REMEDIATION SYSTEM EVALUATION
A-Z Automotive
West Milford, New Jersey
Report of the Remediation System Evaluation
Site Visit Conducted at A-Z Automotive
July 30, 2003
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£
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Office of Solid Waste EPA 542-F-04-028
and Emergency Response September 2004
(5102G) www.epa.gov/tio
clu-in.org/optimization
Remediation System Evaluation
A-Z Automotive
West Milford, New Jersey
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NOTICE AND DISCLAIMER
The U.S. Environmental Protection Agency (U.S. EPA) funded the preparation of this document by
GeoTrans, Inc. under General Service Administration contract GS06T02BND0723 to S&K Technologies
Inc., Bremerton, Washington and under EPA contract 68-C-02-092 to Dynamac Corporation, Ada,
Oklahoma. Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.
This report has undergone review by the state site manager and EPA headquarters staff. For more
infomation about this project, contact: Joe Vescio (703-603-0003 or vescio.joseph@epa.gov) or
Kathy Yager (617-918-8362 oryager.kathleen@epa.gov).
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EXECUTIVE SUMMARY
A Remediation System Evaluation (RSE) involves a team of expert hydrogeologists and engineers,
independent of the site, conducting a third-party evaluation of site operations. It is a broad evaluation that
considers the goals of the remedy, site conceptual model, above-ground and subsurface performance, and
site exit strategy. The evaluation includes reviewing site documents, visiting the site for up to 1.5 days,
and compiling a report that includes recommendations to improve the system. Recommendations with
cost and cost savings estimates are provided in the following four categories:
• improvements in remedy effectiveness
• reductions in operation and maintenance costs
• technical improvements
• gaining site closeout
The recommendations are intended to help the site team identify opportunities for improvements. In many
cases, further analysis of a recommendation, beyond that provided in this report, may be needed prior to
implementation of the recommendation. Note that the recommendations are based on an independent
evaluation by the RSE team, and represent the opinions of the RSE team. These recommendations do not
constitute requirements for future action, but rather are provided for the consideration of all site
stakeholders. This RSE report pertains to conditions that existed at the time of the RSE site visit, and any
site activities that have occurred subsequent to the RSE site visit are not reflected in this RSE report
(unless otherwise noted).
The A-Z Automotive site is a former gasoline retail outlet and automobile service station located on Union
Valley Road between St. George Street and Lou Ann Boulevard in West Milford, Passaic County, New
Jersey. Approximately 25 residences are located on St. George Street and Lou Ann Boulevard to the
east of the A-Z site. Belcher Creek is about 1,000 feet further to the east of the subdivision. Petroleum
impacts were discovered at the site in 1989 initially due to a diesel spill that occurred during the filling of a
UST. Subsequent investigations found UST leaks, basement vapor issues, and potable well impacts.
Shallow ground water occurs in a glacial deposit overburden that is reported to be about 80 feet bgs. The
potable wells in the area are completed in the underlying bedrock (potable wells are reported to average
about 150 feet bgs). Between 1989 and 1992, potable well sampling indicated exceedances of New
Jersey Department of Environmental Protection (NJDEP) ground water standards at nine potable wells,
and detectable contaminant concentrations in twelve additional wells. Gasoline odors were noted at that
time in the basements of several residences. Approximately 19 point of entry treatment (POET) systems
with GAC treatment were in place as of May 1995, and most of these are still in place.
Contaminants of concern include typical gasoline constituents such as benzene, toluene, ethylbenzene,
xylenes (BTEX), methyl tertiary butyl ether (MTBE) and tertiary butyl alcohol (TEA). Benzene is
present above NJDEP standards in the most widespread area. Analytical results for ground water
samples taken in July 2003 show a marked decrease in the extent and magnitude of dissolved
concentration from earlier results. Free product has been observed at the site, reaching as far
downgradient as RW-13 (300 feet east of the abandoned gas station), where up to three feet of product
has been observed during pumping conditions. During the site visit it was reported that free product was
recently noted in MW-9, MW-15, and MW-16. There is concern that a large volume of product is
trapped below the water table.
