-0"
FIGURE 8
SWMUe
THERMALK£M FACILITY

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95080BA
0 - BORING
BP - BURN PIT
Mr - yOMTOfSNG WELL
OB - OBSERVATION KtU
P - PIEZOMETER
PW - rVRCE WELL
TW - TEST WELL
w - t*ru
WP - WELL POINT
A - BEDROCK WELL
• - UHCONSOUtMTEV SAPROUTE WELL
$ - HYBRID OR UNCLASSflED WELLS
¦ - ABANDONED BORING LOCATION
200
0
200
400
SCALE IN FEET
1" = 200-0"
FIGURE 9
AOCs
THERMALKEM FACILITY

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Extent of Contamination
•	Solvent Recovery Containment Ditch
•	Fuel Oil Area

-------
8U9tM
Figure 10. Total Volatile Organics Near Solvent
Recovery Containment Ditch
0B-8A Tolal VotatlUs
OB-llOA Tolal Volatile*
00
C
Q
C
0)
u
a
o
L>
tti
C
o
Zj
ta
u
4J
c
0)
o
C
O
a
200000
6/3/88
(391.160:
l/l/fl*
($06,200)
0/80/86
(414.300)
«/t&/ao
(3I7.M0)
\ ?
±,u.
* * I I
UW- 104 Total VolatUes
\
00
a
o
£
*
u
C
V
a
c
o

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15
81931M
Figure 11. Total Volatile Organics Downgradient of
Solvent Recovery Containment Ditch
MW-113B Total Volatiles
MW-115B Total Volatiles
tsfl
C
o
• M
-*->
a
u
c
0)
o
a
o
c_>
700
600 -
500
400 -
300 -
200
100
on
G
O
(0
u
+->
a
0)
o
a
o
u
700
600 -
500 -
400
300 -
200 -

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B - BORING
BP - BURN PIT
UW - UOMTOMNG WELL
OB - OBSERVATION WELL
P - PIEZOUETER
PW - PURGE well
TW - TEST WEIL
W - WELL
WP - WELL POINT
A - BEDROCK WELL
9 - UNCONSOLIDATED SAPROUTE WELL
• - HYBRID OR UNCLASSIFIED WELLS
B - ABANDONED BORING LOCATION

y
TBM-CHISELED ON TOP
WALL - LEFT DOWNSTREAM
Si DC OF BRIDGE
ELCV - 327.67
200
200
SCALE IN FEET
1" = 200-0"
400
FIGURE 12
EXTENT OF FUEL OIL
THERMALKEM FACILITY

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S193160
Figure 13: TCE and PCE at MW-100
if&R
MW-100 PCE
DO
a
o
¦ rH
-*-»
(0
u
*->

o
C
o
CJ
80
60
40
20
8/3/88
(83)
Below Detection Limit
ettoooe • e e • ®
i
_L_
_1_
13 3 3 3 1
DO
3
G
O
(0
C
V
o
a
o
u
MW-100 TCE
40000
30000
20000
10000
3/1/85
(41.000)
Detection Limit < 10 ug/l
8/3/88
(30,000)

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Groundwater Remediation Systems
• Initial Remediation
° Extraction Well (EW-1)
° Production Well (PW-1)

-------
SL03156
19
ENR
Initial Remediation
(June 1983- 19135)
® Cleaned and Closed Solvent Recovery
Containment Ditch by October 1983
° Removed Contaminated Surface Soil by
October 1983
»Removed Underground Fuel Oil Tanks by
June 1984
° Cleaned Out Above Ground Tank Waste by

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sun 1&6
20
ENhR
Initial Remediation
(June 1983- 1385) (Cont'd)
•	Implemented RCRA Facility Standard
•	Upgraded Incinerator to Subpart O Standards
•	Performed Magnetometer Survey; Identified
Buried Drums and Burn Pits in 1985
•	Removed Buried Drums Near MW-103;
Remediation Approved by DHEC
•	Excavated Burn Pits; Remediation Approved

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8L931M
Figure 14. Drawdown in Saprolite with EW-1

-------
950B15A
iSsW-too
i rerun
MW-107
V
HV-10S
V
MWrlOl
~
*1-1
UMCONSOUDA1ED HELL
BEDROCK WELL
HYBWO
UMOMNM
5MO	 pczoumoc ELEVATION CONTOUR (ft MSL)
CONTOUR MTDIVAL - I FOOT
200	0	200
APPROXIMATE SCALE IN FEET
1" = 200-0"
400
FIGURE 15
PIEZOMETRIC SURFACE, 6/25/91
THERMALKEM FACILITY

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SL69156
Fuel Oil Area Pilot Purge Wells
• Two Shallow Purge Wells
-	Screened 10 to 20 ft. deep; across product level and
product/water interface
-	Screened 20 to 30 ft. deep; below product level, but
across product/water interface
•	Pumped at 4 to 8 gpm

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6L931t^
Fuel Oil Recovery Pilot Study
•	Phase I: Total Fluid Recovery From One Well
•	Phase II: Vacuum Extraction and Fluid
Recovery From One Well
•	Phase III: Multiple Well Recovery - Six Wells

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= VAPOR LXmrtv/iio,.
EXISTING
CONCRETE
SLAB
= EXISTING GROUNDWATER MONITORING WELL
= EXISTING GROUNDWATER PUMPING WELL
(PW-2A IS A FORMER PUMPING WELL
EW-1 IS ACTIVELY PUMPING)
OB—13 A
OB—11
APPROXIMA SCALE: 1"=30'
FIGURE 16
PILOT STUDY
THERMALKEM FACIl
ROC VIILL, SC

-------
Phase 1 Liquid Extraction System
10
WAS ft WA FIR
IREA1MINI
Pi AMI
Lf Cf NO
EXTRACTION WELLS
PI
-
PRESSURE ft D
-------
Vt-I
VAPOR tXTRAClKW
ncti
VAPOR
PHASE
CARBON
i *
' NOeUMLt
I aosto
I VM.VI
I
I
U-til-
chrbow ar-p»ss
J£L
BLOtCR
WLET
filter
-tNLEI
SILENCER
MO

LfCfHD
FP - now MEASUREMENT POR!
ts - um smich
PI	- PRESSURE INDICATOR
PS	- PRESSURE SWITCH
SP	- SAMPLING POR I
It	- UMPCRATURE Etcutfatf . ,
II	- TEMPERATURE tNOtCAlOR
TS	- TtUPERATURE SM1CH
dpi	- differential pressure woicaior
• MANUAL VALVt 
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Phase 3 Multiple Well Groundwater
Extraction System
SftER
FOOT
VALVt «/
STRAMCft
IFGIHO
-	PRESSURE MOICAfOR
. PRESSURE SWITCH
-	PRESSURE RELAY
-	F10W 10TAL12ER MOlCAlOR
-	VALVt
•	OIAPHRAM VAL\ff
•	SOUNOC VAIVE

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Fuel Oil Recovery Pilot Study Results
•	Vacuum Had Measurable Positive Effect, But
Not Significant
•	Satisfactory Recovery From Multiple Wells
•	Most Recovery From Secondary Fractures
•	Long Term Pumping Might Recover Remaining

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SL991S6
30
EN3R
EW-1 Remediation
August 1992:
February 1993:
• April 1993:
July 1993:
EW-1 Pumping at 14 gpm;
Preventing Off-site Migration
EPA Notified That Newly Installed
Downgradient Wells Show Low
Level VOCs
EW-1 Raised to 35 gpm;
Preventing Off-site Migration
Product Found in EW-1; EW-1
Lowered to 25 gpm; Preventing

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Conceptual Sitewide Remediation Plan
•	One Additional Extraction Well
•	Two Wells Pumped to Prevent Off-site Migration

-------
950811A
legend
B - BORING
BP - BURN PtT
UW - UONWOMNC WELL
08 - OBSERVATION WELL
P - PIEZOMETER
PW - PURGE WELL
TW - TtST MEU.
w - mi
WP - WELL POINT
A - BEDROCK WELL
« - UNCONSOUDATED SAPROUTF WELL
% - HYBRID OR UNCLASSIFIED WELLS
¦ - ABANDONED BORING LOCATION
A - ADDITIONAL EXTRACTION WELL
	POTENTIAL GRAVITY DRAINS
—— - APPROXtmn CAPTURE ZONE


TBM-CW SB-ED ON TOP
WALL - l£FT OOVMSmCAM
SIDE OF BRUXZ
ELEV. - 327.67
200
0
200
400
SCALE IN FEET
1" = 200'—0"
FIGURE 17
CONCEPTUAL REMEDIATION PLAN
THERMALKEM FACILITY

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84.03156
33
ENS
Results of Remediation
•	EW-1 Continues to Remove Mass
•	Total Volatiles Near the Source Decreased
•	EW-1 Prevents Off-site Migration of Dissolved
Constituents and Pure Product Fuel Oil

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6L03
34
Figure 18. Total Volatile Recovery in Treatment
System from PW-1 and EW-1
TOTAL VOLATILES
6000
5000
4000
3000
i r
25.499 I ppb
2/91
&0
2
c
o
(0
u.
e
01
c 2000
o
u
1000
o
a>
Z
<
o
o>
K
%
0
01
J
p
0
01
£-
CJ
O
z
CT>
(Z
%
-J
o> o>
E-
U
O
CM
CT>
<
CM
CT>
K
0*
<
13.108 ppb
11/82
6.679 ppb_
1/93
C\J
Ol
C\1
CO
t-
CJ
O
n
en
z
<
i	r
6.M3 ppb
5/93
CO
O,
<
CO
J
CO
CT)
t-
U

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95081OA
B - BORING
BP - BURN PIT
UW - UOMTOfUNC WELL
OB - OBSERVATION WEIL
P - PIEZOUETER
PW - PURGE WEIL
TW - TEST WELL
W - WEU
WP - WEIL POINT
A - BEDROCK WELL
• - UNCONSOUMTEO SAPROUTE WELL
e - HYBRID OR UNCLASStfTtD WELLS
m - AB/ T> BORING LOCATION
200
200
SCALE IN FEET
1" = 200'-0"
400
FIGURE 19
EW-1 CONTAINMENT
OF FUEL OIL
THERMALKEM FACIUTY

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TABLE 1
Approximate Remediation Costs - 1983 to Present
ThermalKEM, Rock Hiil Facility, SC
REMEDIAL TASK
COST
Initial Remedial Programs - Magnetometer Study and
Remediation of Old Burn Pits [1985]
$1,200,000
Design and Installation of Remediation Wells
EW-1 and PW-1 [1988]
$37,000
Fuel Oil Pilot Purge Wells [1991]
$80,000
Fuel Oil Recovery Pilot Study [Aug - Oct, 1992]
$130,000
Site Characteristics Investigations [1988 • 1993]
$260,000
Groundwater Monitoring [Annually]
$35,000 for
years; now
$12,000
RFI WorkPlan Preparation and Regulatory Response

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p

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RCRA Ground Water Remediation Conference
December 1-3, 1993

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The Torrington Company
Clinton Bearings Plant
© Roller Bearing Manufacturer.
@ 550,000 sq. ft., 156 acres.
Employing 1200+ People.
© Clinton, South Carolina.
Between Greenville and Columbia, off I-26.
® Mostly Rural Housing and Farmland.

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HAZARDOUS WASTE

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Hazardous Waste Management Units
•	5 Surface Impoundments (R)
A.	Copper Cyanide and Floating Oil
B.	Copper Cyanide and Floating Oil
C.	Copper Hydroxides
D.	Chemical Milling Solution
E.	Chemical Milling Solution
•	Cyanide Destruction Units 1 and 2
•	Sludge Drying Beds 1 and 2 (R)
•	5 Industrial Wastewater Lagoons
Clay-lined, Earthen
•	Several Industrial Waste Landfills

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LJ

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Hydrogeology Beneath Facility
Consists of three interconnected water
bearing zones.
•	Zone 1 - Soil Zone
Sandy Silts and Clays near surface.
•	Zone 2 - Partially Weathered Rock (PRW) Zone
Transition between soil and bedrock.
Variable quantities of both sandy silts
and highly fractured rock.
Preferential flow path for ground water.
•	Zone 3 - Weathered, Fractured, and/or Jointed
Bedrock Zone
Extends from base of PWR to bottom of uppermost

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Hyrogeology Beneath Facility
con't
•	Verticle limit of uppermost aquifer has been defined
to be below the uppermost 10 feet of unweathered
competent bedrock.
•	Presence of iron staining on joint surfaces is indicative
of ground water flow through the fractured bedrock.
•	Low hydraulic conductivities suggest that movement is
very slow.
•	Based on potentiometric surface contour maps, ground
water flow in the aquifer system is from north to south-

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Scope & Extent of Ground Water Contamination
Prior to Ground Water Remediation Efforts
BACKGROUND
•	To comply with ground water monitoring requirements,
we conducted a hydrogeologic study in 1981.
•	Six wells were installed near the regulated units.
•	Sampling and analysis was done quarterly until mid 1985.
•	Monitoring activity indicated that ground water had been
impacted with indicator and several specific parameters.
•	Three phases of ground water assesment were conducted
between Jan. 1986 and Aug. 1987.
•	These studies concluded that ground water had been impacted

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Scope & Extent of Ground Water Contamination
Prior to Ground Water Remediation Efforts
•	Phase II data suggested that the horizontal extent
appeared to be limited to Torrington property and
was discharging into North Creek and North Creek Pond.
® Vertical extent is limited to the uppermost aquifer.
•	Phase III was conducted to better define the horizontal
extent.
•	Data collected in the North Creek area further defined
the horizontal and vertical extent to the south-southeast
with point sources in the vicinity of the lagoons.
•	Phase III concluded with a conceptual corrective action
plan (CCAP) to remediate ground water through the

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Ground Water Remediation System
•	The Ground Water Recovery (GWR) system is intended to
produce and maintain a hydraulic barrier for ground
water-flow.
•	The GWR system consists of 15 recovery wells and
corresponding observation wells.
•	Recovery Wells R-1 through R-11 were installed in a
linear network along the southern property boundary.
Each well pumps into an aboveground pipe manifold which
carries the water to the wastewater pretreatment plant.
The water is collected in a 7,500 gallon tank and then
pumped through twin air stripper towers for VOC reduction.
•	Recovery Wells R-12 through R-15 are located in zones of
specific contamination. Each well (except R-12) has a
dedicated discharge line and is treated separately at the

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Ground Water Remediation System
•	Each well is constructed of a 6-inch diameter
stainless steel casing and screen.
® Each well has a submersible pump that is rated
for the flow necessary to achieve the desired
ground water table drawdown.
•	Flow controls and electronic components are
located at each well.
•	A main control/status panel is located in the
pretreatment plant which monitors operational
conditions of each well and provides ON/OFF

-------
Ground Water Remediation System
Operational Problems, Difficulties, Changes
•	Casing Shift in R-4. This recovery well descends
through an old debris landfill. Evidently, some settling
has occurred which has bent the casing more than 4 inches.
The pump could not be removed for repair, so a Jet pump
was installed above the well to ensure operation and
barrier integrity. Well repair is still being considered.
•	Modification of R-13. Source area recovery well R-13 is
utilized to remove light, non-aqueous phase liquids (LNAPL)
from the ground water surface. The skimmer pump never
ran because the layer of LNAPL was not thick enough. A
recovery pump has been installed below the skimmer pump to
generate a hydraulic gradient that will pull more of the

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Ground Water Remediation System
Operational Problems, Difficulties, Changes
•	Colonizing Iron Bacteria. We have had to replace more
than 5 submersible pumps due to failures related to the
bacteria problems.
The bacteria growth has affected the ground water
recovery rate. At times, it has come close to jeopardizing
to integrity of the barrier systen:.
We are about to undertake a project of rehabilitation for
the system. This is to include a pH adjustment and a UV
Oxidation step to kill the bacteria.
•	Pressure Sustaining Regulators. Due to periods of drought
and flood, we have installed the regulators to adjust the

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-------
4 12 3 4 12 3 4 12 3 4
87
2 d 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3
oo
(39
90
92
93


-------
PPM
"3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3

-------
PPM
O
O
4 12 3
7| 88
2 3 4 1 2 3 4 1 2 3 4 1
91 |

-------
PPM
3 4 1 2 3 4 1 2 3 4 1 2 3
1 2 3 4 1 2 3 4 1 2 3
1 2
86 | 87 | 88 | 89 | 90

-------

-------

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Progress In Ground Water Remediation
•	Since startup of GWR system, there has been a continual
decrease of VOC and inorganic constituent concentrations.
•	Plume size has not greatly decreased.
•	Wells near the recovery system that previously exhibited
artesian conditions, no longer do so.
•	Additional off-site assesment, including additional well
installations, have confirmed that North Creek acts as a
hydraulic barrier and R-12 is successfully remediating

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Costs of Ground Water Remediation System
• One Time Costs
Logistics and Planning	$ 15,000
Pilot Recovery System	175,000
Barrier System Implementation	410,000
Source Recovery Wells	200,000
Total	$ 800,000
Annual Costs
Repair	32,000
Modification/Upgrade	20,000
Utility	36,000
Personnel	22,000
Total

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David Carl Cromwell Age: 27
BS Industrial Chemistry	Western Carolina University
Position: Project Engineer A Title: Plant Chemist/Environmental
Coordinator
Joined Torrington in 1990.
Two years Active Duty - Army

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Cardinal.

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WSRC-MS-93-511
Groundwater Cleanup: An Update of the
Savannah River Site Experience (U)
J.G. Horvath
Westinghouse Remediation Services, Inc.
C.L. Bergren
Westinghouse Savannah River Company
ABSTRACT
A full-scale pump-and-treat groundwater remediation program that addresses a large plume of volatile organics has
been ongoing at the Savannah River Site (SRS) since 1985. The system has recovered more than 135,000 kilograms
of solvent and is containing the center of the plume. While overall protection is being achieved, reducing the
concentration of contaminants to regulatory acceptable levels is a problem.
INTRODUCTION
As presented at ER '91', the Westinghouse Savannah River Company (WSRC) and Department of Energy (DOE)
experience at the Savannah River Site (SRS) suggests that meeting cleanup standards is a challenge in light of
technical realities.
The purpose of this paper is to update the reader regarding the corrective action program that is addressing a large
plume of volatile organics beneath the A/M Area of SRS. At ER "91, we described the history and status of the
program, costs, measures of performance, lessons learned, and challenges faced.1 Below, we briefly review these
areas and provide a list of recently completed actions.
HISTORY
SRS, which has been in operation since 1953, is a 780-square kilometer site that produced special isotopes for the
national defense program. As a result of past waste disposal practices, groundwater at several locations within the
Site has become contaminated with solvents, metals, and radionuclides. In 1981, the groundwater located beneath the
Site's fuel and target fabrication facility was found to be contaminated with volatile, organic degreasing solvents,
primarily trichloroethylene (TCE) and tetrachloroethylene (PCE). The sources of contamination were a settling basin
and sewer line (now closed)2, a solvent storage area, and other release points located near the fabrication facility. In
response, DOE voluntarily initiated a groundwater corrective action program, including an extensive groundwater
monitoring system. Groundwater remediation in the A/M Area began in 1982 with the startup of an experimental air
stripper. To date, more than 300 monitoring wells have been installed to characterize the plume.
Full-scale groundwater recovery with treatment by air stripping has been ongoing in A/M Area since 1985. The
remedial system now comprises 12 recovery wells and two air strippers. Since the beginning of remediation, more
than 135,000 kilograms of degreaser solvents have been removed from more than 6,700,000,000 liters of
groundwater. The system is reducing the mass in the central plume region effectively and is serving to contain the
contamination present there. SRS has realized through continuing evaluations that the current system will require
augmentation to address other areas as discussed below.
Ongoing investigations have determined that a significant amount of solvent remains in the vadose zone. More
recently, a separate phase of solvents was detected in a monitoring well located near the closed settling basin. Both
occurrences continue to influence the amount of solvent in the aqueous phase. WSRC has completed a program to
characterize more fully the vadose zone beneath source areas. Contamination in the vadose zone has been and will be
addressed by vacuum extraction. The presence of dense nonaqueous phase liquids (DNAPLs) is the focus of a
current characterization effort. DNAPLs represent an even greater challenge in characterization and remediation

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WSRC has completed some enhancements and plans to expand the corrective action program. In 1989, packing in
the full-scale air stripper was replaced, the system was tested,3 and flow from the recovery wells to the air stripper
was increased from 1500 to 1900 liters per minute, a 25% increase. Additional recovery capacity was added in 1991;
SRS installed a recovery well and relocated a prototype air stripper to a source area near the Site's northern
boundary, outside the influence of the original recovery system.
In addition to relocating the prototype air stripper, WSRC and DOE also plan to install additional groundwater
recovery capacity near the Site's northern boundary. The DOE-WSRC team also initiated projects that will address
contamination remaining in the vadose zone. A 1987 pilot system recovered more than 450 kilograms from the
vadose zone in a three-week period. More recently, experimental horizontal well systems, tested by the Savannah
River Technology Center under the auspices of the Office of Technology Development, have recovered more than
7200 kilograms from the subsurface by using vacuum extraction and in situ air stripping of the aquifer near a source
area (the closed sewer line). Based on the success of these efforts, WSRC plans to pursue installing four additional
systems that will address source sites.
Completed actions since ER '91 are presented below:
WSRC obtained SRS's first CERCLA records of decision (RODs) in 1992. These RODs are serving as a model
for implementing EPA's fundamental study area concept. The concept was developed to efficiently manage sites
with several operable units. It is expected that integrating CERCLA requirements into the program will
encourage the use of risk and cost-benefit analyses to determine the degree of and need for future enhancements
to the program.
The design of a vadose zone remediation system has been completed. WSRC plans to install the system for DOE
during FY 94. The system will use vacuum extraction and will be skid mounted.
The design of a 250 GPM groundwater recovery system to be installed near the Site's northern boundary has
been completed. This system will complement the 70 GPM unit completed in 1991.
DOE's integrated demonstration project has been incorporated into the actual cleanup operation. The hardware
(horizontal wells, treatment systems, etc.) from the successful technology development projects are considered to
be a part of the total cleanup program.
•	Forum for national focus on DNAPLs was established. The discovery of DNAPLs in the subsurface near the M-
Area Settling Basin prompted WSRC/DOE to lead a DNAPL national task team. The results of this task have
been visible in recent DOE reports.4
Risk assessments are ongoing for the multiple operable units in the fundamental study area. The risk assessments
are complicated because of the multiple contributions of the various operable units and specifically how the units
influence groundwater contamination.
•	Cone penetration and resistivity tools were used successfully to screen areas for additional well placement and to
characterize DNAPL contamination. The dilute plume south of the closed M-Area Settling Basin was
characterized further using cone penetration to minimize the addition of monitoring wells. Closer to the basin
cone, penetration combined with resistivity techniques and other methods were used to determine the nature and
presence of DNAPLs in the subsurface.5
The remediation program at SRS is providing knowledge and experience on how well cleanup programs work.
WSRC is conducting extensive risk assessments associated with contaminated sites for DOE. A better understanding
of the limits of remediation, combined with the amount of risk posed by the impact, eventually should lead to
improved decisions regarding cleanup goals.
PROGRAM COSTS
The original 11 recovery wells and air stipping system cost $4,800,000 to design and construct. The system costs
approximately $100,000 per year to operate and maintain. The system has performed very well with an operating
utility of greater than 95%. The major maintenance concern is lightning strikes.
Other costs associated with the corrective action program are the expenses of groundwater monitoring, interpreting
and managing data, modeling, reporting, and continuing investigations and project development.
REMEDIATION REQUIREMENTS, GOALS
The A/M-Area groundwater corrective action program is permitted under the postclosure requirements of the
Resource Conservation and Recovery Act (RCRA). The facility became fully permitted in September 1987. Exact
conditions for the program are stated.in the Site's hazardous waste permit6 and in the associated permit application7.

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The initial goal of the program was to remediate the most contaminated groundwater by maximizing mass removal
from the center of the plume. It has been SRS's position that the remediation would take place in stages. The
corrective action program calls for groundwater remediation to be continued until "the groundwater concentration ...
no longer poses a threat to human health and the environment..." However, concentration limits listed in the permit
and permit application for the primary constituents of concern are very near analytical detection limits. Although
concentrations of a few other constituents are above the limits described in the permit and associated application,
they do not exceed these limits in the influent stream to the air stripper. These other constituents are of limited extent
and are detected in only a few monitoring wells near the closed settling basin.
WSRC and DOE have used the following tools to evaluate performance of the recovery system:
Zone of capture modeling - The volumetric extent of groundwater is recovered during a specified time interval.
Estimated changes in subsurface inventory - The original subsurface inventory is compared to current inventory
using data from monitoring wells.
Mass removal - This is the mass balance of contaminants across the groundwater treatment system. The total
mass removed is compared to a hypothetical 99% mass removal curve.
These methods are explained in detail in the ER '91 paper.1
CONCLUSION
SRS has developed a groundwater program intended to detect, characterize, and remediate groundwater impacts.
When evaluated against original goals, the pump-and-treat system has been successful. A large amount of mass has
been removed, and significant progress has been made regarding plume containment. However, low concentrations
probably are not achievable through a standard approach. Although new technologies offer hope, they still must
overcome the difficulties presented by a complex hydrogeologic system. In addition, other issues such as vadose
zone Contamination and uncertainties associated with DNAPLs need to be addressed. It is imperative that the sources
of contamination be addressed to prevent further degradation of the groundwater resource. However, the limits of
any type of remediation must be faced such that reasonable cleanup targets are chosen.
DOE and WSRC are committed to restoration, while assessing risk and continuing to search for less-expensive
methods. Risk-based approaches to cleanup may lead to more logically deduced cleanup goals and standards. It is
essential that the benefit of such efforts be assessed so that resources are applied wisely.
REFERENCES
1.	J.G. HORVATH and SCOTT SUROVCHAK, Groundwater Cleanup: The Savannah River Site Experience,
presented at Environmental Remediation '91, Pasco, Washington.
2.	S.R. MCMULLIN and J.G. HORVATH, M-Area Basin Closure: Savannah River Site, Westinghouse Savannah
River Company, presented at Environmental Remediation '91, Pasco, Washington.
3.	S.T. MCKILLIP, K.L. SIBLEY and J.G. HORVATH, Air Stipping of Volatile Organic Chlorocarbons: System
Development, Performance and Lessons Learned, Westinghouse Savannah River Company, presented at
Environmental Remediation '91, Pasco, Washington.
4.	TIE Quarterly, Vol 2, No. 3, Summer 1993, U.S. DOE, Office of Environmental "Restoration.
5.	B.B. LOONEY, et al, Characterizing DNAPL Contamination: A/M-Area Savannah River Site, Presented at
Environmental Remediation '93, Augusta, Georgia (unpublished).
6.	Hazardous Waste Permit No. SCI-890-008-989, Part IV, South Carolina Department of Health and
Environmental Control, Office of Environmental Quality Control, Bureau of Solid and Hazardous Waste,
Columbia, S.C. (September 1987).
7.	Application for a Post Closure Care Permit, M-Area Hazardous Waste Management Facility, Volume III, E.l.

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L LAKE
I
H
RI v	SOUTH
ER	CAROLINA

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BIOGRAPHICAL SKETCH
Chris Bergren is a geologist with Westinghouse Savannah River Company. He is a
manager within the Environmental Restoration Department at the Department of Energy's
Savannah River Site (Aiken, South Carolina) and is responsible for monitoring and
remediation efforts within the Site's A/M Area. Previous assignments over the past eight
years at the Savannah River Site involved well drilling and sampling, monitoring and

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Evaluation of Pump & Treat System Performance
Robert C. Borden
North Carolina State University
Pump and treat systems have been designed to prevent contaminant migration,
recover both dissolved and separate phase contaminants from the subsurface, and to
restore ground water to a quality suitable for other beneficial uses. Typical pump and
treat systems consist of recovery wells and/or trenches, an above ground treatment
system (oil/water separator, air stripper or carbon adsorber), and some method for
disposal of the final effluent (infiltration gallery, injection wells, surface discharge or
POTW discharge).
Pump and treat systems can be effective in preventing contaminant migration
but are often less effective at restoring ground water quality. This is often due to the
presence of non-aqueous phase liquids or NAPLs. These NAPLs may be present in
the subsurface as single discontinuous droplets or large elongated blobs. Because of
the chemical properties of the contaminants, most petroleum compounds will partition
into the NAPL and dissolve very slowly. To evaluate the process, a series of laboratory
column experiments were conducted using sand which had been previously flooded
with gasoline. Water was then pumped through the contaminated aquifer material and
monitored for dissolved BTEX (benzene, toluene, ethylbenzene and xylene isomers).
The concentration of most compounds in the column effluent declined steadily and then
reached a plateau where little additional change in concentration occurred. The less
soluble compounds take longer to decline and then reach the same plateau.
A statistical study was conducted of the long term performance of pump and
treat systems installed at underground storage tank (UST) sites in North Carolina.
Monitoring histories from 48 wells at 13 sites were evaluated to detect trends in the
concentration of BTEX over time. For the 48 wells analyzed, 12 to 29% reported a
statistically significant negative slope (95% confidence) in the concentration versus
time plot. Cleanup times were estimated by extrapolating the regression line until it
reached the appropriate groundwater standard for each BTEX compound. The cleanup
times were generally in the range of zero to 15 years, or enormously long, indicating
the would not reach standards at the current trend. These results indicate that the
existing pump and treat systems will not be effect at meeting ground water standards
within a reasonable time period.
Monitoring data were also used to estimate the amount of benzene recovered
from the ground by pump and treat systems. Benzene was selected for analysis
because it has the lowest allowable concentration in drinking water and is the least
biodegradable under the anaerobic conditions common in many petroleum

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equivalent gasoline volume based on an estimate of the average amount of benzene in
gasoline. Results from this analysis show that many pump and treat systems are very
effective in removing contaminants from the ground. In three of the four systems
evaluated, recoveries ranged from 1200 to 2800 gallons of equivalent gasoline. One
system was poorly designed and recovered little or no contamination after the initial
startup, even though free product was still present in some wells.
Summary and Recommendations
Pump and treat systems can be very effect at removing contaminants from the
ground but are typically much less effective at meeting ground water standards. The
design of these systems should be modified to maximize contaminant recovery by
pumping more water through the contaminated interval. Once the readily recoverable
contaminants are removed, other alternatives should be considered for managing any

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Evaluation of Pump & Treat
System Performance
Robert C. Borden
North Carolina State University
PUMP & TREAT OBJECTIVES
Q Prevent migration.
Q Recover contaminants from
subsurface.
© Restore CW quality.

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STATISTICAL EVALUATION OF
PUMP & TREAT PERFORMANCE
9 Collect data on NC P&T systems
over 3 yrs old.
O Evaluate change in BTEX in MW
over time.
Q Estimate time to cleanup.
O Estimate benzene removed from
ground.
SITE CHARACT1STICS



Sito
Rogion

Monitor
Raoov
System
Pmp


(yrs)
Walls
Well*

Rat*





<9Pm)
1
Mount.
5
8
2
O/W
1.25
2
Coast.
4
11
2
Strip.
3.5
3
Cout.
4
16
2
Strip.

4
Plednxt.
4
7
1
Strip.
1.
5
Coast.
4
5
2
Strip.
4.
6
Coast.
4
9
1
O/W

7
Cout.
5
7
3
Strip.
1.3
8
Piodmt.
4
12
2
Strip.
3.5
9
Mount.
5
5
1
O/W

10
Coast.
5
8
1


11
Fiadmt.
3
5
1
Strip.
1.
12
Coast.
6
6
3
Strip.
3.
13
Mount.
6
11
3
Strip.
1.25
WELLS WHERE BTEX IS DECREASING
(95% Confidence)
Q Benzene	21%
O Toluene	21%
9 Ethylbenzene	20%

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TIME TO MEET STANDARD AT A WELL(%)
(95% confidence concentration is decreasing)
Tim* Benxene Toluene 1-Benx. Xylene BTEX
(yr*)
0-5 11	24	18	24	B
5-10 3
10-15 5
15-20
20-25
25-30
30-50
50-100
TIME TO MEET STANDARD A T A WELL(%)
(no significance test)
Time Benzene Toluene I-Ben*, xylene BTEX
(yre)





0-5
21
84
48
55
18
5-10
16
3
12
5
8
10-15
13

3
3
10
15-20
5


5
5
20-25



8

25-30
3



3
30-50
S
3
3

5
50-100
5

3

5
>100
29
10
31
24
46
TIME TO MEET STANDARD AT A SITEC/o)
(no significance test)
Time Benzene Toluene B-Benx. Xylene BTEX
(yr»)





0-5
8
75
20
33
8
5-10
17
8
8
8
8
10-15
17

8
8
8
15-20
8


8
8
20-25





25-30





30-50





50-100





>100
50
17
60
43

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BENZENE RECOVERY ANAL YSIS
9 Multiply concentration x flow rate
in recovery welL
9 Plot cumulative recovery versus
time.
9 Convert to equivalent gallons
gasoline.
EQUIVALENT GASOLINE RECOVERY
(based on Kg Benzene)
EQUIVALENT GASOLINE RECOVERY

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EQUIVALENT GASOLINE RECO VERY
Site Flowrate	Time Benzene	Gas
(gpm)	(yrs) (Kg)	(gal)
A 3.5	4 67	1196
B 4.0	4 118	2106
C 2.0	5 50	893
D 3.0	6 156	2793
CONCLUSIONS
9 Pump and Treat is not effective at
meeting groundwater quality
standards.
Q Pump and Treat is effective at
removing significant amounts of
BTEX from the ground.
O Most systems are designed for
containment only, not remediation.
RECOMMENDA TIONS
O Maximize pumping rates to remove
more contaminant
O Use mass recovery analysis to determine
when system modifications are needed.

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SUCCESSES AND FAILURES USING ALTERNATIVE TECHNOLOGIES AT
GROUNDWATER CONTAMINATED SITES IN NORTH CAROLINA
Burrie vD. Boshoff
North Carolina Department of Environment, Health and
Natural Resources
Division of Environmental Management - Groundwater Section
Conventional pump and treat systems have been installed and
operated at many UST sites in North Carolina. These systems have
had varied success although none of the sites have been closed
out. This can be contributed to several factors such as pump and
treat systems are inherently less effective at restoring
groundwater guality but more effective in preventing contaminant
migration; existing systems have been either improperly used or
were designed with a limited ability to remediate groundwater;
groundwater cleanup requirements in North Carolina are relatively
more stringent than in many other states; and the time since
operation was started at these systems is fairly short.
Alternative treatment technologies have been introduced with
high expectations and claims by consultants that sites will be
cleaned up much quicker and at significantly lower cost.
Innovative systems have been put into operation, but experience
from these identified some pitfalls which prompted the development
of guidelines to be used by field personnel. Some of the
successes and problems are illustrated by the following three
examples:
Examples of Alternative Technologies
i) Pump and Treat with Bioremediation
The former Dennis Equipment Rental had seven USTs with
gasoline arid diesel releases. The site is located in the Triassic
Basin of central North Carolina, which is primarily composed of
mudstones and siltstones. The soils encountered consisted mainly
of fine sandy clays and silty clays, with occasional clay lenses
and rock fragments. The site hydrology is interpreted as an
unconfined water table aquifer with an estimated saturated
thickness of approximately 15 ft. Petroleum hydrocarbon (PHC)
concentrations detected in the soil amounted to 12,000 ppm
gasoline and 3,000 ppm diesel fuel. The groundwater contained
7 7.1 ppm BTEX and 215.5 ppm TPHCs. A pump and treat system was
installed consisting of a bioremediation system to treat the
groundwater using a closed-loop treatment program with recovery
wells and infiltration galleries. Recovery well and biotreatment
system influent and effluent samples were collected and analyzed
on a weekly basis for the first several months of the project.
Sampling was then reduced to biweekly of bioreactor influent and
effluent, and monthly sampling of recovery wells and selected
monitoring wells. Over a period of two years, this system reduced
the PHC concentration in the soil to 2,900 ppm gasoline and less
than 10 ppm diesel fuel. The concentration of BTEX in the

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groundwater was reduced to 24.9 ppm. The total cost of the
cleanup operation performed to date amounts to $578,627 which
includes construction and maintenance costs. Operation and
maintenance and lease costs per month are about $12,000. Concern
about the system at this stage is mainly due to the high cost
especially for operation and maintenance. The question that comes
to mind is whether the same cleanup could not have been achieved
if all contaminated soil was excavated and hauled away during the
first month. In which case, costs may have been reduced to about
$150,000 and the same results could have been achieved in a much
shorter time.
A major concern has developed with innovative technologies
where consultants have patent rights on a system or part of a
system. The system is then installed and leased at a monthly rate
which turns out to be quite substantial. This has prompted a
policy whereby systems will only be leased to an amount equal to
the purchase price of such a system. A further complication of
systems where patents are pending is that the patent holder does
not want any information about the system to be released or
published until the patent has been granted. This is in conflict
with the 40 CFR 280.67 federal rules and state rules. Corrective
action plans cannot be approved with any stipulation that prevents
the public notice or information being distributed to interested
parties.
ii) Vacuum Air Sparging System
Dodge Store, Fayetteville, North Carolina is a former retail
gasoline outlet and convenience store located in central North
Carolina on flat land with a slight slope from the front toward
the back. Groundwater flow was determined to be in a
northwesterly direction and parallel to the road in front of the
store. A gasoline release was associated with a five-tank
complex. The surficial aquifer is a heterogeneous mixture of
sand, silt and clay layers and the water table is generally just
below 10-11 feet in most monitoring wells. There is a thick and
hard clay layer starting about 10 to 13 feet deep beneath the
southeastern part of the site, but it is absent on the
northwestern part, being replaced by sand with some silt. A
vacuum air sparging system was installed using sparging wells and
vacuum lines on the same wells. One of the main concerns about
this system was that there is a patent pending on the design of
the system. Further questions were raised on how effective the
system was because all but one of the monitoring wells were
eventually used for sparging wells and the sparging wells were
used to sample and determine the groundwater cleanup status.
Information is still needed to determine the radius of influence
of the system and to what extent the system is actually cleaning
up the groundwater. Several requests to the consultant to provide
this information were unsuccessful and approval of this system for
any other sites is being withheld subject to submittal of the
requested information.