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The current system P&T system consists of one main recovery well for hydraulic control (RW-13).
Other wells are periodically pumped to lower the water table for soil vapor extraction (SVE) application.
The recent (May to July 2003) system flow rate has been about 20 gpm. The current SVE system
consists of several wells that can recover vapors to prevent contaminant migration to residences, and to
remove mass. The vapors are extracted at a rate of approximately 70 to 100 cfm, and are currently
treated by a catalytic oxidizer.
The observations and recommendations contained in this report are not intended to imply a deficiency in
the work of either the system designers or operators but are offered as constructive suggestions in the
best interest of the EPA, the public, and the facility. These recommendations have the obvious benefit of
being formulated based upon operational data unavailable to the original designers.
Recommendations to improve effectiveness in protecting human health and the environment include the
following:
• further delineation of ground water impacts beyond MW-37 and MW-38
• performing capture zone analysis (including the development of a target capture zone)
• formalizing a well sampling program
• conducting vapor monitoring at nearby residences
Recommendations to reduce costs include the following:
• clarifying the scope of the site contractor
• switching from the catalytic oxidizer to vapor phase carbon
• reducing the frequency of GAC changeouts
A recommendation for technical improvement is to begin more formal reporting regarding the status and
progress of the system. A recommendation for site closeout is to start formulating a site-specific exit
strategy that includes an estimated time frame for shutting down the system, and a specific monitoring
program to indicate when the system can be shut off (including post-shut-down monitoring). All of these
recommendations can be easily implemented, and a prioritization of the recommendations is provided.
A table showing estimated costs and/or savings associated with each recommendation is presented in
Section 7.0 of this report.
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PREFACE
This report was prepared as part of a pilot project conducted by the U.S. EPA Office of Underground
Storage Tanks (OUST) and Office of Superfund Remediation and Technology Innovation (OSRTI). The
objective of this project is to conduct Remediation System Evaluations (RSEs) of pump and treat systems
managed by State UST programs. The following organizations are implementing this project.
Organization
Key Contact
Contact Information
U.S. EPA Office of Underground
Storage Tanks (OUST)
Joe Vescio
EPA Headquarters 5401G
Ariel Rios Building
1200 Pennsylvania Ave, N.W.
Washington, DC 20460
phone: 703-603-0003
fax: 703-603-0175
vescio.j oseph@epa.gov
U.S. EPA Office of Superfund
Remediation and Technology
Innovation
(U.S. EPA OSRTI)
Kathy Yager
11 Technology Drive (ECA/OEME)
North Chelmsford, MA 01863
phone: 617-918-8362
fax: 617-918-8427
yager.kathleen@epa.gov
U.S. EPA Office of Superfund
Remediation and Technology
Innovation
(U.S. EPA OSRTI)
Ellen Rubin
EPA Headquarters 5102G
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
phone: 703-603-0141
rubin. ellen@epa. gov
Dynamac Corporation
(Contractor to U.S. EPA)
Daniel F. Pope
Dynamac Corporation
3601 Oakridge Boulevard
Ada, OK 74820
phone: 580-436-5740
fax: 580-436-6496
dpope@dynamac. com
GeoTrans, Inc.