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iii) Conventional Vacuum Air Sparging System
The Corner Store located on the southwest corner of
intersection of N.C. Highway 71 and State Road 1312, Robeson
County, had five USTs removed. Initial assessment indicated a
release of petroleum hydrocarbons had impacted soil and
groundwater in the area. Five residential potable water supply
wells were impacted. Eight county water supply wells are located
within one mile of the site, pumping a combined total of over 8.5
million gallons per day. The soils encountered varied from fine
through course sand with underlying clayey sand and streaks of
coarse sand and sandy clay. Four monitoring wells were installed
initially and sampled with nearby county supply wells. Total
contaminant concentrations detected ranged from 6 ppb to 60,330
ppb. MTBE was the only compound detected in one of the county
supply wells at a concentration of 5 ppb. An air sparging system
consisting of four sparging points were installed around the west
and south sides of the former UST pit and vary in depth between 28
and 35.5 feet. The points were constructed identically to 2-inch
monitoring wells with a 2-foot screen at the bottom and were
terminated from 7 to 12 feet below the water table. Individual
PVC air lines were trenched in to each well and connected below
grade. A soil vapor extraction system was installed to operate in
conjunction with the air sparging system. It was recognized that
a pump and treat system may be necessary as an additional
treatment system because of (1) the depth of confirmed
contamination in groundwater, (2) the depth limitations of the air
sparging system, and (3) the known effects of pumping rate at one
of the county supply wells. The pump and treat system would serve
to begin treatment of the highly contaminated groundwater in the
vicinity of the former USTs, as well as assist in counteracting
the pumping effects of the county supply well to limit to the
extent practical any continued plume migration. The air sparging
system is limited to the treatment of the upper 20 feet of the
shallow aquifer, due to pressure restrictions associated with
oil-less blowers required by the State of North Carolina. The
vacuum air sparging system was operated for approximately eight
months and significant results have been obtained in that MTBE
concentration was reduced from 8,600 ppb to 270 ppb, benzene from
12,000 to 100 ppb, toluene from 21,000 to 940 ppb and xylenes from
17,000 to 3,200 ppb.
Guidelines on the Use of Innovative Technologies
New and innovative assessment and remediation technologies
are continually being developed and proposed for sites throughout
North Carolina. The question is frequently raised about how they
should be dealt with from regulatory and trust fund reimbursement
standpoints. In general, the Groundwater Section encourages the
use of new and innovative approaches and technologies for
assessment and remediation. However, the State Trust Funds should
not be used to finance research and development of untried and
untested methods and technologies.

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The following guidelines were formulated to address the use
of new and innovative technologies for site assessment and
remediation activities. It treats the approval and cost
reimbursement of innovative technologies with a documented history
of successful application or testing differently than technologies
which are untried or untested.
Assessment
Current assessment technologies and investigatory methods are
effective, but substantive improvements may be possible. The use
of new technologies and methods may increase the amount of data
available for the money spent or may provide a more accurate
result. Because the assessment is the basis for all subsequent
actions taken at a site, the use of new and innovative approaches
and technologies that could provide better or more complete
information should be encouraged. At the same time, these new
methods should be approached cautiously.
A consultant, vendor or tank owner proposing a new site
assessment technology should demonstrate that it has a reasonable
probability of providing additional or more reliable information
than conventional methods or will provide equivalent information
at equal or lesser cost. The following information should be
provided:
1.	A description of the tecnnology's operation.
2.	Detailed results of previous site testing (either full
or pilot scale) which describe the characteristics of
site(s) with respect to geology, hydrogeology, and
contaminants present.
3.	A summary of the technology's applicabilities and
limitations due to site and contaminant characteristics,
and onsite or offsite interferences.
4.	Identification of the financial or technical benefits.
If based upon the above information the consultant
demonstrates that the new technology has been successfully used or
tested on other sites with similar characteristics and
contaminants, and that the technology is applicable for the
proposed site, the new method may be approved for use as a
stand-alone method. As long as the technology is used in an
efficient manner, meeting the criteria of "reasonable and
necessary" as applied to other assessment technologies, the State
Trust Fund would reimburse the activity.
If an approach appears to have merit, but there has not been
adequate testing conducted to make the above demonstration (e.g.
it has had limited testing or use, but in different geologic
settings or with different contaminants), it should only be
permitted as a supplemental method or technology. The use of
untested assessment methods and technologies should be relegated
to a duplicative role only. The cost of using an untested method

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in this role should be the risk of the consultant or responsible
party.
Remediation
New technologies or methods which can be demonstrated to
increase the effectiveness of a remedial action or may reduce the
cost should be encouraged, as long as they do not reduce the
ability to control the threats to human health or the environment.
In essence, new methods and technologies should only be
approved on a trial basis and only if the consultant can
demonstrate that it has a high probability of being as effective
as other methods and at a cost equal to or less than conventional
methods. All cost comparisons should assume an equal duration of
cleanup activities, unless substantial information to the contrary
is provided. The demonstration must include use at other sites or
pilot scale testing and the consultant must provide the following
information:
1.	A description of the technology's operation.
2.	Detailed results of previous site testing (either full
or pilot scale) which describe the characteristics of
site(s) with respect to geology, hydrogeology, and
contaminants present.
3.	A summary of the technology's applicabilities and
limitations due to site and contaminant characteristics,
and onsite or offsite interferences.
4.	Identification of the financial or technical benefits as
compared to conventional methods.
Any approval of a new approach or technology should be as an
"interim" remedial measure only until it has been shown to be
effective on that particular site. Such interim measures should
be reviewed^ and approved (or denied) on a site-by-site basis for
limited periods. The length of this interim approval will vary
based on the technology and site specific conditions; generally a
12-month operational/monitoring period under interim approval with
quarterly review of the data will be appropriate.
The number of sites for which interim approval of a specific
innovative method or technology is given should be limited until
the Department has some real knowledge that this approach will
have the benefits at least equal to those already offered by
existing methods and technologies; generally, this interim
approval should be limited to three (3) sites statewide until
monitoring data show that the technology is working. A remedial
action technology which obtains "interim" approval would be
eligible for reimbursement of reasonable and necessary costs
through the end of the trial period and beyond if it proves to be
successful and cost effective.
Before any methods or technologies are incorporated into an

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review of the effectiveness and applicability of the proposed
method or technology to the specific site. In addition, no
approach or technology (new or existing) should be assumed to be
universally applicable. The technical staff should use their
scientific and engineering knowledge and experience to evaluate
the methods and technologies proposed for each site. A given
technology should be approved in a CAP only where it was used as
an interim remedial measure or where the conditions are obviously
equivalent to such a site in all critical parameters.
Because the Department's primary mandate is to protect human
health and the environment, care should be exercised to minimize
the potential for additional threats when approving any
technology. Untried remedial approaches and technologies should
only be allowed at sites where a delay in effectively cleaning up
does not significantly increase the threat to human health. The
cost of using an untested remediation technology should be at the
risk of the consultant or responsible party. The State Trust Fund
will not reimburse costs associated with use of this technology
unless it proves to be successful. To be considered successful ,
the innovative technology must be shown to remediate the site to,
at least, the extent that an appropriate conventional technology
would have, at equal or lesser cost.

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DEVELOPING A CONCEPTUAL FRAMEWORK AND RATIONAL GOALS FOR
GROUNDWATER REMEDIATION AT DNAPL SITES
J.A. Cherry, S. Feenstra, and D.M. Mackay
Waterloo Centre for Groundwater Research
University of Waterloo
Waterloo, Ontario
N2L 3G1 Canada
For Publication in Proceedings of:
Subsurface Restoration Conference
Third International Conference on
Ground Water Quality Research
Dallas, Texas, June 21-24, 1992
DRAFT

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ABSTRACT
Many tens of thousands of sites with DNAPL in groundwater exist across North America
including most Superfund sites, many RCRA sites, and many military and municipal lands.
Chlorinated solvents are the most common DNAPL problem. Few, if any, DNAPL sites have
been permanendy restored although many attempts have been made using pump-and-treat.
DNAPL-contaminated aquifers have two segments: the source zone where immiscible-phase
liquid is the primary cause of contamination, and the plume where contamination is dissolved
and sorbed and where immiscible-phase liquid is absent. This paper categorizes technologies in
the context of source zones and plumes. It considers technologies that are proven and those that
are experimental, for containment and also for restoration. A conceptual framework is presented
for remediation tasks and goals. Emphasis if directed at the potential role for relatively passive
technologies for containing source zones and plumes without need for pump-and-treat. Except
for cutoff wall enclosures, passive technologies are new, including permeable treatment curtains
and funnel-and-gate systems that can be placed across plumes/5r downgradient of source zones.
The challenge facing these new technologies for containment of dissolved contamination is
considerable but not near that required for source-zone restoration, which is an elusive goal
because essentially all of the immiscible-phase must be removed to restore the source-zone part
of the aquifer to drinking water use. The development of cost-effective source removal
technologies will be slow, arduous, and expensive. Thus, we are transferring into the next
century the task of operating and maintaining numerous active containment systems in order to
prevent further growth or spread of contaminants from subsurface source zones. Although the
transfer of this responsibility is presently unavoidable, today we have an opportunity to enhance

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possibilities for future remedial efforts by a systematic advance of scientific and engineering
knowledge of the processes and performance of remediation technologies.

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INTRODUCTION
Remediation or remedial measures conducted at .sites of subsurface contamination are
engineered activities designed to protect present or future human health and maintain or improve
environmental quality. Subsurface contamination may occur as soil contamination (ie.,
contamination in the vadose zone) or groundwater contamination (ie., contamination below the
water table) or both. Subsurface contamination may present a variety of types of risks including
risks via groundwater usage, surface water usage, soil contact, vapour inhalation, or food
consumption. Any of these risks may provide cause for subsurface remediation. However, the
nature of the subsurface problem and the strategy for remediation depends greatly on which of
these risks are significant and what degree of risk reduction or environmental protection is
required.
This paper provides a conceptual development of subsurface remediation goals, that are
rational and consistent with our present understanding of subsurface contamination caused by
industrial organic liquids, particularly organic chemicals thayare immiscible and heavier-than-
water. These liquids are commonly known as DNAPLs (dense non-aqueous phase liquids) and
commercial, industrial, and waste disposal sites where DNAPL is the major cause of
groundwater contamination are referred to as DNAPL sites. In the 1980's, it became evident in
North America and Europe that portions of many aquifers had become contaminated by a variety
of chemicals of industrial, municipal, or agricultural origin, particularly nitrate, chloride and
sulphate salts, metals, and industrial organic chemicals. Most sites that have received, or will
soon receive, major remediation efforts are afflicted with DNAPLs, the most common of which
are chlorinated solvents. Other important DNAPLs are: creosote, coal tap, PCB oils, some types

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of mixed organic industrial wastes and some pesticides in pure-product form. Chlorinated
solvents (such as trichloroethylene, tetrachloroethylene, trichloroethene, and methylene chloride)
have been used by nearly all manufacturing industries in North America and continue to be used
by many. Also, chlorinated solvents have been used for many decades in most dry cleaning
facilities. They are much more common than was thought to be the case a few years ago. Most
Superfund sites, most military facilities, and many RCRA sites are in this category. Many of the
U.S. Department of Eftergy's sites have DNAPL in the subsurface along with other types of
contaminants. Realization that DNAPLs are common at industrial and military sites came
gradually over a decade, evolving from the interpretations of site conditions by a few
groundwater scientists in the earl$f 1980's to broad recognition by the groundwater profession
by the early 1990's. Although the occurrence of DNAPLs at many sites across the continent is
now recognized, there is currently no consensus on how to deal with this immense groundwater
problem. DNAPL sites pose much greater technical problems and financial burdens than other
types of sites. Meeting regulatory cleanup criteria is elusive at most DNAPL sites. This paper
is intended to provide a structural scientific framework for conduct of debate on this issue.
Figure 1 shows schematic diagrams for three different conceptual models for groundwater
contamination caused by industrial chemicals. In the simplest model (Figure la), plumes of
contaminated groundwater are caused by leaching of contaminants from the soil or waste situated
above the water table. Permanent restoration of such a site can be relatively simple, though not
necessarily inexpensive: remove the contaminated soil or waste by excavation or remove the
contaminants from the soil or waste by in situ methods, and then extract the plume by
groundwater pump-and-treat. It is now clear that this model fits only a very small proportion of

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those industrial sites where organic contaminants exist in groundwater. In the second model
(Figure lb), petroleum products such as gasoline, fuel oil, or kerosene (ie., LNAPLs - light non-
aqueous phase liquids or immiscible liquids less dense than water), exist above the water table
or in the zone of water table fluctuation. This subsurface mass of immiscible liquid emits
dissolved contaminants to groundwater and soil water, causing a plume to form. Contaminant
plumes from LNAPLs are usually not large mainly because natural microbiological degradation
of LNAPL-derived constituents in the plumes usually restricts growth of the plumes. Also, the
fact that LNAPLs do not penetrate much below the water table tends to limit LNAPL-derived
plumes to relatively shallow depths and therefore to restrict spread of plumes because shallow
groundwater usually encounters local hydrologic boundaries. This is not to say that some plumes
from LNAPL sources do not cause major problems, but rather that the problems are generally
much more limited in geographic extent than other types of plumes, particularly plumes at
DNAPL sites. To permanently clean an LNAPL site, the mass of immiscible-phase liquid in the
subsurface, above and below the water table, must be removal by excavation, or by extraction
processes and in- situ destruction and the plume must be removed by pump-and-treat or in situ
degradation.
The most difficult site to remediate is represented in Figure lc. The primary cause of
contaminant at DNAPL sites is slow dissolution of the mass of immiscible organic liquid situated
below the water table. In Germany, Frederich Schwille recognized the importance of this type
of groundwater contamination in the 1970's. Schwille (1982, 1984) conducted intensive
laboratory research on chlorinated solvents in groundwater. Schwille's work was not known in
North America until 1984. Villaume (1983) published the first North American paper describing

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DNAPL (creosote) in groundwater, but it was not until the mid- to late-1980's that the
conceptual model displayed in Figure lc and its extension into a DNAPL paradigm became
known amongst groundwater scientists and engineers in North America (Cherry, 1984; Mackay
et al., 1985; Mackay and Cherry, 1989; Feenstra, 1984). Specific consideration of DNAPL sites
was not included in the late 1980's edition of the U.S. EPA guidance document for remedial
investigations of Superfund sites (U.S. EPA, 1988). It was not until the early 1990's that the
general implications of DNAPL for site monitoring and remediation were recognized by the U.S.
Environmental Protection Agency (U.S. EPA, 1991). Such official recognition has not yet been
made by regulatory agencies in Canada, Mexico, or Europe. The fact that it took about a decade
for the new paradigm to move faim creation by a small segment of the scientific community to
widespread recognition is not surprising. Paradigm shifts in science and engineering often take
a decade or more. Unfortunately, the large and costly effort of site investigation and subsurface
remediation undertaken in the United States in the 1980's and continuing in the 1990's is based
primarily on concepts for site conditions represented by non-DNAPL causes of contamination
(Figures la and lb). DNAPL sites typically have groundwater contamination that is deeper and
much more widespread than is common at other sites. The main hazardous organic contaminants
in groundwater at DNAPL sites tend to be more persistent than those at LNAPL sites.
Some industry; sites have very complex conditions of subsun. ce contamination better
represented by a combination of the three conceptual models shown in Figure 1 rather than any
one of the models. At these sites, the DNAPL part of the problem is usually deeper in the
subsurface and most difficult to remediate permanently.

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REMEDIATION CONCEPTS AND TERMINOLOGY
Groundwater remediation technologies can be grouped in two general categories: proven or
experimental. To be classified as a proven technology, a technology must have been applied
previously at a sufficient number of sites so that a base of general knowledge has been developed
to allow detailed design and reliable estimation of the cost and time required to achieve a
specific remedial goal. Experimental technologies are those for which there is an expectation of
effectiveness based on conceptual models, computer models, laboratory studies, or field trails,
but for which performance cannot yet be predicted reliably.
Another useful categorization of remediation technologies distinguishes between those that
are active or passive. Active technologies are those that require a considerable amount of
ongoing engineering activity (operations, monitoring, and maintenance) to maintain adequate
performance of the technology. Conventional groundwater pump-and-treat is an example of an
active technology. In contrast, passive technologies are those that are put in place and
subsequently require little or no ongoing energy inputs or maintenance other than performance
monitoring. Low-permeability caps and covers to minimize infiltration and plume generation are
examples of passive technologies. Active technologies have the disadvantage of transferring
significant operating costs to future generations, whereas passive technologies minimize such
transfer.
Subsurface chemical masses that emit persistent groundwater plumes are referred to as
sources or source zones. Commonly, the most important sources at industrial sites are masses
of heavier-than-water immiscible industrial liquids (DNAPLs) located below the water table
(Figure 2). However, old drums or tanks containing chemicals or near-surface soils or sludges

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may also be active sources of groundwater contamination. At many sites, even when the drums,
tanks, sludges, and soils are removed, the DNAPL that remains in the subsurface represents a
significant continuing source of groundwater contamination. Until this subsurface source is
removed, the plume will continue to receive contaminants leached from the DNAPL.
Considering the relatively low solubilities of DNAPL chemicals and low drinking water
standards for many DNAPL chemicals, plumes may be generated in this fashion for very long
periods of time, even when the mass of DNAPL in the subsurface source zones is relatively
small. Removal of the subsurface source zones to a degree that prevents continued formation of
the plume is by far the most difficult task in aquifer restoration. The DNAPL mass that exists
below the water table typically represents a much greater groundwater problem than any buried
drums or buried sludge or soil that may exist at the site. The concept of the source of
groundwater contamination at a DNAPL site represents a dichotomy: for groundwater scientists
and engineers focused on the technical matters of groundwater remediation, the most significant
'source' is generally the mass of immiscible liquid residing below the water table, whereas for
the regulatory or the legal community, the 'significant source' on the property is commonly the
buried drums or sludge that still remains. The buried drums and sludge are typically all above
the water table. The regulatory or legal viewpoint is what governs most remedial actions at
industrial sites. Thus, at many DNAPL sites, particularly Superfund and RCRA sites, large
remedial effort is commonly directed at the drum or sludge 'source' and little effort at the
below-water table DNAPL source. Thus, at many DNAPL sites, the dichotomy in the concept
of 'source' results in 'source remediation' for which benefits in risk reduction and improvement
in groundwater quality may be minimal even after large expenditures have been made.

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In the groundwater context, risk can be reduced or eliminated by controlling the migration
of the aqueous-phase and vapour-phase plumes to achieve plume containment. A fully contained
plume leads to no further expansion of contamination in the groundwater zone. Thus, around a
contained plume, no additional portion of the groundwater resource is becoming contaminated.
At many, if not most, DNAPL sites, full containment is not achievable without engineered
controls such as groundwater pump-and-treat (Figure 3a). In order to eliminate or reduce risk
to an acceptable level, remedial measures for plume containment must continue for as long as
the subsurface source zone persists. This typically requires long-term application of technologies
such as groundwater pump-and-treat. In some cases, the condition offull containment is achieved
by natural site circumstances. An example would be a plume that emanates from the DNAPL
source and discharges into a nearby stream (Figure 3b). Although the plume may cause surface
water contamination, the portion of the contaminated aquifer does not expand, and therefore in
the context of the groundwater environment, the plume is contained naturally.
Aquifer restoration is a task much different from plume containment. Aquifer restoration
requires source~zone containment or source removal as well as plume removal to a degree
sufficient to provide for the original beneficial use of the aquifer. This beneficial use is
commonly drinking water supply. A fully restored aquifer is one that requires no further source
zone containment or plume containment (Figure 4). Of the thousands of contaminated aquifers
in North America, some have ongoing successful measures for plume containment, but very few
have been fully restored to drinking water use because of difficulties with source-zone
restoration. We know of no significant DNAPL site where full aquifer restoration has been
achieved and substantiated with detailed monitoring data. Claims of full aquifer restoration have

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generally not been confirmed by adequate testing, or the cleanup standard has been lenient, not
requiring restoration to drinking water use.
At the present time, the only remedial technologies that should be regarded as proven
technologies for most organic industrial chemicals in most hydrogeologic settings are: (i)
groundwater pump-and-treat for containment of groundwater plumes and source zones (but not
source removal); (ii) vertical cutoff walls coupled with hydraulic control inside the enclosure for
source zone containment, and, in some cases, coupled with caps for source containment; and (iii)
soil vapour extraction for containment of vapour plumes in the vadose zone, but not for complete
removal of all significant contaminant mass from the vadose zone.
On-going elimination of risk isCall areas outside of the source area and plume and prevention
of further degradation of environmental quality can generally be achieved by plume containment
without the necessity of significant reduction in contaminant mass in the source zone. It is
possible to perform cost-benefit analyses for pump-and-treat for plume containment if the risks
associated with the plume are known. In contrast, the lack of proven in situ technologies for
source removal, and hence for full aquifer restoration, renders cost-benefit analysis for these
technologies impossible because the ultimate cost of remediation cannot be defined. The difficult
and unresolved issue in groundwater remediation therefore pertains to the degree of effort and
the level of financial resources that should be directed towards the presently elusive goal of full
aquifer restoration. This goal is elusive because of the extreme uncertainty in the performance
of remediation technologies to achieve common regulatory cleanup criteria. This uncertainty
derives from the limitations inherent in the technologies and from the complications for
technology performance imparted by subsurface geologic heterogeneity. A technology that

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performs well in a simple geologic site situation can be entirely inadequate in a complex
geologic setting. There are many more complex sites than simple sites.
A partially restorea aquifer is an aquifer in which the segment of the plume between the
plume front and the downgradient periphery of the source zone (zone between A and B, Figure
5) has been removed, while the source zone is contained by engineered means such as cutoff
walls or pump-and-treat to prevent dissolved contaminants emitted from the source from causing
regrowth of the plume. Thus, partial restoration of the aquifer depends on long-term operation
of the source-zone containment system. Partial aquifer restoration makes available for use, the
portion of the aquifer in the area beyond the source-zone control system. Partial aquifer
restoration can be accomplished by one of two approaches: (1) plume removal by pump-and-treat
(Figure 5), or (2) plume renovation by natural-gradient groundwater flushing (Figure 6). Plume
removal by pump-and-treat enables the plume to be removed more rapidly (Figure 6a), whereas
plume renovation relies on natural groundwater flow to flush the plume from the aquifer. Once
the source zone containment system is functioning, the pluitfe exists only temporarily if there
is an engineered or natural discharge point. After the plume separates from the source zone, it
is flushed along the natural groundwater flowpaths toward points of groundwater discharge at
streams, rivers, wetlands, or water supply wells. Under these constraints; natural-gradient plume
flushing results in a flux of contamination to the river, lake, or water supply well for a finite
period of time.
The cumulative contaminant flux is the total initial contaminant mass in the plume (aqueous
and sorted phases) emitted from the groundwater flow system at the points of discharge over
the length of time of the emission. This emission at points of discharge is typically small. Once

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separated from the source zone, plumes normally have a small total aqueous and sorbed mass.
Mackay and Cherry (1989) provide examples of estimates of total aqueous phase contaminant
mass in several large plumes in sand or gravel aquifers. In some cases, part or all of the plume
mass may disappear due to biodegradation or abiotic degradation prior to arrival at groundwater
discharge points. In many cases, the point-of-discharge emission causes insignificant
environmental impact, and/or insignificant risk to actual or potential receptors. Plumes from
many LNAPLs and DNAPLs, particularly chlorinated solvents, only rarely cause detectable or
significant impact on rivers or lakes. Therefore, isolation of the source zone followed by natural
flushing for plume removal may be a reasonable option in many cases when decision-making can
be governed solely by issues of science and economics. In some cases, the emission involves
significant risk to receptors or causes a significant loss in use of water resources, surface water,
groundwater, or both. In such cases, these risks can be prevented by plume containment or
plume removal.
Full-scale plume-removal is the higher cost remedial option when compared to natural-
gradient plume renovation or plume containment. In full-scale plume removal, expenses accrue
from capital costs and operating and maintenance costs for the network of pumping wells and
water treatment and for performance monitoring. For natural-gradient plume renovation, the
main expense is monitoring to ensure that the aquifer renovation rate and impact at discharge
points such as rivers or lakes are within acceptable limits; the required source-zone containment
can usually be accomplished using only a small number of wells and a relatively small water-
treatment system or cutoff wall enclosure around the source zone with little or no pumping.

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At most sites where industrial organic contaminants are a groundwater problem, the majority
of the expense for groundwater pump-and-treat is due .to capital and operating costs for the
portion of the system needed for full-scale plume removal rather than the portion needed for
source containment. Therefore, selection of the full-scale plume removal option rather than the
natural-gradient plume renovation option coupled with source containment is a selection of a
higher-cost, lower-risk plan over one with a much lower cost and higher temporary risk. For
the selection to be done in a cost-benefit context, it is necessary that remedial designs specific
to each of these options be compared. Some pump-and-treat systems put into operation during
the 1980's were compromises that accomplished neither full containment of the source zone nor
removal of the plume.
A third option, intermediate between the two described above, is natural flushing with
capture. In this option, the source zone is contained (Figure 6a) and the front of the plume is
captured. The plume, thus detached from the source zone, is allowed to flush under only slightly
accelerated above natural gradient conditions to the downgradi^ftt capture system. This is a lower
cost option than the full-plume removal option because of less pumping and lower water
treatment costs. This option accomplishes the same goal as the full-plume removal option but
it takes longer for the plume to disappear.
TASKS IN PLUME CONTAINMENT AND AQUIFER RESTORATION
Remediation of a DNAPL or LNAPL site can be considered on the basis of four
fundamental tasks: plume-front containment, source-zone containment, plume removal, and
source removal. The first three of these tasks can be undertaken to accomplish partial aquifer

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restoration but all four must be applied for an attempt at full aquifer restoration (Figure 2).
Conventional pump-and-treat is a proven technology for accomplishing any of the first three of
these tasks. Pump-and-treat generally accomplishes plume front or source zone containment with
minimal difficulty if applied properly. Pump-and-treat is a viable technology for plume removal,
but at some sites, subsurface complexity causes large uncertainty in the time and cost to achieve
the specified degree of plume removal. Thus, long-term cost estimates for this task are generally
inaccurate or unreliable.'Groundwater pump-and-treat is generally inadequate to accomplish the
fourth task, source removal. Although conventional pump-and-treat can perform effectively for
three of the tasks, it is not inexpensive and involves substantial ongoing costs because of energy
use, maintenance, and monitoring.-^Therefore, there is incentive to develop less expensive and
generally more passive means of accomplishing these tasks. Experimental technologies aimed
at this goal are described briefly below.
Plume Front Capture
Most dissolved plumes are too large to be enclosed practically by cutoff wall barriers. The
goal of plume-front containment is to capture the entire mass flux at the front of the: plume
during the entire duration of the flux. Contaminant fluxes at the plume front are commonly
small, requiring a low annual rate of contaminant mass removal.Three potential engineering
options for capture or containment of the plume-front are 1) conventional pump-and-treat, 2) in
situ treatment curtains, and 3) in situ funnel-and-gates with in situ or ex-situ treatment (Figure
7). The options for plume-front containment are nearly the same as those for source-zone

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containment with the exception of cutoff wall barriers that can be used effectively at the source
zone in many cases but generally not at the plume front.
An in situ treatment curtain is a reactive permeable material placed as a wall vertically
across the plume (Figure 7b). As the plume passes through the curtain, physical, chemical, or
microbial processes remove the contaminants from the plume. An effective treatment curtain
avoids the need for removing water from the aquifer to achieve plume cutoff. The in situ
treatment curtain is currently an unproven or experimental technology. Various versions of the
technology for many contaminant species are being subjected to research and development.
Bums and Cherry (1992) describe the status of this research. Gillham and Burns (this volume)
provide a more recent review. Recently, prototypes of the technology have been installed at a
few field sites.
A funnel-and-gate system, also known as a wall-and-gate system, uses segments of
impervious wall to direct groundwater flow to engineered gaps in the wall, referred to as gates,
through which the plume is channelled (Figure 7c). As the #ater flows through the gate, the
contaminants are removed by comparable types of in situ treatment processes used in the in situ
treatment curtains (Figure 7d). Plume containment may be achieved by a single funnel-and-gate
placed across the entire plume, or if the plume is relatively wide, by a series of funnel-and-gates
across the plume. Intensive research on in situ treatment curtains and funnel-and-gate systems
began only recently. Starr and Cherry (1993) describe the hydraulic aspects of funnel-and-gate
systems. The first prototype funnel-and-gate system was installed at a field site in Canada in late
1992. The funnel-and-gate configuration for in situ treatment has an advantage over the curtain:
ease of installation and possibility for repair or rejuvenation.

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There are three general categories of in situ treatment zones, regardless of whether they are
positioned as curtains or in gates: 1) physical systems (e.g. air sparging); 2) chemical (abiotic)
systems, and 3) microbial systems (microbial filters). There are various types of air sparge
systems for containing or cutting off plumes, three of which involve pumping air into or through
a line of wells positioned in a row across the plume. In the other air sparge system, air is
sparged upward through the plume as it passes through gates in a funnel-and-gate system
(Pankow et al., 1993). In this type of funnel-and-gate, the gate is an open water column with
no porous medium packed in it. The injected air strips volatile organic contaminants from the
open water column in the gate. In each of the air sparge systems, air is used to strip volatile
contaminants from the groundwater in situ. The contaminants are swept to the vadose zone
where they are degraded or to ground surface where they are released to the atmosphere, or
collected and treated. In direct contrast to air sparge systems, which generally bring the
contaminants to land surface, the chemical or microbial treatment zones are intended to destroy
the contaminants in the treatment zone as the plume passes through it.
Source-Zone Containment
Source-zone containment may be accomplished by: (1) conventional pump-and-treat; (2)
cutoff wall enclosure with or without interior pump-and-treat; (3) in situ treatment curtain or
funnel-and-gate system immediately downgradient of the source zone; or (4) cutoff wall
enclosure with in situ treatment gates as outlets from the enclosure (Figure 8). The first two
approaches (Figures 8a and b) indicated above arc proven technologies for many sites, whereas
the others have components that are experimental. When conventional pump-and-treat is used

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for source zone containment, the pumping system need only capture the contaminant mass flux
emanating from the source. It is not necessary to remove mass at a rate that depletes the source
mass at a significantly higher rate than what is needed for source zone control. For source-zone
containment, as is also the case for plume-front containment, the required mass-removal rate
needed may be relatively small. In some circumstances, hydrogeologic complexities and
contaminant mass distributions are such that the only viable approach for source-zone
containment is pump-and-treat. In other situations, cutoff wall enclosures are a proven
technology. The choice can depend on total cost,-cash-flow factors, and future remedial
intentions. Pump-and-treat involves lower capital cost (design and construction of the water
treatment facility) and higher annual operating and maintenance costs than cutoff wall enclosure.
Cutoff wall enclosures will have a higher capital cost but may provide the opportunity for educed
operating costs resulting from lower groundwater pumping rates. The construction of a cutoff
wall enclosure may also facilitate further application of in situ remedial technologies such as
surfactant flushing.
Most DNAPLs are much more dense than water and, at many DNAPL sites, the bottom of
the immiscible-source mass is much deeper than non-DNAPL chemical substances would have
penetrated. At some sites, the bottom of the immiscible source mass is hundreds of metres deep,
in some cases deep into bedrock. Conventional cutoff walls generally cannot be installed to such
depths. At many sites, the bottom of the DNAPL has not yet been determined. In some cases,
shallower cutoff wall enclosures can be used to isolate the upper part of the source mass with
minimal pump-and-treat, leaving the deeper part to be contained by pump-and-treat.

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Cutoff wall enclosures can be installed in fractured bedrock at most sites and to greatest
depth by injection grouting. This technique involves injection of sealant (ie., grout) into closely
spaced boreholes to achieve sealing of fractures. The technique has been used for many decades
in the geotechnical industry to reduce groundwater seepage at dam sites and other large-project
construction sites. There is no doubt that considerable reduction in bulk hydraulic conductivity
is achievable in nearly all types of fractured rock, but often at very high cost. The degree of
hydraulic-conductivity reduction is generally much more difficult to predict and verify than is
the case for conventional cutoff wall enclosures in overburden or at shallow depth in soft
bedrock. As is the case for cutoff wall enclosures in overburden, decisions regarding selection
of cutoff wall enclosures by borehofe grouting should be founded on issues of cost and benefits.
There is no specific hydraulic conductivity that must be achieved in the cutoff wall enclosure
in order to be effective. Lower bulk hydraulic conductivity of the wall provides lower leakage
through the wall. Consequently a lower pumping rate inside the enclosure is required to
maintain a hydraulic gradient directed inward across the wall. The inward gradient prevents
outward lateral advection of dissolved contaminants. Lower pumping from the interior results
in lower long-term cost of water treatment. The long-term cost of water treatment "can be
reduced further by capping or diverting surface runoff in the area inside the enclosure to
minimize groundwater recharge. In some cases, much of the water entering the enclosure is
upward seepage from below. Upward seepage at the bottom of the enclosure is generally
desirable to prevent leakage of dissolved contaminants downward into deeper strata. However,
in some cases, natural downward hydraulic gradients may be too large to allow gradient reversal
to be imposed by pumping.

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There are several technologies available for construction of low-permeability cutoff-wall
enclosures (described by Mitchell, this volume). These technologies are proven technologies in
the sense that they can achieve specific, relatively low permeability values (less than 10"6 or 10"7
cm/s). There is very little published information pertaining to how long these barriers will
maintain low permeability. There is a need for research in the longevity of low-permeability
barriers. Many decades or centuries are generally expected. In the event that the permeability
of the wall increases, the consequence would be an increase in the rate of pumping from the
interior of the enclosure. If the increase in permeability of the wall is large, pump-and-treat
inside the enclosure evolves towards the conventional pump-and-treat option without a barrier.
The alternative would be to replace or repair the barrier. Repair of most vertical types of
barriers is generally a much easier task than the initial construction of the barrier. At sites where
no NAPL occurs, or where LNAPL but no DNAPL occurs, the depth to which the cutoff wall
must be installed is generally not great. The hydrogeologic nature of the bottom of the
subsurface source zone at these sites is less important than at DNAPL sites. For cutoff wall
enclosures to beJully effective at DNAPL sites, it is generally necessary for the bottom of the
wall to extend somewhat below the deepest zone of DNAPL. If the input of DNAPL to the
groundwater zone has ceased prior to construction of the wall, it is expected that the DNAPL
has already gone as deep as it will go under the existing conditions. It is important that the wall
be installed and the hydraulics of the enclosure be operated in a manner that DNAPL
remobilization is avoided. Pumping within the enclosure that dewaters the DNAPL zones may
cause further migration of the DNAPL downward.

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For source-zone containment, an alternative to combining cutoff-wall enclosures with
interior pumping is to place in situ treatment gates in the cutoff wall and thereby avoid interior
pumping. The water that enters the enclosure by infiltration of rain or snowmelt and by seepage
into the enclosure has contaminants removed when it flows through the gates at the downgradient
side of the enclosure. If the enclosure has a sufficiently low permeability , and if surface runoff
from the source zone area is diverted, the flux through the gates will be small because
groundwater recharge would be small. For most treatment processes within the gates, treatment
efficiencies will be greater flow low water flux rates through the gate. This fully passive
approach to source-zone containment is less suitable for sites where there is downward
contaminant migration out of the bfcttom of the enclosure.
Of the many experimental technologies being developed for groundwater remediation, those
that will accomplish plume containment and source-zone containment most passively and at
lower cost than conventional pump-and-treat offer the best prospects for advancing in the next
few years to the status of proven technologies. The technical challenge associated with
restoration of source zones at DNAPL sites is much greater than that of source-zone containment
or plume capture. The technical limitations imposed by geologic complexity are severe for
source-zone restoration, but commonly much less severe for source-zone containment or plume
containment. Several experimental technologies now in the research stage, such as surfactant
flush, alcohol flush, and chemical oxidant flush, are directed at removal of or in situ destruction
of contaminant mass from source zones. A secondary advantage provided by cutoff wall
enclosures is enhancement of the potential for more effective and environmentally safe
application of the above-mentioned in situ flush technologies. The enclosure can effectively

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prevent lateral escape of chemical reagents or aqueous contaminants mobilized during
immiscible-phase removal. Also, the enclosure minimizes the mass of chemical reagent that must
be added for effective enhancement of the mass removal or mass destruction processes. The
source zone situated inside the enclosure can be manipulated in a manner analogous to a very
large batch reactor rather than a groundwater flow system.
Plume Removal
Plumes can be removed using arrays of pumping wells positioned according to the well-
established principles of aquifer hydraulics and solute transport. The initial mass of aqueous
phase contamination in the plume can be removed by pumping but requires removal of much
more groundwater than that equivalent to the volume of the plume. Additional plume volumes
must be pumped to remove the mass of adsorbed-phase contamination and the mass of dissolved
and adsorbed phase stored in lower permeability zones in the plume and in aquitards above or
below the aquifer. Mathematical models can be used to determine optimal well positioning and
pumping rates to remove the plume in the shortest possible time. However, predictions of the
time required to achieve regulatory cleanup criteria are commonly unreliable due to processes
which generally cannot be accounted for rigorously by the models (Figure 10), such as
desorption effects, delayed yield from the capillary fringe, and diffusion out of low permeability
zones.
Possibilities exist for enhancing plume removal by combining pump-and-treat with aquifer
heating, chemical flushing, or microbial processes. However, we can expect that plume removal
is a task for which these new technologies may not provide much improvement in effectiveness

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or efficiency over conventional pump-and-treat. These enhancement processes for plume removal
are intended to stimulate removal or destruction of the initially adsorbed portion of the plume
mass. Efficiency of release of the adsorbed phase is expected to be inhibited at many sites by
geologic complexity and slow diffusion from low permeability zones.
Source Zone Restoration
Nearly all of the contaminant mass in the source zone is normally immiscible-phase organic
liquids relative to the other forms of contaminant mass: the dissolved and sorbed mass. If the
entire plume mass, excluding the source mass, is removed and if control of the source zone is
not maintained thereafter, the jtfume will reestablish itself due to continued dissolution of
immiscible phase into the groundwater. Conventional pump-and-treat is generally ineffective for
removing much of the immiscible phase mass because the mass removal rate is insufficient due
to dissolution and solubility constraints. Hydraulic systems such as pumping wells, and drainage
trenches, with or without water injection, can in some situations remove considerable
immiscible-phase mass, however, most of the immiscible-phase mass remains in the aquifer after
these systems have reached their effectiveness limit. Thus, to accomplish source mass reduction
beyond what can be accomplished by hydraulics alone, enhancement of the removal rate is
required by means of experimental technologies such as chemically enhanced pump-and-treat,
or other approaches such as steam flush or in situ chemical destruction of the NAPL.
Chemically enhanced pump-and-treat for removal of the immiscible-phase involves flushing
the DNAPL zone in the aquifer with water containing chemical additives or reagents (Figure
11). Research currently focuses on two categories of chemical additives: surfactants and alcohol.

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Surfactants added to water enhance the effective solubility of the DNAPL so that the contaminant
mass-removal rate by the surfactant-enhanced pump-and-treat is much greater than that of
conventional pump-and-treat (Wunderlich et al., 1992). For cost-effectiveness, it is generally
necessary to remove the contaminants from the mixture of water, surfactants, and contaminants
in above-ground facilities so that the surfactant solution can be used for repeated aquifer flushes.
The use of surfactants for removing DNAPL has recently progressed from laboratory studies to
small-scale field prototype tests of flush systems.
For alcohol flushing to be effective for removal of immiscible phase DNAPL, flushing must
be done with alcohol mixed with only a minor fraction of water. The cost of the alcohol is an
important factor and therefore the efficiency of each flush and potential for reuse of the alcohol
are critical factors. Alcohol flush for DNAPL removal is currently being assessed in laboratory
studies and has not yet reached the field prototype stage.
Another technology for flushing DNAPL from aquifers relies on the use of steam. Steam
injected into the source zone drives the contaminant in the inyniscible phase as well as in the
vapour phase to withdrawal wells. Udell and co-workers have advanced the understanding of the
physics of steam flush, using theoretical and laboratory studies, as well as small-scale field
trials. The effectiveness of steam flush for removing NAPL from below the water table is
currently being assessed by field prototype trials.
The flush technologies described above have in common the process of moving the DNAPL
mass from the aquifer via wells to above-ground facilities for treatment or disposal. An
alternative approach is to flush the source zone with chemicals that destroy the DNAPL in situ.
Schnarr and Farquhar (1992) conducted laboratory and prototype field trials at the Borden site

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in Canada of in situ chemical destruction of immiscible-phase chlorinated solvents. Additional
field trails are in progress. The destruction is accomplished using a strong chemical oxidant:
potassium permanganate.
There are several factors that can severely limit the effectiveness of mass removal from
source zones using surfactants, alcohol, steam, or chemical oxidants. Firstly, the injectant must
be very efficient for removal or destruction of the immiscible phase chemicals when brought in
contact with these chemicals. Secondly, if pump-and-treat is used as part of the flush system,
there must be effective facilities above ground for treating, recycling, or disposing of the
injectant and reaction products. Thirdly, the injectant chemicals and/or hazardous reaction
products from the in situ processes^must be prevented from escaping from the remediation zone
into other parts of the aquifer. Finally, the injectant must be brought sufficiently in contact with
the chemicals to enable the removal or destruction processes to be effective.
These latter two problems generally pose exceptional problems. At some sites, geologic
complexity and the nature and amount of DNAPL make the task of complete source-zone
restoration impossible because the injected solution cannot be made to contact adequately the
immiscible-phase contaminant mass. For chemical flush or steam flush technologies to be
effective, the spatial distribution of the immiscible phase DNAPL and the spatial distribution of
hydraulic conductivity in the groundwater zone must be favourable for contact between the flush
fluid and the immiscible phase. The contaminant-mass removal rates or in situ destruction rates
must be sufficient to produce source-zone restoration in a practical time period, a period of
months or years rather than decades. The spatial distributions of the immiscible phase and
hydraulic conductivity derive their character primarily from geologic heterogeneity or

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complexity. Current capability to characterize DNAPL source zones adequately to allow
prediction of the performance of technologies for in situ source removal or destruction is
minima]. The problem of contact between the flush fluid and the immiscible phase mass is
exacerbated by the fact that DNAPL presence lowers considerably the hydraulic conductivity of
the porous medium with respect to the aqueous solution in the portion of the aquifer where free-
product DNAPL resides. A proposed advantage of the steam flush method is that, if pressures
are released after initial heating, the NAPL caught in lower permeability zones may be made to
volatilize and advect into the more permeable strata (K. Udell, pers. comm.)
All technologies for in situ source removal or destruction of DNAPL have the potential to
make the site conditions worse rather than better. A particularly adverse possibility is
remobilization of DNAPLs, causing some of the DNAPL mass to sink deeper into the aquifer
or to sink through an aquitard into an underlying aquifer not previously contaminated.
Unfortunately, the state of knowledge of technologies for source mass-removal is poor pertaining
to their potential to cause DNAPL remobilization. Therefore, decisions to use in situ mass
removal or destruction technologies in source zones should not be taken lightly. Poorly
controlled experimentation at real sites can be hazardous to groundwater resources.
In the context of environmental safety, the ideal form of in situ source-zone remediation is
one that destroys the immiscible phase to an adequate degree, produces insignificant hazardous
reaction products in situ, and causes no adverse mobilization of the immiscible phase. For
chlorinated solvent DNAPLs, in situ destruction by chemical oxidation is the technology that
currently comes closest to meeting these performance criteria. However, knowledge of the

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degree of the effectiveness of this technology is currently limited to a few chlorinated solvents
in relatively pure form.-No trials at actual, industrial sites have yet been undertaken.
In some types of porous fractured rock such as sandstone and fractured clayey or silty
overburden, all or much of the mass of immiscible-phase organic liquid in the source zone may
have transferred from the immiscible phase in the fractures to the aqueous and sorbed phase in
the porous matrix over the years or decades since the immiscible mass entered the subsurface.
Rather than a favourable change in state, this transfer has a major negative effect. The
contaminants enter the matrix by molecular diffusion. The mass flux and time-scales of the
diffusion process back out of the porous matrix are such that no technology for source mass
removal (other than excavation),-Whether it be conventional pump-and-treat or any of the
chemically-enhanced, heat-enhanced, or steam-enhanced expermc-'al technologies when fully
developed, can be expected to accomplish effective source mass removal except over extended
periods of time (Parker et al., 1993).
DISCUSSION
Mass Removal
At DNAPL and LNAPL sites, nearly all of the contaminant mass occurs in the source zone
as immiscible phase organic liquid (DNAPL and LNAPL). Therefore, when full aquifer
restoration is the goal, essentially all of the immiscible phase mass must be removed.
Conventional pump-and-treat accomplishes source mass removal too slowly and therefore it is
not a practical technology for source mass removal.

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Some degree of mass removal is a consequence of most remedial measures. Containment
of source zones or plumes does not require a specific degree of mass removal. Containment
requires only that necessary changes in the groundwater flow pattern be imposed. However,
removal of a source zone or a plume clearly requires a specific degree of mass removal. At
DNAPL sites, it will seldom be possible to predict or even determine when a sufficient
percentage of the total mass has been removed to achieve full source zone restoration. The
cumulative mass removed by a remedial technology such as groundwater pump-and-treat or soil
vapour extraction can generally be measured reliably. However, at most sites, the total initial
mass in the plumes or the source zones is not known. Mass estimates for source zones,
particularly the part of the source zone below the water table, commonly have uncertainties of
one or more orders of magnitude. Consequently, it is not possible to compare reliably the mass
removed to the mass remaining (Figure 12a) and therefore the percentage of mass removed
cannot be determined.
For the most common type of DNAPL sites (chlorinated solvent sites), restoration of source
zones requires reduction of bulk soil concentrations in the source zone from hundreds to
thousands of parts per million to a part per million or lower. Restoration of the source zone to
such low levels may often require ultimate mass removal effectiveness greater than 99.9%. This
is a truly exceptional challenge for all in situ mass removal technologies. The best that the
petroleum industry is able to do when applying advanced technologies for oil recovery is 40 or
50% of oil removal from the geologic stratum. The difficulty of this challenge generally has
gone unrecognized. It may be viewed that any degree of mass removal is a beneficial step
towards eventual achievement of source zone restoration. However, from a-practical perspective,

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the benefits cannot be quantified unless the mass removed can be quantitatively related to the
degree of restoration achieved, or unless the mass .removed allows more cost-effective
implementation or elimination of other remedial measures that might otherwise be required.
Without such information, which is typically the case, the cost-benefit comparison for the mass
removal action cannot be made.
There are currently great expectations in government and industry for technologies such as
surfactant and steam flushing for restoration of DNAPL source zones. These technologies appear
capable of removing DNAPL mass much more rapidly than conventional pump-and-treat, as
illustrated in Figure 12b. The DNAPL mass removal graphs (Figures 12a and b) illustrate that
source restoration is characterized by diminishing returns. As the restoration proceeds, the
DNAPL mass remaining in the subsurface decreases, unfortunately, so does the efficiency of the
extraction technology. Considering that the remaining DNAPL mass must be reduced to a small
percentage of the original mass, the ultimate practicability of all enhanced removal technologies
is in doubt and will remain in doubt for some time because the necessary research will be slow,
difficult, and very expensive.
To select and compare rational options for remedial measures we must determine the
appropriate conceptual model for the subsurface contamination given the type of chemicals, the
nature of chemical release to the subsurface, and the hydrogeological setting. In simplest terms
this would be the determination of whether the site has or likely has immiscible-phase organic
liquids (LNAPL or DNAPL) in subsurface source zones and the approximate spatial extent and
character of such zones. Also, we must acquire sufficient site-specific information on the
subsurface conditions and distribution of contamination to define or estimate the lateral and

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vertical extent of the migrating aqueous-phase plumes. The two tasks indicated above need to
be accomplished only to the level of detail appropriate for consideration of the performance of
those technologies that appear, based on general knowledge of site use and conditions, to have
potential applicability. It should be clearly recognized which technologies are considered proven
technologies and which are experimental technologies in the site-specific context. A proven
technology for one type of site may be unproven or experimental for other types of sites.
Experience with groundwater pump-and-treat for common industrial organic contaminants
has shown that restoration of plumes (but not source zones) in sandy aquifers to achieve drinking
water standards is possible in a practical timeframe at some sites, but only after the source zones
are adequately identified and contained. Full restoration of significant subsurface source zones
has not yet been demonstrated. No technology or groups of technologies for in situ removal or
in situ destruction of chemical mass has yet advanced to the stage where it is possible to predict
when, or even if, sufficient restoration of DNAPL source zones can be achieved.
Issues of Time and Benefits
Until source zone restoration is achieved, it will be necessary to maintain a source-zone
control systems such as pump-and-treat or cutoff wall enclosures to prevent plume growth. With
no special source-mass removal activity, the pump-and-treat system at a typical DNAPL site may
need to function for centuries or longer before the source mass will be dissipated sufficiently to
meet an aquifer-restoration condition. When source mass removal is pursued by active
engineering means such as chemical flush or steam flush or in situ destruction (ie., enhanced
source mass removal), the number of years that might be required to .achieve restoration is

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reduced. Thus, if enhanced source-mass removal achieves only partial source-mass removal,
some benefit is achieved in terms of the duration of pu;np-and-treat. However, this benefit is
hypothetical only because its magnitude cannot be predicted and it accrues at some undefinable
future time. This hypothetical relationship of source mass removal to time-of-achievement of full
aquifer restoration is displayed schematically in Figure 13. For example, with no enhanced
source mass removal, the length of time that pump-and-treat would be necessary to achieve full
aquifer restoration might be 1,000 years. If enhanced source mass removal removes half of the
source mass and is then discontinued, the length of time necessary for pump-and-treat would be
some fraction of 1000 years, perhaps 500 years. A direct proportion assumption on time is
optimistic; a more plausible expectation is a much more adverse time relationship. The key issue
pertaining to partial source mass removal centres on the value of the ultimate benefits achieved
in the distant future by such removal relative to the cost of the removal. If the benefit does not
accrue for decades, then it has very little present worth and the source removal may not be
justified on solely economic grounds.
A major tenet of modem environmental ethics is the desirability of choosing courses of
action that will lead most rapidly and/or assuredly to a sustainable environmental and economic
condition. In a groundwater context, a sustainable environmental condition may be considered
to be a condition where groundwater resources are not significantly diminished in quality due
to continuing growth of contaminant plumes. Across North America, the ever-increasing number
of pump-and-treat systems for source-zone control represents large-scale action for risk control
and groundwater protection that cannot be considered sustainable in the long-term because pump-
and-treat is an excessively active (and expensive) technology. Pump-and-treat requires continuing

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commitment by future generations of their societal resources to maintain the pump-and-treat
facilities and for performance monitoring and energy use. Given the ephemeral nature of
governmental policies and the transient existence of some of the corporations that carry some
of the cost of the "in perpetuity" pump-and-treat burden, it is likely unreasonable to assume that
the pump-and-treat facilities put into operation in this century will continue to be maintained
properly or even maintained at all through the next century. Similarly, it may be unreasonable
to expect that sufficient societal resources will be available to evaluate ever-increasing reams of
monitoring data to determine if corrections and adjustments in the pump-and-treat systems are
required.
Full aquifer restoration is generally not achievable at DNAPL sites and, therefore,
unavoidably, our society must transfer responsibilities and risks associated with these sites to the
future. Given this transferred burden, we should ask what more positive legacy we may be able
to offer to future generations. Our best answer is that technologies for in situ aquifer remediation
will be improved considerably in the next few decades, but probably not in the next few years.
Therefore, onexif the goals of current aquifer remediation should be to pass to future generations
site conditions that are better suited for application of new technologies than the present
condition. Conventional pump-and-treat systems will likely contribute little towards this goal,
particularly if their performance and effects are monitored as casually as is typically the case at
present.
Conceptually, an array of remediation options are available for application to DNAPL sites
(Figure 13), ranging from the most 'active' option, which is aggressive, large-scale pump-and-
treat to the most passive, which has cutoff wall enclosures and in situ treatment systems without

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pump-and-treat. In situ treatment curtains and funnel-and-gates are new technologies still in the
prototype field trial stage. However, we expect that these technologies will advance rapidly in
the next few years. The in situ contaminant mass flux that these technologies must accommodate
in most plumes is not large and therefore the technical challenge is not particularly difficult.
However, even when these new technologies are fully developed, hydrogeologic conditions at
many sites, particularly fractured rock sties, are such that they will not be suitable, leaving only
pump-and-treat as the technically and economically viable option for groundwater remediation.
The Cap Dilemma
A common dilemma in decisionmaking for remediation of waste disposal sites is whether
or not to put a cap on the ground surface over the source zone. The construction of highly
engineered low-permeability surface covers (ie., caps) is commonly undertaken at waste disposal
sites. In many cases, much of the expense of the cap derives from a specification that the cap
prevent infiltration of rainwater and snowmelt through the waste. Prevention of infiltration
through the waste is intended to prevent groundwater contamination. This intention makes sense
if the site condition fits the conceptualization shown in Figure la where the entire source mass
is situated above the water table. However, if the site is a DNAPL site (Figure lc), allocation
of large financial resources to construct a cap to achieve low infiltration to the water table is
typically unwarranted on scientific grounds. At sites where appreciable DNAPL exists below the
water table, it is generally not possible to achieve any significant reduction in plume growth or
plume control by means of a cap. At DNAPL sites, the contribution of water to the plume from

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infiltration through the waste to the water table is typically very small in comparison to lateral
groundwater flow through the DNAPL zone (Figure 15).
At sites where chlorinated solvents exist above the water table, even if only in small
amounts, it is reasonable to expect that plumes of solvent vapour will occupy the vadose zone
beneath the site and will move by diffusion away from the site. Solvent vapour in the vadose
zone causes groundwater contamination by transfer of some vapour mass to the groundwater
zone. Mendoza and McAlary (1989) and Hughes and Gillham (1992) describe solvent vapour
migration in the vadose zone and its impact on groundwater. Placement of a low permeability
cap over the land area where immiscible-phase solvents occur in the vadose zone does not
necessarily diminish impacts of the solvents on groundwater. On the contrary, in many cases it
is likely that the cap increases the tendency of vapour to contaminate groundwater by causing
greater lateral spread of the vapour beneath and beyond the cap (Figure 16). This spread can be
prevented by vacuum extraction of vapour, however, this imposes a need for long-term active
engineering because full cleanup of vadose zone DNAPL by vacuum extraction typically takes
decades. Another alternative is to connect the cap to vertical low-permeability walls (ie.,
enclosures) that extend below the water table, with active or passive vapour venting.
In circumstances where source zone containment is implemented, the principal objective of
a cap may be to prevent direct exposure to the contaminated soil and to resist erosion and
weathering. These objectives may result in a cap design that is considerably different, and
perhaps less costly, than one intended to reduce infiltration.
The main issue addressed here is that a remedial action such as a cap, which is a beneficial
action at sites that have no solvent DNAPL, can be an beneficial option at solvent DNAPL sites

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unless the cap design is adapted to the special demands of the DNAPL problem. We expect that
a detailed post mortenvof the many caps that have been constructed at Superfund and RCRA
sites would show, because of DNAPL issues, that little or no benefit was achieved by the
groundwater environment, contrary to the expectation at the time that the cap was built. In fact,
many caps have probably been detrimental to groundwater remediation.
In Situ Bioremediatiod
Of the various types of experimental technologies for in situ remediation at industrial sites,
the one that has had the most research is in situ bioremediation. Unfortunately, the prognosis
for most types of in situ bioremediation at DNAPL sites is not good.
Nearly all DNAPLs in the immiscible phase are toxic to microbes. Also, the groundwater
in and near DNAPL source zones commonly has sufficiently high aqueous concentrations
leached from the DNAPL to be toxic to microbes. Therefore, in situ microbial technologies are
particularly ill-suited for removal of DNAPL mass from source-rone. There is some hope for
in situ microbial technologies to assist in the restoration of source zones at some stage after
chemical or steam flush technologies or after in situ chemical destruction technologies have
removed nearly all of the immiscible-phase mass from the source zone. This assumes, however,
that the primary technologies do not create a biological or geochemical environment that is
inhospitable to in situ bioremediation.
The potential for in situ microbial methods to be useful is greatest in the plume at some
distance from the DNAPL source zone where the aqueous-phase contaminant concentrations are
lower than levels toxic to microbes. However, the most common approaches suggested for in

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situ bioremediation of plumes involve injection of nutrients and electron acceptors (ie., oxygen)
into the plume to stimulate activity of natural microbes for destruction of contaminants that
desorb from the porous medium. This approach suffers from various limitations related to
delivery of the injectants to all zones where contamination is present. These limitations typically
derive from geologic complexity or heterogeneity. An alternative approach is to stimulate
microbial activity for in situ contaminant destruction in a permeable microbial curtain or in
funnel-and-gates placed across the plume. In this in situ use of bacteria, the contaminants are
bought to the microbial zone by natural groundwater flow and therefore much of the injectant
delivery problem is avoided. However, research on this type of in situ bioremediation is in its
infancy. The main challenge is to develop relatively passive life support systems for the in situ
microbial processes.
CONCLUDING STATEMENT
To date, when remedial measures are implemented to achieve source containment and/or
plume containment at DNAPL sites, the measures nearly always include pump-and-treat. In most
cases, these pump-and-treat systems will require operation "in perpetuity" because of our
inability to achieve adequate removal or restoration of DNAPL source zones. This approach does
not meet reasonable criteria for long-term environmental sustainability because pump-and-treat
is an excessively active technology. A more passive approach for source zone containment would
be the use of low-permeability cutoff-wall enclosures, coupled with minimal pump-and-treat or,
in some cases, no pump-and-treat. This approach involves higher up front capital expenditures
for construction but lower average annual long-term operations and maintenance costs. Since low

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permeability cutoff wall enclosures as well as pump-and-treat systems are proven technologies
for source zone containment, the choice is between one or the other of these two proven
technologies. Issues of long-term cost and environmental sustainability should govern the
technology choice. Cutoff wall enclosures may facilitate future use of promising in situ
technologies for source mass removal that are more difficult or risky to use without such
enclosures. There are many sites where significant mass of DNAPL exists too deep for use of
enclosure or in fractured bedrock. Cutoff wall technologies are much less well developed for
fractured rock than overburden, particularly hard rock. In hard rock such as granite, cutoff walls
in the conventional sense cannot be constructed. Other types of walls made by injecting sealants
into fractures via boreholes can be&onstructed but reliable prediction of the performance prior
to construction is generally not possible. In this situation, pump-and-treat is usually the only
proven technology available for source zone or plume containment.
Apparent failures in the arena of subsurface restoration abound because of the lack of clear
recognition of the difference between: (i) plume containment, (ii) plume removal, and (iii) full
aquifer restoration. Many attempts at aquifer restoration have been made or are in progress.
Remediation aimed directly at the goal of full aquifer restoration in this decade or even in the
next decade or two should be recognized clearly as experimentation rather than actual
remediation. In the United States, the Superfund process is intended to be primarily an aquifer
restoration program, but it cannot perform as such because of the nature of the subsurface
contamination at DNAPL sites and the inherent limitations of existing remedial technologies
relative to what must be accomplished to achieve full aquifer restoration. In a groundwater
context, most remedial efforts of the Superfund program be regarded as numerous and costly

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experiments; unfortunately, in scientific terms, they are relatively unmonitored experiments with
poorly defined hypotheses. In retrospect, the progress of these remedial efforts is best described
as "trial and error". Opportunities to acquire information that would ultimately provide better
remedial choices and designs and commensurate cost savings are being lost on a grand scale.
To derive benefits from careful site monitoring and experimentation, the experimentation
must be designed specifically to track and assess in detail the progress of the restoration or
plume containment attempts and to develop general scientific and engineering knowledge on the
remediation technologies. This is rarely done. Rather, in the United States and Canada
monitoring of remedial activities is generally implemented simply to satisfy basic regulatory
requirements. Even the data acquired from such basic monitoring are rarely studied to derive
guidance that will improve future efforts.
The acquisition of carefully-obtained scientific and engineering knowledge from large-scale
site experimentation will allow better design and implementation of remedial actions at other
sites. However, the benefits may accrue mainly to future activities at other sites and to future
generations of cleanup. Eventually, this class of large-scale experimentation is likely to pave the
way to an era of practical groundwater restoration where the stated goals are in fact achievable
in a practical time scale.
Large-scale experimentation with technologies for subsurface source removal or aquifer
restoration should normally be preceded by appropriate bench-scale studies, prototype technology
trials, and then pilot-scale technology assessments (Figure 17) in a variety of hydrogeological
settings. In the rush towards aquifer restoration that is driven by public opinion and legislation,
careful completion and critical review of each of these stages in technology development is

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rarely accomplished and hence large-scale site experimentation is hampered by a weak base of
fundamental knowledge even when large-scale field experimentation is accompanied by detailed
monitoring. Rigorous methods or protocols for technology trials and pilot-scale trials are not
well developed because of underemphasis of these essential steps in technology development.
It is truly unfortunate that, for most sites, today's technologies are inadequate for the task
of source mass removal, and hence inadequate for full aquifer restoration. The current use of
pump-and-treat or alternative technologies having the same intention, which can perform well
for plume or source zone containment but not for source removal, must therefore continue until
such time as more cost-effective mass removal and containment technologies are developed, or
until source zone restoration through mass removal can be accomplished. The development of
cost-effective source removal technologies will be slow, arduous, and expensive. Thus, we are
transferring into the next century the task of operating and maintaining numerous active
containment systems in order to prevent further growth or spread of contaminants from
subsurface source zones. Although the transfer of this responsibility is presently unavoidable;
today we have an opportunity to enhance possibilities for future remedial efforts by a systematic
advance of scientific and engineering knowledge of the processes and performance of
remediation technologies.

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ACKNOWLEDGEMENTS
This paper is a contribution from the University Solvents-In-Groundwater Research
Program, Phase n, supported by funds from the Natural Sciences and Engineering Research
Council (NSERC), the Ontario University Research Incentive Fund (URIF), and the following
corporations: Boeing, Ciba-Geigy, General Electric, Eastman Kodak, and Laidlaw
Environmental Services.

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phase organic liquids in fractured geologic media. Ground Water (submitted July).

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Schnarr, M.J. and Farquhar, G.J., 1992. An in situ oxidation technique to destroy residual
DNAPL from soil. Paper presented at Subsurface Restoration Conference, 3rd International
Conference on Ground Water Quality Research, Dallas, Texas, June 21-24.
Schwille, F., 1984. Volatile chlorinated hydrocarbons in porous and fractured media (in
German). Spec. Contrib. Germany Water Studies Annual Report No. 46, Federal Institute for
Water Studies, Koblenz, Germany.
Schwille, F., 1981. Groundwater pollution in porous media by fluids immiscible in water. The
Science of the Total Environment, 21:173-185.
Starr, R.C. and Cherry, J.A., 1993. In situ remediation of contaminated groundwater: The
funnel-and-gate system. Ground Water (submitted May).
U.S. Environmental Protection Agency, 1988. Guidance on remedial actions for remediation
actions for contaminated ground water at Superfund sites. EPA/540/-88-003.
U.S. Environmental Protection Agency, 1992. Dense nonaqueous phase liquids: A workshop
summary. Dallas, Texas, April 16-18.
Villaume, J.F., 1983. Recovery of coal gasification wastes: An innovative approach.
Proceedings Third National Symposium on Aquifer Restoration and Groundwater Monitoring,
National Water Well Association, Worthington, Ohio, 434-445.
Wunderlich, R.W., Fountain, J.C., and Jackson, R.E., 1992. In situ remediation of aquifers
contaminated with dense non-aqueous phase liquids by chemically enhanced solubilization. J.
Soil Contam., l(4):361-378.

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LIST OF FIGURES
Figure 1: Three different conceptual models for groundwater contamination: (a) non-
NAPL case; (b) LNAPL case; and (c) DNAPL case.
Figure 2: Anatomy of a DNAPL site: (a) plan view of source zone and plume; and (b)
vertical section of source zone. Note contaminant sources (sludge, drums,
contaminated soil, residual) above the water table and immiscible-phase
DNAPL (residual, lenses, pool) source below the water table.
Figure 3: Containment of plumes at DNAPL sites: (a) pump-and-treat for containment
of plume; and (b) natural hydrologic boundary (river bed).
Figure 4: Conceptual representation of aquifer restoration: source and plume removal
sufficient to meet cleanup standard: (a) before aquifer restoration; and (b)
conditions when fully restored; flux from source insufficient to produce
plume.
Figure 5: Conceptual representation of partial aquifer restoration using pump-and-
treat: (a) initial condition; (b) performance of plume purge wells and
contaminant well; and (c) partially restored aquifer with source zone
containment to prevent regrowth of plume.
Figure 6: Three approaches for achieving partial aquifer restoration: (a) aggressive
pump-and-treat; (b) flushing to containment well; and (c) natural flushing of
plume to hydrologic discharge zone (contaminant flux to river).
figure 7: An in situ treatment curtain for plume control: (a) plan view; (b) vertical
cross-section, both showing plume entering the treatment curtain and treated
plume water exiting downgradient side.
Figure 8: Options for source zone containment: (a) pump-and-treat; (b) cutoff wall
with interior pumping; (c) in situ treatment curtain; and (d) funnel-and-gate.
Solid dots are extraction wells, thick lines are impermeable walls, and areas
with small circles are permeable media.
Figure 9: Cutoff wall enclosures around DNAPL source zones: (a) natural gradient
case (b) inward flow everywhere induced by pump-and-treat (c) downward
flow from bottom cannot be reversed by pump-and-treat.
Figure 10: Influence of delay processes on time to completion of partial aquifer
restoration by pump-and-treat.

-------
Figure 11: Restoration of DNAPL source zone using chemically-enhanced flushing with
injection and withdrawal wells: (a) plan, injection and withdrawal wells for
chemical flush across source zone and purge wells to remove plume; and (b)
section; and (c) comparison of mass removal with and without chemical
enhancement.
Figure 12: Schematic representation of cumulative mass removal for restoration of
DNAPL source zones: (a) total mass in source zone is uncertain; (b)
technology performance graph contaminant mass in source zone assumed
known; and (c) discrepancy between desired performance and actual
performance caused by heterogeneity, etc.
Figure 13: Relationship of percent contaminant mass removed from source zone during
period of source zone restoration to time necessary to achieve full restoration of
source zone by conventional pump-and-treat.
Figure 14: Variety of options for full aquifer restoration: ranging from fully active
technology at top fully passive at bottom.
Figure 15: Contaminant contribution to groundwater plume from: A-A', zone of leaching
of contaminants from vadose zone to groundwater zone; and B-B', zone of
volatile from dissolution of DNAPL residual and pool causing main contaminant
flux to plume. A' flux is typically small relative to B' flux.
Figure 16: Comparison of the effect of caps on two source zones: (a) source materials exist
only above the water table and emit no contaminant vapour; (b) volatile source
materials exist above the water table causing contaminant vapour to contaminate
groundwater.
Figure 17: Stages in the development of groundwater remediation technology from concept

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NON NAPL
TANK LEAKAGE
LNAPL
	rut
FLOATING LNAPL
L5.-. PLUME;'—^
•	«	•	a	,	* 	•
RESIDUAL LNAPL
Figure 1: Three different conceptual models for groundwater cc.ntamination: (a) non-

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ANATOMY OF A DNAPL SITE
(a)
DNAPL ENTRY
LOCATIONS
DISSOLVED PHASE PLUME
GROUND
WATER
FLOW
S\
PROPERTY
BOUNDARY
DNAPL ZONE
RESIDUAL^UENSES
AND POOLS BELOW
WATER TABLE
(i.8. AREA OF
SUBSURFACE
DNAPL SOURCES)
PLUME OUTLINE
BASED ON SOME LIMIT
SUCH AS 0RINKIN6 WATER
MPC OR DETECTION LIMIT
PLUME
ADVANCE
TOWARDS
RECEPTORS
SUCH AS WELLS,
WETLANDS
OR STREAMS
(b)
VADOSE
ZONE
SOURCES
NFILTRATION
	2_
- SOURCE ZONE
CONTAMINATED
SLUDGE
DRUMS
7
FILL
CONTAMINATED
SOIL
GROUND-
WATER
ZONE i
SOURCES
->—'—7—T: "j ^—T 1 ' T—r—r
IMPERVIOUS LAYER
PLUME
TRAVELS
TOWARDS
RECEPTORS
Figure 2: Anatomy of a DNAPL site: (a) plan view of source zone and plume; and (b)
vertical section of source zone. Note contaminant sources (sludge, drums,
contaminated soil, residual) ab*>ve the water table and immiscible-phase

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PLUME CONTAINMENT
(a )
PUMP AND TREAT
FLOW
PLUME
PUMPING WELL
FOR PLUME
CONTAINMENT
/ '.'-JS
(b) NATURAL BOUNDARY
FLOW
Figure 3: Containment of plumes at DNAPL sites: (a) pump-and-treat for containment

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AQUIFER RESTORATION
(a) BEFORE AQUIFER RESTORATION
FLOW
-i—i r*
SOURCE-
ZONE
-L-LX
PLUME-
(b) FULLY RESTORED AQUIFER
F LOW
/"FORMERS
SOURCE
v ZONE /
"S	^"

FORMER PLUME
Figure 4: Conceptual representation of aquifer restoration: source and plume removal
sufficient to meet cleanup standard: (a) before aquifer restoration; and (b)
conditions when fully restored; flux from source insufficient to produce

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PARTIAL AQUIFER RESTORATION
(a)
(b)
SOURCE ZONE .
CONTAINMENT 1
WELL
PLUME PURGE
WELLS
"6*. *• o • '"o*' 'n.'-'
"N
SOURCE ZONE CONTAINMENT WELL
PLUME PURGE WELLS
—	MCL
(C)
PORTION OF RESTORED
AQUIFER
\
I
/
PERSISTANT
CONTAMINATION
Figure 5: Conceptual repres?"'.ation of partial aquifer restoration using pump-and-
treat: (a) initial - eition; (o) performance of plume purge wells and
contaminant wel ."-d (c) partially restored aquifer with source zone

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PARTIAL AQUIFER RE
(a )
THREE APPROACHES
(1) AGGRESSIVE PU MP - A ND - TREAT
SOURCE ZONE
CONTAIMENT
(2) FLUSHING TO CONTAIMENT WELL
CONTAINMENT
WELL
2 3 4 5 * »l
.v V \ > °n|
	*	*	is. _

(3) NATURAL FLUSHING OF PLUME
(b)


PROGRESS OF PARTIAL AQUIFER RESTORATION
LU
LU
<2
z o

-1 ^ > n
a. o 5 O
TIME
Figure 6: Three approaches for achieving partial aquifer restoration: (a) aggressive
pump-and-treat; (b) flushing to containment well; and (c) natural flushing of

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IN- SITU TREATMENT CURTAIN
(a)
FLOW
PLUME
IN - SITU TREATMENT
CURTAIN

a;
' L_
jgj.	^
A'
j
i#—
(b)
FLOW
FILL
BY CHEMICAL OR
MICROBIAL PROCESSES
V
X
A X


* V

•' • PLUME
• " >
• • •
• »
Jt' •
ZONE WITH NO
—~ CRITICAL CONTAMINANTS
REMOVAL OF //
0 • •
0 O9
^ PERMEABLE
MEDIUM
Figure 7:
An in situ treatment curtain for plume control: (a) plan view; $) vertical
cross-section, both showing plume entering the treatment curtain and treated

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SOURCE ZONE CONTAINMENT
PUMP a TREAT
CUTOFF WALL
ENCLOSURE
TREATMENT
CURTAIN

FUNNEL 8 GATE
Figure 8: Options for source zone containment: (a) pump-and-treat; (b) cutoff wall
with interior pumping; (c) in situ treatment curtain; and (d) funnel-and-gate.
Solid dots are extraction wells, thick lines are impermeable walls, and areas

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CUTOFF WALL SCENARIOS
CUTOFF WALL
FLOW UP
OR DOWN
AQUIFER
HEAD
PUMP 6 TREAT
/1 t t \
~
PUMP 8 TREAT
- ::Vi
¦ : V	' UNSATURATED ZONE
Figure 9:
Cutoff wall enclosures around DNAPL source zones: (a) natural gradient
case (b) inward flow everywhere induced by pump-and-treat (c) downward

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RESPONSE OF
PURGE WELLS
A	RAPID PLUME REMOVAL WHERE DELAY
PROCESSES ARE INSIGNIFICANT
B DELAY CAUSED BY PROCESSES SUCH AS
SLOW DESORPTION, DIFFUSION FROM LOW
PERMEABILITY ZONES IN THE AQUIFER
AND FROM AQUITARDS
MCL STANDARD TO WHICH CONCENTRATION
MUST DECLINE FOR SHUT DOWN
OF PUMP AND TREAT
Figure 10: Influence of deiay processes on lime to completion of partial aquifer

-------
SOURCE RESTORATION BY CHEMICAL FLUSH
(a) CHEMICAL FLUSH: INJECTION AND WITHDRAWAL WELLS
-v.rvjM. USING
PVJRGE
yjEU-S
SOURCE ZONE
^RESTORATION
CHEMICAL FLUSH			
, CONVENTIONAL
^ ^ ^ PUMP 8 TREAT
Tl ME
Figure 11: Restoration of DNAPL source zone using chemically-enhanced flushing with
injection and withdrawal wells: (a) plan, injection and withdrawal wells for
chemical fl,-sh across source zone and purge wells to remove plume; and (b)
section; and (c) comparison of mass removal with and without chemical

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~ ^UNCERTAINTY OF
^ J CONTAMINANT MASS IN SITU
/
'NEW
TECHNOLOGIES FOR
CONTAMINANT MASS REMOVAL
///^^		CONVENTIONAL
—	 p a t _
TIME
MASS REMOVAL FOR SOURCE
ZONE TO MEET CLEANUP STANDARD
"V PERFORMANCE OF MASS
REMOVAL TECHNOLOGY
TIME
T-
TECHNOLOGY LIMITATION :
EFFECT OF HETEROGENEITY
Schematic representation of cumulative mass removal for restoration of
DNAPL source zones: (a) total mass in source zone is uncertain; (b)
technology performance grapi" contaminant mass in source zone assumed

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NATURAL
FLOW —*
<
1
<
£
-J
Li.
SOURCE
ZONE '
&
s. J>>	p.
CONTAMINANT
MASS FLUX
FROM SOURCE
L /
A'
PERCENT SOURCE MASS
^INITIALLY REMOVED
0%
_L
DRINKING WATER —
, STANDARD
10 100 1000
YEARS
Figure 13:
Relationship of percent contaminant mass removed from source zone during
period of source zone restoration to time necessary to achieve full restoration of

-------
APPROACHES FOR SOURCE
CONTROL AND PLUME REMOVAL
UJ
> >
D O
Ll. <
FULL SCALE P and T
LlI
>
°3
CUTOFF WALL ENCLOSURE WITH
INTERIOR/EXTERIOR P and T
TREATMENT ZONE WITH PLUME/P and T
CUTOFF WALL ENCLOSURE WITH TWO
TREATMENT ZONES

Figure 14: Variety of options for full aquifer restoration: ranging from fully active

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AREA OF INPUT FROM
- RAIN/SNOW 	
VADOSE
ZONE
GROUNDWATER
ZONE
5
o
i
z
^	A CONTAMINATED SOIL
iVii.fYi
« . i J	'	.* '' ' Ttifc'
B
B'
^ RESIDUAL

POOL. .
Figure 15: Contaminant contribution to groundwater plume from: A-A', zone of leaching
of contaminants from vadose zone to groundwater zone; and B-B', zone of
volatile from dissolution of DNAPL residual and pool causing main contaminant

-------
CASE A WASTE WITH NON - VOLATILE CONTAMINANTS
CAP
CASE B WASTE WITH VOLATILE CONTAMINANTS
Figure 16: Comparison of the effect of caps on two source zones: (a) source materials exist
only above the water table and emit no contaminant vapour; (b) volatile source
materials exist above the water table causing contaminant vapour to contaminate

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STAGES IN TECHNOLOGY DEVELOPMENT
PROVEN
TECHNOLOG
EMERGING
TECHNOLOGY.
EXPERIMENTAL
TECHNOLOGY
COSTisjEFFECTIVE TECHNOLOGY
LARGE TRIALS
PROTOTYPE ASSESSMENT
FIELD STUDIES WITH RIGOROUS
MASS BALANCE CONSTRAINTS
SCREENING OF NUMEROUS
TECHNOLOGY CONCEPTS
CONCEPTS
Figure 17: Stages in the development of groundwater remediation technology from concept

-------
Reprinted from ENVIRONMENTAL SCIENCE & TECHNOLOGY, Vol. 23, Page 630, June 1989

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Groundwater
Pump-add-tr
Second of a me-part series
Douglas M. Mackay
University of California
Los Angeles, CA 90024
John A. Cherry
University of Waterloo
Waterloo, ON, Canada
Almost all remediation of groundwater
at contaminated sites is based on
groundwater extraction by wells or
drains, usually accompanied by treat-
ment of the extracted water prior to dis-
posal. This often causes an initial de-
crease in contaminant concentrations in
the extracted water, followed by a lev-
eling of concentration, and sometimes a
gradual decline that is generally ex-
pected to continue over decades. In
such cases, the goal of reaching strin-
gent health-based cleanup standards is
very remote and the ultimate cost of
cleanup very high (I).
The purpose of this paper is to ex-
plore reasons for the observed difficulty
of groundwater cleanup and note some
implications that become clear during
this process. Our discussion is limited
to organic contaminants because they
are the most common health-threaten-
ing chemicals detected in groundwater
and because the greatest difficulties in
groundwater remediation have been en-~
countered at organic contamination
sues.
Organic contaminant plumes
Prior to the passage of the Compre-
hensive Environmental Response,
Compensation, and Liability Act
(CERCLA) and revised Resource Con-
servation and Recovery Act (RCRA)
legislation in 1980 and 1984, respec-
tively, detailed monitoring of ground-
water at industrial and waste disposal
sites was rare, particularly for trace or-
ganic contaminants. Now, as the end of
the decade approaches, knowledge of
the nature of organic contamination of
groundwater has advanced considera-
bly because of the expenditure of more?
than a billion dollars on site investiga-
tions and cleanup activities. Hundreds
of plumes of organic contaminants have
now been delineated by networks of!
monitoring wells.
Several examples of organic plumes
in the United States and Canada are
given in Table I. Table I pertains to
plumes in sand and gravel aquifers; al-
though there are many plumes in frac-
tured rock, summary data such as we
630 Environ Sci. Technol . Vol 23, No. S, 1989

-------
present in this table are not readily
available because the outer boundaries
of such plumes and the fracture poros-
ity are very difficult to determine.
Plumes such as those in Table 1, which
extend 0.5-10 km from the source and
which generally have formed over dec-
ades, are common in North America
and Europe. Each of the sites listed in
the table represents a major plume in
the sense that millions of dollars have
been spent on plume characterization,
feasibility studies for alternative reme-
dial actions, and attempts at remedia-
tion. Cleanup programs are now
planned or underway for some of the
plumes in the table at ultimate costs for
each plume estimated at tens of millions
of dollars or more. The CERCLA and
RCRA programs address hundreds of
plumes such as those in the table. There
are probably thousands of other such
plumes in North America that are not
addressed by these programs.
Of the various organic contaminants
found in groundwater, the widely used
industrial solvents and aromatic hydro-
carbons from petroleum products are
most common (2-4). Much if not most
of groundwater contamination of this
type is caused by leakage, spillage, or
disposal of organic liquids immiscible
with' water (nonaqueous-phase liquids
[NAPLs]) into the ground. Dissolution
of the NAPL and subsequent transport
of the dissolved constituents by ground-
water is thought to generate many
plumes (5), although there is mounting
evidence that migration within the va-
por phase of the unsaturated zone with
subsequent transfer of vapor-phase con-
tamination to soil water and ground-
water may also cause formation of
groundwater plumes (6, 7).
The plumes in Table 1 are listed in
decreasing order of the mass estimated
to be present in the dissolved form (ex-
pressed as equivalent volume of NAPL
in the right column). Note that there are
documented examples of plumes that
encompass much larger volumes of
groundwater and greater masses of dis-
solved contaminants than listed in this
short table. Also, not all types of con-
TABLE 1
Relatively well-documented organic contaminant plumes in sand-gravel aquifers'
S'tB location
«... a plume map
0
Presumed
sources
5 km
Flow
Predominant
contaminants"
Plums volume
(liters)0
Contaminant mas9
dissolved In plume (as
equivalent NAPL volume In liters
or 55-gal drums)"
chemical
plant
electronics
plants
sewage
infiltration
beds
TCE
TCA
PER
TCE
TCA
TCE
PER
Detergents
5,700.000,000
6,000,0003000
40,000,000,000
15,000 (72 drums)
9800 (47 drums)
1500 (7 drums)"
Traverse C Ity, Ml
aviation
fuel
storage
Toluene
Xylene
Benzene
400,000,000
1000 (5 drums)
Gloucester. ON
Canada
special
waste
landfill
1,4 Dioxane
Freon 113
DEE, THF
102,000,000
190 (0.9 drum)
San Jose CA
electronics
plant
trainyard,
airport
TCA
Freon 113
1, 1 DCE
TCE
TCA
DBCP
5,000,000.000
4,500,000,000
130(0.6 drum)
80 (0.4 drum)
•	Readers aware of othe' well-documented cases (or which reliable estimates of contaminant mass distribution aad organic carbon content (foe) of
the aquifer solids are available are encouraged to contact the authors, who plan to expand this compendium.
0 TCE «trichioroethyien ; TCA -1. 1 trichloroethane; PER - per-, i.e., tetrachloroethyl?ne; 1,1 DCE^ 1, 1 dichloroethylene; CHCL3-chloroform;
DEE =» diethyl ether, TH =• tetrahydr "uran; DBCP = dibromochloropropane.
" Approximate estimate., denved frc plume length, groundwater velocity, contaminant i-oncuntration distributions, etc., provided for illustrative
purposes only Estimated contaminant mass accounts only for the dissolved phase (I.e., c'oes not account for contaminant sorbed to the aquifer
media throughout the plume or for NAPL contaminant, if any, from the sources). Most ot oasic data is trom unpublished sources; data on three
plumes arB published (13, 27, 28, 2S).
*	This mass estimate is for the hafcx mated contaminants only (i.e., detergents are exclrded).

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FIGURE 1
Schematic of granular subsurface environment*
•Illustrates phases in which organic contaminants may be present or migrate. Note deflection of NAPLs by large
day strata and fine lenses of less permeable material such as day or silt withm the predominantly sand-gravel
aqurfet Note that sorted phase may be assoaated with the exterior of the particles or with in tenor sites.
*lKcNoroethylene.
taminants encountered in groundwater
plumes are represented, though most of
those listed are quite commonly de-
tected. Nevertheless, the table is in-
structive. It is clear, for example, that
the contaminant load in an aquifer can-
not be judged from the magnitude of
the contaminated area; two of the ap-
parently larger plumes have the least
contaminant mass dissolved in them.
This, of course, reflects the differences
in the concentrations within the various
plumes as well as their total volume.
All but two of the plumes in the table
contain more than a billion gallons of
contaminated water. Yet the two small-
est plumes contain relatively large
amounts of contaminants, in part the
result of their relatively high solubility
compared with the halogenated com-
pounds in the other plumes.
The table also illustrates that plumes
often contain less mass in the dissolved
form than would be present in a few
drums of NAPL. This may be a minis-
cule fraction of the total NAPL mass
that entered the subsurface at many
sites where the total amount of organic
chemicals used or disposed of would
have been extremely large, often mea-
sured in hundreds of tanker truck loads.
These examples ignore the contami-
nant mass that would be sorbed to the
aquifer media contacted by the plume,
which may be on the same order as or
significantly greater than the dissolved
mass (8). Nevertheless, it is clear that
the primary challenge in groundwater
cleanup is to remove the organics
masses that serve, in effect, as subsur-
face sources and cause the plumes to
grow and persist, rather than simply to
remove the mass of dissolved contami-
nants that defines the plume. This is-
sue, so fundamental to the proper diag-
nosis and efficient solution of the
problem, is explored further below.
Cleanup of sand and gravel aquifers
Ideally, a remediation project for
contaminated sand and gravel aquifers
would be designed based on a solid un-
derstanding of the mass and types of
pollutants released, the current location
of all the mass remaining in the subsur-
face, and the processes controlling the
removal of the mass from the subsur-
face (or its destruction in situ). Unfor-
tunately, none of these requirements is
generally met in practical investiga-
tions, leading to a considerable amount
of guesswork in developing a cleanup
plan.
Figure 1 illustrates a few of the many
known complexities of granular subsur-
face environments as well as the phases
in which organic contaminants may be
present and migrate through the porous
media that comprise the unsaturated
(above the water table) and saturated
(below the water table) zones. Upon re-
lease to the subsurface, the total mass
of each pollutant will be distributed
among the various phases by the move-
ment of vapors and liquids and diffu-
sion of the pollutants within thjjfi.
NAPL may be present in pools at near
saturation, having displaced most of the
pore water, or in "residuals" at "resid-
ual saturation," on the order of 1-10%
of the pore volume (6, 9) remaining
from contact with a migrating NAPL
slug. The mass of organic pollutant
present in a given volume of NAPL-
contaminated soil may be many orders
of magnitude greater than the mass
present if the soil volume were contam-
inated only with vapor, dissolved and
sorbed phases. We thus refer to the
pools and residuals as subsurface con-
taminant sources.
With regard to cleanup efforts, it is
clearly advisable to first remove the
NAPL sources from the subsurface if
all possible, because they may contaH
most or nearly all of the total mass cf
fugitive contaminants. For NAPL s
such as benzene and other petroleum
products, which tend to floa" '
groundwater, the p. have been succ ss
in pumping a sigr:5cant fraction o." th.
NAPL to the surface (JO). Yet for oth-
ers more dense than water (e.g., chlo-
rinated solvents, crersots, -mc T"
rich oils), very little success has been
achieved in even locating the subsur-
face NAPL sources, let alone removing
them (11).
For NAPLs that cannot be removed
directly or that remain in residual satu-
ration, the pollutant mass they contain
will generally have to be removed in a
much more dilute form, such as by va-
porization into the soil gas or by disso-
lution in groundwater. These removal
methods require the extraction of con-
siderable volumes of gas or water.
Practical experience indicates that the
cleanup process is lengthy and expen-
sive, especially for contaminants in the
saturated zone.
The problem of groundwater cleanup
is exacerbated by the desire to return
aquifers to drinking-water quality,
which for many important organic con-
taminants requires concentrations less
than 100 parts per billion (ppb) and in
some cases less than 5 ppb. However,
the concentrations in groundwater
withdrawn by wells are controlled in
part by transfer of contaminant mass to
Jie flowing water from other phases
acting as contaminant reservoirs: con-
taminant sorbed by the aquifer solids,
contaminant present in immobile pock-
ets of contaminated groundwater in less
permeable but porous strata or lenses,
vapor spreading from residual or

-------
pooled NAPL in the vadose zone, or
dissolution of residual or pooled NAPL
in the saturated zone. As discussed be-
low, such transfers of contaminant
mass can cause the extracted ground-
water to fail to meet drinking-water
standards for prolonged periods of
time, a problem compounded by the
slow rate at which these transfers often
occur.
Effects of contaminant desorption
from solids
Dissolved organic contaminants gen-
erally move more slowly through gran-
ular aquifers than the groundwater it-
self because of sorptive interactions
with the aquifer solids (12-16). Al-
though there have been only a few field
studies that have yielded quantitative
understanding of the relative mobility
of organic contaminants, a review of
them indicates—as expected from labo-
ratory studies and basic geologic
knowledge—that field retardation var-
ies among contaminants for a given site
and among sites for a given contami-
nant (8).
The greater the retardation, the more
time will be required to remove the
contaminants for a given pumping rate.
Furthermore, the removal of dissolved
and sorbed contaminants by pumping
requires the extraction of more water
than is contaminated at the onset of re-
mediation. Figure 2a illustrates this in
an idealized case for a contaminant
with a retardation factor of two (i.e, in
which the sorption/desorption interac-
tions cause the contaminant to move at
a constant fraction, 1/2, of the ground-
water velocity). The retardation factors
observed in sand-gravel aquifers for
contaminants such as those listed in Ta-
ble 1 vary from 1 to 33 (8); in other
media or for other contaminants, the
retardation may be even greater. Thus,
unless injection wells are used to supply
the clean water, which is rarely the
case, the "pump-and-treat" approach
may utilize a considerable volume of
uncontaminated groundwater surround-
ing the site to flush the contaminants
from the polluted area.
However, kinetic limitations to de-
sorption can occur during groundwater
extraction programs, as has been ob-
served in field studies (17, 18) and im-
plied by laboratory investigations (19-
22). The practical effect of these kinetic
FIGURE 2
Hypothetical examples of contaminant removal ;
(a) Uniform sand-gravel aquifer"
to
Contaminant concentration in extracted
water
t1
to
nsr
(b) Stratified sand-gravel aquifer
to
t1
	
	
		—i; »¦







tO t1
(c) Clay lens in uniform sand-gravel aquifer
to
to t1
(d) Uniform sand-gravel aquifer
¦
2. •/ •
to
t2
: IVf."..'.1

•Dens® color Indicates NAPL contaminant, sttppilng indicates corrtcmT^ni tn dissolved and corfcrd phesci*
(assumed untformty distributed rnio&Uy), and anwj indicate relaijv© vedoaiy ot grounzwaiz? flow. The
groundwater Is assumed to be extracted from the waJI el the samo rats in the four cases.
^Dotted fines cjvJqss toiaJ vc!umo o7 ivetsr tfiat uculd bs pumped to removo contzminsnt with rennfcion factor
0(2.
limitations is to slow the removal of the
contaminants from the aquifer, thereby
increasing both the time required to
achieve cleanup and the total volume of
water that must be extracted to flush the
¦¦contaminated zone. Furthermore, if
pumping is ceased before all of the con-
taminant is removed, the contaminant
concentrations in the groundwater will
rise as desorption continues (1). Whif-
fin and Bahr (17) observed such results.
Effects of geologic complexity
Although the processes that affect or-
ganic contaminant transport are essen-
tially the same in various sites, the opti-
mal design of a remediation program is
very site specific, mainly because of
geologic complexity. Sand and gravel
aquifers typically have silty or clayey
strata above, within, or beneath them
(Figure 1). These strata normally are
less permeable than the aquifer by a
factor of 1000 to 10 million. Ground-
water flow and contaminant migration
are distorted because of these strata.
The positions of NAPL sources in the
aquifer are commonly complex and un-
predictable because exact locations and
volumes of spills or leakages are un-
known, and, as illustrated in Figure 1,
the positions of subsurface NAPL
sources are determined by deflections
and pooling caused by stratification.
Current research suggests that even
slight heterogeneities can influence
NAPL penetration into porous media,
particularly in the saturated zone (23).
As plumes spread through aquifers,
the dissolved contaminants move
quickly through more permeable zones
while they slowly invade the less per-
meable ones by flow or diffusion (24).
Over the years and decades, this inva-
sion can cause the plume to occupy
large volumes of low permeability ma-
terial. To obtain clean water from
wells, it is generally necessary for the
lower permeability parts of the aquifer
system to be cleaned as well as the high
permeability zones.
Figure 2b illustrates an idealized case
in which the aquifer is composed of two
relatively distinct and horizontally con-
tinuous sand-gravel strata, the upper
stratum having a somewhat higher hy-
draulic conductivity than the lower. The
contaminant is assumed present in dis-
solved and sorbed phases, uniformly
spread in the volume indicated. If
groundwater is extracted from a fully
penetrating well or a well with most of
its screen in the more permeable zone,
as is common practice, the bulk of the
water will be moving through the upper
stratum. Thus, even in sand-gravel
aquifers, some strata may be flushed of
contaminants long before others. Fig-
ure 2b assumes that the retardation fac-
tor of the contaminant is two in both

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FIGURE 3
Schematic of subsurface environment composed of fractured rock
under the overburden*
Diffused
into and sorbed
onto rock matrix
Dissolved
The fracture system may lead to the appearance erf NAPL Of dissolved contaminant in unpredictable locations.
Dense ookx indicates NAPL contaminant: stippling indicates contsminnnt m the dissotrod phase, either In water
in the fractures or diffused into water held in the porous rock matrix.
THdiloroethytene.
strata. If the retardation is greater in the
lower stratum and desorption is kineti-
cally limited, then the flushing will be
even more inefficient (25).
Figure 2c illustrates another situa-
tion: a very low permeability clayey
stratum in the middle of an aquifer that
has been contaminated for decades.
Dissolved contaminants have perme-
ated the clayey stratum during this per-
iod primarily by molecular diffusion.
Although the permeability of a clayey
stratum is low, the porosity is usually as
large as or larger than that of the adja-
cent aquifer, thereby facilitating diffu-
sion into the clay. Furthermore, the ca-
pacity of clayey strata to sorb
contaminants may be much greater per
unit volume than that of the aquifer.
When the aquifer is flushed by clean
water, the only significant process for
release of the contaminant from the
clay will be a reversal of the diffusion
direction. The relatively slow rate of
release of contaminants from the clay
by diffusion and the potentially appre-
ciable contaminant mass contained in
dissolved and sorbed fo m in the clay
causes a long-term bleed of contami-
nants into the aquifer during remedia-
tion (1). In many aquifers there are nu-
merous thin beds of silt and clay that
634 Environ. Sci. Technol.. Vol. 23. No. 6, 1989
compound this problem of delayed dif-
fusive release. Such processes may
maintain contaminant concentrations in
the extracted water above typically low
cleanup criteria for very long periods of
time, gready increasing the duration
and cost of cleanup. In most investiga-
tions, however, the details of site geol-
ogy are not well enough understood to
allow prediction of the effect of delayed
diffusive release.
Effects of fugitive NAPL
As described above, organic NAPLs
are often suspected to be present in the
subsurface, but reliable estimates of the
volume of NAPL spilled or disposed of
exist for very few groundwater contam-
ination sites. Furthermore, even after
exceptionally detailed site investiga-
tions are conducted, it is normally not
possible to predict reliably where these
NAPL pools are. Not knowing the size
and location of NAPL pools and zones
of residual NAPL makes it impossible
to predict how long a pump-and-treat
program must operate in order to clean
the aquifer. Figure 1 shows how clayey
lenses in the aquifer can cause the
NAPL to be deflected laterally so that
most of the NAPL mass exists as iso-
lated pools away from the spill origin.
Perched pools of NAPL can jeopardize
site investigations because it is very
easy to unknowingly drill through the
pool and the bed it sits on, causing the

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deeper part of the aquifer or into a dif-
ferent aquifer. When pumping causes
lowering of the water table from a posi-
tion above perched NAPL pools or
NAPL residual zones to below them,
remobilization of the pools and resid-
uals may occur, allowing them to drain
deeper into the aquifer.
Figure 2d illustrates the effect that
even relatively small quantities of
NAPL might have on a typical cleanup
program based on groundwater extrac-
tion. In the general case the extraction
well is located at some distance from
the NAPL that has penetrated the satu-
rated zone. The groundwater extraction
might quickly remove the bulk of the
dissolved and sorbed contaminant that
had migrated from its NAPL source(s)
and thereby achieve an initial decrease
in concentration in the extracted water.
However, the NAPL present in pools or
residual saturation may be dissolved
slowly by the groundwater flowing
around or through them, maintaining
contaminant concentrations at signifi-
cant levels for a long time, even in rela-
tively uniform aquifers. When zones of
lower permeability are contaminated
with NAPL, the cleanup time would be
expected to increase considerably.
Feenstra and Cherry (11) present a
more complete review of these and
other issues regarding NAPL behavior
and cleanup of NAPLs denser than wa-
ter.
Cleanup of fractured rock aquifers
Generally, rock aquifers contain a
myriad of cracks (fractures) of various
lengths, widths, and apertures. Most
rock aquifers in North America are
permeable primarily because of the ef-
fective porosity provided by these frac-
tures rather than that of the rock ma-
trix, which is relatively impervious.
The effective fracture porosity of frac-
tured-rock aquifers is generally in the
range of 0.001-0.1%, which is much
smaller than the porosities of typical
granular aquifers (20-40%). For exam-
ple, a rock mass with one fracture per
linear meter with fracture apertures of
500 nm would be very permeable but at
saturation would have a very small
storage volume of mobile groundwater
(only about one-half liter per cubic me-
ter of rock).
When NAPL enters such aquifers, it
flows mainly through the intercon-
nected fractures and settles out in dead-
end segments of the fracture system
(Figure 3). Relatively small volumes of
NAPL can move deep and far into the
rock because the retention capacity of-
fered by the dead-end fractures and the
immobile filaments and globules in the
larger fractures is so small—much less
than the percentage given above for wa-
ter in saturated fractured rock. Al-
though the rock matrix typically has a
relatively small intergranular porosity,
it is commonly large enough to allow
dissolved contaminants from the frac-
tures to enter the matrix by diffusion
and be stored there by adsorption, as
shown in Figure 3.
The prognosis for cleanup of frac-
tured rock aquifers, particularly those
containing NAPL contaminants, is
worse than for sand and gravel aqui-
fers. Even if the location of the spill is
known exactly, the location of the
NAPL is typically difficult or impos-
sible to determine from site investiga-
tions. This is because NAPL pathways
"...cleanup of groundwater
contamination by organic
chemicals typically pro-
ceeds slowly using the
common pump-and-treat
approach"
At
through the fracture system are excep-
tionally complex and distribute the
NAPL into many small and scattered
amounts (Figure 3). When attempts are
made to clean such fractured rock aqui-
fers by pumping water, major improve-
ments in water quality are exceedingly
slow because little or no water flushes
through dead-end fracture segments or
through the porous but impervious rock
matrix, both of which are likely tcyfe-
tain the bulk of the contaminated mass.
Such has been the experience at an or-
ganic liquids disposal site in Ville Mer-
rier, Quebec, where the effectiveness of
pump-and-treat remediation of the
large plume has been severly hampered
by the penetration of the NAPLs into
the fractured bedrock (26).
Summary and implications
We have explored, via simplified ex-
amples and illustrations, many of the
reasons cleanup of groundwater con-
tamination by organic chemicals typi-
cally proceeds slowly using the com-
mon pump-and-treat approach. At
many sites of significance, a relatively
large mass of contaminants has been
leaked, spilled, or disposed into the
subsurface, and in comparison the rate
of contaminant mass removal by pump-
ing wells is exceedingly slow. In such
cases the pump-and-tre:it option is best
thought of as a management tool to pre-
vent, by hydraulic manipulation of the
aquifer, continuation of contaminant
migration.
This option often effectively shrinks
the plume toward its source(s), but for
the shrinkage to persist it is necessary
for the pumping to continue. Even if
contaminants remain in some portions
of the aquifer, it is often possible by
such -hydraulic influence to eliminate
real, potential, or perceived risks to
public health. However, the long-term
cost of such pumping with treatment of
the extracted water is often high
whether measured in dollars spent for
system operation and maintenance or in
gallons of previously uncontaminated
groundwater used to flush out the con-
taminants. The mass of NAPL at or be-
low the water table is not known with
sufficient detail at most sites to make
reliable predictions of the time neces-
sary for cleanup by pump-and-treat
programs. In general, it is appropriate
to view such approaches as remediation
in perpetuity.
At quite a few sites, the dissolved
mass of organic contaminants in rela-
tively large plumes is quite small, less
than that present in one drum of the
pure chemical. This suggests that seem-
ingly innocuous and often unnoticed
leakages or spills of a few gallons per
day or less, so common at many indus-
trial and military sites, may pose a ma-
jor threat to groundwater. Considering
the extremely high cost per equivalent
NAPL gallon of removing the contami-
nant from aquifers, it is clear that the
economic advantage of preventing such
small leaks or spills is immense.
A number of new technologies are
under development for groundwater re-
mediation, as explained in later articles
in this series, which may accelerate
contaminant removal from the subsur-
face (e.g., injection of steam, surfac-
tants) or destroy the contaminant in situ
(e.g., bioreclamation). For many if not
most sites, it is important to recognize
that all of these technologies will be
severely hampered by geological com-
plexities and the difficulty of locating
the subsurface contaminant sources.
Laboratory studies and small-scale field
prototype trials are likely to yield over-
optimistic expectations for the applica-
tion and efficiency of these technolo-
gies.
Site characterization programs often
seem to the public and regulators to be
inefficient and excessively lengthy.
Shortening site characterization efforts,
a currently popular demand, may be
appropriate for pump-and-treat pro-
grams intended to prevent contaminant
migration, but cannot be expected to be
satisfactory for permanent aquifer
c' -anup. At sites where permanent
c. anup is the goal, detailed and accu-
rate site characterization is a prerequi-
site for a reasonable probability for suc-
cess (1). As reviewed in other papers in
: lis series and elsewhere (1, 8), there is

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much potential for improvement in site
characterization and remediation,
through both the development of new
tools and the continued training of ev-
eryone involved: site owners, consult-
ing engineers and hydrogeologists, reg-
ulators, and the public.
Acknowledgements
Preparation of this paper was supported in
part by the National Science Foundation
through its sponsorship of the U.C.L.A.
Engineering Research Center for Hazard-
ous Substance Control, and by the Univer-
sity of Waterloo part of the University
Consortium Solvents-in-Groundwater Re-
search Program.
We are grateful for comments and assist-
ance from B. Kueper (University of Water-
loo), R. Jackson (Environment Canada),
S. Feenstra (Applied Groundwater Re-
search, Ltd.), and D. McWhorter (Colo-
rado State University). Numerous people
assisted in the preparation of the table, in-
cluding J. Anderson (IBM), M. Brother
(Eckenfelder, Inc.), G. Patrick (Golder As-
sociates), K. O'Brien (Pacific Environ-
mental Services), C. Haddox (Ebasco
Services, Inc.), T. Hunt (Harding-Lawson
Assoc.), J. Armstrong (Traverse Group),
and L. Barber (U.S. Geological Survey).
References
(1)	Robert S Kerr Environmental Research
Laboratory "Practical Limits to Pump
and Treat Technology for Aquifer Reme-
diation", paper prepared for (he ; I S En-
vironmental Protection Agun<-> Ada,
OK, 1987
(2)	Westrick, J. J ; Mello, W J.; Thomas.
R F J Amer. Water Works Assoc 1985,
6, 52-59.
(3)	Mackay, D. M , Gold, M , Leson, G In
Proceedings of the I6lh Biennial Confer-
ence on Ground Water, Devries, J. J ,
Ed , University of California Water Re-
sources Center Report No 66, Davis,
CA, 1988, pp 97-110
(4)	Barbash, J E , Roberts, P. V. J. Water
Pollut Control Fed 1986, 58(5), 343-
48.
(5)	Mackay, D. M.; Roberts, P V, Cherry.
J. A Environ. Sci. Technol 1985, 19(5),
384-92.
(6)	Schwille, F. Dense Chlorinated Solvents
in Porous and Fractured Media. Model
Experiments (Engl transl.); Lewis Pub-
lishers' Ann Arbor, MI, 1988.
(7)	Mendoza, C. A., McAlary, T. A.
Groundwater, in press.
(8)	Mackay, D M. Presented at the National
Research Council colloquium on ground-
water and soil contamination remedia-
tion Washington, DC, April 1989.
(9)	Hoag, G. E.; Marley, M. C. J. Environ.
Eng Div. (Am. Soc. Civ. Eng.) 1986,
112(3), 586-604.
(10)	Roy F. Weston, Inc., University of Mas-
sachusetts, Environmental Science Pro-
gram, Division of Public Health; Reme-
dial Technologies for Leaking
Underground Storage Tanks; Lewis Pub-
lishers: Chelsea, Ml, 1988.
(11)	Feenstra, S., Cherry, J. A In Proceed-
ings of International Groundwater Sym-
posium; International Association of Hy-
drogeologists. Halifax, Nova Scotia,
May 1988; pp 61-69.
(12)	Roberts, R V; Schreiner, J.. Hopkins.
G D. Water Res. 1982, 16. 1025-35
(13)	Patterson. R. J. et al. Water Sci. Technol.
1985, 17. 57-69
(14)	Schwarzenbach, R. P. et al. Environ. Sci.
Technol 1983, 17. 472-79
(15)	Mackay, D. M et al. Water Resour Res.
1986, 22(13). 2017-30
(16)	Roberts, P V, Goltz, M. N ; Mackay,
D M Water Resour. Res. 1986, 22(13),
2047-58.
(17)	Whiffin, R. B , Bahr, J M In Proceed-
ings of the Fourth National Symposium on
Aquifer Restoration and Ground Water
Monitoring; National Water Well Associ-
ation Worthington, OH, 1985, pp. 75-
81.
(18)	Bahr, J. M. J. Contam Hydrol., in press.
(19)	Karickhoff, S J Hydraul. Eng. 1984,
110(6), 707-35.
(20)	Curtis, G L., Reinhard, M., Roberts.
P V. Water Resour Res. 1986, 22(13),
2059-67
(21)	Wu, S-C , Gschwend, P M Environ.
Sci. Technol 1986, 20. 717-25
(22)	Ball, W P Ph D Dissertation, Stanford
University, Stanford, CA, 1989
(23)	Kueper, B H , McWhorter, D B., Frind,
E O In Proceedings of the International
Symposium on Contaminant Transport in
Groundwater; International Association
for Hydraulic Research, Stuttgart, FRG,
April 1989.
(24)	Gillham. R W Cherry, J. A. In Recent
Trends in Hydrogeology. T. N Nori-
simhan (Ed.), Geological Society of
America (Special Publication), 1982,
189. pp. 31-62
(25)	Mackay, D M . Michelsen, C , Thorb-
jarnarson, K. Abstracts of Papers; Amer-
ican Geophysical Union Conference, San
Francisco, EOS 1988, 69(4). p. 1197
(26)	Martel, R "Groundwater Contamination
by Organic Compounds in Ville Mercier.
New Developments", report to the
NATO/CCMS Pilot Study of Remedial
Action and Technologies for Contami-
nated Land and Groundwater. Bilthoven,
The Netherlands, Nov 1988
(27)	Barber. L. E II et al. Environ. Sci Tech-
nol. 1988, 22. 205-11
(28)	Armstrong, J. M , Sammons, J. H. Pro-
ceedings of the 1986 Hazardous Materi-
als Conference. May 1988, St. Louis,
MO
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114(5), 1007-29
Douglas M. Mackay (I) is an assistant pro-
fessor in the Environmental Sciences and
Engineering Program of the UCLA School
of Public Health, with graduate degrees in
civil engineering. Since 1981 his research
has focused on integrated field and labora-
tory investigations of the transport and re-
mediation of organic contaminants in the
subsurface.
John A. Cherry (r) has degrees in geologi-
cal engineering ¦ >'.d hydrology and, since
1971, has been a professor at the Univer-
sity of Waterloo where he is a member of
the Waterloo Centre for Groundwater Re-
search. For the past 20 years, his research
has focused on processes and monitoring
of groundwater conuimination.

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GOALS AND EFFECTIVENESS OF PUMP AND TREAT REMEDIATION
VOLUME I
A Review of Selected Case Studies of Large Plumes
of Chlorinated Solvents or Pesticides in Sandy Aquifers
J. Harman, D. M. Mackay and J. A. Cherry
Waterloo Centre for Groundwater Research
University of Waterloo
Waterloo, Ontario, Canada N2L 3G1

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EXECUTIVE SUMMARY
The majority of'groundwater remediation programs in the United States has used the groundwater
remediation method known as "pump and treat" (hereafter abbreviated as P&T) in which contaminated
groundwater is extracted from the aquifer, treated to prescribed contaminant levels and then disposed. In
the early years of its application, this method was expected to permanently remediate the contaminated
zones and thereby restore the aquifers to drinking water standards within reasonable time frames (1 to 10
years). However, remedial performance data indicates that actual progress in aquifer restoration is
generally much slower than originally expected.
This study provides an analysis of past P&T performance at selected sites that overlie sand and
gravel aquifers. The primary goals are to better understand the capabilities and limitations of the P&T
approach and to propose procedures for performance assessments that may be readily applied at other
sites.
The eleven contaminant plumes evaluated in this study were selected qualitatively based on size,
long histories of site investigations, and abundance of site monitoring information. This review is restricted
to plumes in sand and gravel aquifers because, in comparison to plumes in other types of hydrogeologic
settings such as fractured rock, they generally are defined more completely and offer better prospects for
full restoration. At 10 of the 11 sites, the predominant groundwater contaminants were chlorinated organic
chemicals typically used as industrial solvents (at the remaining site, the contaminants are halogenSted
alkane pesticide&-with expected groundwater transport properties similar to those of chlorinated solvents).
At 7 sites, P&T remediation has been underway for seven to thirteen years. At 1 site, P&T began as this
report was being finalized. At the other 3 sites, detailed characterization was complete or nearly so and
P&T systems were being planned or designed. Of the 11 sites, 7 are regulated under the Superfund
program. The other 4 are regulated by state or federal agencies under other programs.
Our review indicates that, with one exception, only recent remedial designs have recognized that
subsurface contamination by chlorinated solvents often is comprised of two conceptually different zones:
1) the subsurface source zone, in which dense nonaqueous phase organic liquids (a.k.a. DNAPL's) may
exist, and 2) the plume, in which only dissolved and sorbed contaminants are present. If the source zone
is significant, it will often be the case that far more contaminant mass is present there than in the plume
itself, where contaminant concentrations are often relatively low. It is our conclusion that the progress of
many remedial programs has appeared slow because the expectations for the programs were incorrectly
based on the assumption that only the plume existed in the subsurface. In other words, until recently it has
been the rare case in which the significance of subsurface source zones has been recognized in the

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remedial design process for chlorinated solvent contamination.
None of the 7 operating P&T systems reviewed in this study was found to have completely restored
the aquifer. Here we define complete restoration as removal of contaminants from both the concentrated
subsurface source zone and the more dilute but generally much more extensive plume. This observation
is consistent with anecdotal information obtained from a wide variety of sources by the authors over the
last several years; except for petroleum contamination, there appear to be no well-documented cases in
which significant VOC plumes as well as the subsurface source zones have been fully remediated by P&T.
In three of the cases, partial restoration of the aquifer was achieved by reducing the contaminant
concentrations within the dissolved plume to satisfy the regulatory agency or proposed cleanup criteria.
This degree of success seemed to require that the contaminant mass in the subsurface source zone either
be insignificant, removed or isolated from the remainder of the plume by hydraulic or physical means.
Since, in general, the contaminant mass in the subsurface source zones is unlikely to be insignificant if the
plumes are significant, our review^uggests that partial restoration of the aquifer can be expected only if
the subsurface source zone is isolated to prevent regeneration of the plume. On the other hand, this review
confirms that P&T can, under certain circumstances, sufficiently restore considerable portions of an aquifer
to satisfy regulatory agencies or meet cleanup criteria and prevent the spread of contaminants from source
zones. This condition of partial aquifer restoration can be maintained as long as P&T or physical isolation
continues as a source-zone control measure.
In several.of the cases examined, plume containment (i.e. capture) was specified as the remedial
goal, with gradual mass removal as a secondary goal and automatic consequence. Success in achieving
containment, as defined by these goals, varied from site to site. Only two P&T systems with plume
containment as the goal were designed in a manner to capture the entire plume. At one site which is not
yet operating, the pumping wells are to be positioned at the front of the plume. At the second site the wells
were located within the plume and pumped at rate predicted to attain full capture; however, the system has
not yet been in operation long enough for capture to be confirmed via monitoring data.
At other sites, the remedial goal appeared to be partial plume containment or plume cutoff rather
than plume containment. Generally, these older extraction systems were not installed at the front of the
plumes but rather to varying degrees within them, often at site boundaries. In these cases, the wells do
not appear to capture the entire plume and some of the plume may have been lost to migration beyond
the influence of the extraction system. However, once installed, the P&T systems appear successful in
preventing further migration of contaminants beyond therr.. Phis suggests that, if installed in the path of
a migrating plume, P&T may under many ;oncitions sue sjd in plume capture. Thus, P&T can be an

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effective means of limiting or removing risk of exposure to contaminated groundwater.
Free-phase, dense non-aqueous phase liquid (DNAPL) was confirmed to be present (detected) in
the subsurface at only 1 of the 11 sites. However, our review indicated that, at most of the sites, DNAPLs
were very likely present in subsurface source zones below the water table, acting as significant long-term
subsurface contaminant sources. In many cases, other contaminants may be present as well (e.g.
nonchlorinated solvents and/or fuels). In one case, it appears that an LNAPL (non-aqueous phase liquid
less dense than water) was present which had chlorinated solvents dissolved within it. The importance or
even existence of DNAPL sources was not generally recognized at the time that most of the remedial
measures went into operation at these sites. Among the sites examined in this study with operating P&T
systems for plume restoration, the presence of a significant subsurface source of contaminant mass was
explicitly considered in initial remedial designs in only one. We believe that progress towards partial aquifer
restoration was most rapid at that site, primarily because the source zone was isolated early using a cutoff
wall enclosure with pumping inside the enclosure, preventing continued regeneration of the plume.
However, it is important to note th^t though progress has been made toward cleanup of the plume,
remediation of the isolated source zone continues with no certainty of the completion date.
The initial volumes of the studied plumes ranged from 115,000 to 230,000,000 m3. Prior to P&T,
the flux of groundwater and contaminants through these plumes ranged from 3.4 to 46 Us and 5 to 1700
kg/yr, respectively. The contaminant mass estimated to be dissolved within the plumes prior to P&T
generally ranged from 44 to 9,000 kg (0.133 to 33 drums), although one site had an estimated dissolved
mass of over 80,000 kg (275 drums). At the 11 study sites, it was not possible to estimate the total mass
of contaminants in the subsurface, since neither the sorbed or DNAPL mass in the subsurface source
zones nor the sorbed mass in the plumes are known or reliably estimated.
P&T systems achieved mass removal rates from 100 to 3,000 kg/yr (0.34 to 10 drums per year).
Although the mass removal rates are significant at some sites, the actual progress towards complete clean-
up cannot be assessed at any of the sites, because the total initial mass is unknown. The discrepancy
between the minimum mass removal (100 kg/yr) and the minimum dissolved mass in place (44 kg)
suggests that additional mass is contributed to the dissolved plume during the remediation. This additional
mass is likely from dissolution of source zones or desorption from the aquifer media. Despite the fact that
the total mass in the subsurface cannot be estimated, these other types of calculations proved useful for
structuring our review and highlighting apparent inconsistencies in data or their interpretation.
There is evidence for many of the plumes evaluated herein that natural in-situ transformation
processes are converting some of the parent contaminants to other contaminants. Although apparently not

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the case at the sites reviewed in this study, such transformations could yield nontoxic daughter products
and proceed at rapid enough rates to either accelerate the progress of pump and treat remediation or
render it unnecessary (i^e. no action required to prevent risk). In contrast, at several of the sites reviewed
in this study, anaerobic biotransformation of the solvents apparently yielded chlorinated daughter products
which were of regulatory concern. In two of the cases reviewed in this study, natural abiotic transformation
of 1,1,1-TCA appears to have produced sufficient mass of 1,1-DCE such that the daughter product now
is the constituent controlling the achievement of the negotiated remediation goal (note that the drinking
water criterion for 1,1-DCE is significantly lower than for 1,1,1-TCA , i.e., 6 ^xg/L vs 200 (a.g/L). In one of
these cases there is apparently a continuing source of 1,1,1-TCA to maintain the groundwater plume.
Therefore, there is a continuing source for in-situ production of 1,1-DCE. It is likely that plume restoration
in this case will not be possible without source removal or isolation.
In summary, our review indicates that well-executed P&T technology, despite its limitations, has
been and can be successful for partial aquifer restoration. However, P&T or other source control or
removal measures must be continue^ in order to maintain the condition of the partially restored aquifer.
In other cases, P&T can be used effectively to contain plume migration and reduce or eliminate risk even
without restoring the existing plume.
The primary factor preventing P&T from achieving complete aquifer restoration appears to be the
continued presence of DNAPL zones below the water table. These source zones are likely to be present
and significant at most sites contaminated with chlorinated organic chemicals, yet they have rarely been
addressed directlyjn remedial design until recently. In addition, evidence suggests that such source zones
should be expected even if no direct observations can be made to locate them precisely. This conclusion
implies that better remedial designs would be likely if such source zones were simply assumed to exist and
then roughly located so that some form of source containment could be accomplished.
Finally, it is important to realize that the same factors that limit the effectiveness of P&T systems
for source zone restoration are also likely to limit most, if not all, of the alternative technologies that require
active manipulation of groundwater or air in the subsurface as replacements of or enhancements to P&T.
This includes chemically enhanced pump-and-treat, such as surfactant or alcohol flushing. If this is true,
then although these new technologies may initially offer advantages in rate of approach to the cleanup
standard, they too may be unable to reach the required goals in reasonable time frames. This study
suggests that a realistic approach for groundwater remediation at sites with appreciable quantities of
chlorinated solvent contaminants in sand and gravel aquifers is subsurface source-zone isolation or control
using cutoff-wall enclosures, hydraulic manipulation of the groundwater zone, or passive in situ treatment
systems. In addition where conditions allow, the dissolved groundwater plume outside the isolation or

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control boundary can be removed, or at least captured, by P&T.

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