(Contractor to Dynamac)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
phone: 732-409-0344
fax: 732-409-3020
dsutton@geotransinc. com
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TABLE OF CONTENTS
EXECUTIVE SUMMARY i
PREFACE 111
TABLE OF CONTENTS iv
1.0 INTRODUCTION 1
1.1 PURPOSE 1
1.2 TEAM COMPOSITION 2
1.3 DOCUMENTS REVIEWED 2
1.4 PERSONS CONTACTED 3
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS 3
1.5.1 LOCATION 3
1.5.2 POTENTIAL SOURCES 3
1.5.3 HYDROGEOLOGIC SETTING 3
1.5.4 RECEPTORS 4
1.5.5 DESCRIPTION OF GROUND WATER PLUME 4
2.0 SYSTEM DESCRIPTION 6
2.1 SYSTEM OVERVIEW 6
2.2 MONITORING PROGRAM 7
3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE CRITERIA 8
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA 8
3.2 TREATMENT PLANT OPERATION STANDARDS 9
4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT 10
4.1 FINDINGS 10
4.2 SUBSURFACE PERFORMANCE AND RESPONSE 10
4.2.1 PLUME CAPTURE 10
4.2.2 AQUIFER RESTORATION 11
4.3 COMPONENT PERFORMANCE 12
4.3.1 EXTRACTION SYSTEM WELLS, PUMPS, AND HEADER 12
4.3.2 GAC 12
4.3.3 CATALYTIC OXIDIZER 13
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF ANNUAL COSTS 13
4.4.1 UTILITIES 14
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS 14
4.4.3 LABOR 14
4.4.4 CHEMICAL ANALYSIS 14
4.4.5 SYSTEM MAINTENANCE 15
4.5 RECURRING PROBLEMS OR ISSUES 15
4.6 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL CONTAMINANT/REAGENT RELEASES 15
4.7 SAFETY RECORD 15
5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT 16
5.1 GROUND WATER 16
5.2 SURFACE WATER 16
5.3 AIR 16
IV
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5.4 SOILS 16
5.5 SURFACE WATER AND SEDIMENTS 17
6.0 RECOMMENDATIONS 18
6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS 18
6.1.1 DELINEATE CONTAMINATION IN OVERBURDEN AND BEDROCK TO THE EAST AND NORTHEAST 18
6.1.2 EVALUATE CAPTURE ZONE 18
6.1.3 SET UP MONITORING WELL SAMPLING PROGRAM 19
6.1.4 VAPOR MONITORING 19
6.2 RECOMMENDATIONS TO REDUCE COSTS 19
6.2.1 CLARIFY CONTRACTOR SCOPE 19
6.2.2 EVALUATE CATALYTIC OXIDIZER USAGE AND GAG CHANGE-OUT FREQUENCY 19
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT 20
6.3.1 START/IMPROVE REPORTING 20
6.4 CONSIDERATIONS FOR GAINING SITE CLOSE OUT 20
6.4.1 DEFINE EXIT STRATEGY 20
6.5 SUGGESTED APPROACH TO IMPLEMENTATION 21
7.0 SUMMARY 22
List of Tables
Table 7-1. Cost summary table
List of Figures
Figure 1 -1. Site location map
Figure 1-2. Well location map
Figure 1-3. Extent of VOC contamination (May 2001)
Figure 1-4. Extent of VOC contamination (July 2003)
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1.0 INTRODUCTION
1.1 PURPOSE
During fiscal years 2000, 2001, and 2002 Remediation System Evaluations (RSEs) were conducted at 24
Fund-lead pump and treat (P&T) sites (i.e., those sites with pump and treat systems funded and managed
by Superfund and the States). Due to the opportunities for system optimization that arose from those
RSEs, EPA OSRTI and OUST are performing a pilot study of conducting RSEs at UST sites. During
fiscal year 2003, RSEs visits at three State-managed UST sites were conducted in an effort to evaluate
the effectiveness of this optimization tool for this class of sites. GeoTrans, Inc. is conducting these
evaluations, and representatives from EPA may attend the RSEs as observers.
The Remediation System Evaluation (RSE) process was developed by the US Army Corps of Engineers
(USAGE) and is documented on the following website:
http://www.environmental.usace.army.niil/library/guide/rsechk/rsechk.html
A RSE involves a team of expert hydrogeologists and engineers, independent of the site, conducting a
third-party evaluation of site operations. It is a broad evaluation that considers the goals of the remedy,
site conceptual model, above-ground and subsurface performance, and site exit strategy. The evaluation
includes reviewing site documents, visiting the site for 1-1.5 days, and compiling a report that includes
recommendations to improve the system. Recommendations with cost and cost savings estimates are
provided in the following four categories:
• improvements in remedy effectiveness
• reductions in operation and maintenance costs
• technical improvements
• gaining site closeout
The recommendations are intended to help the site team (the responsible party, if one exists, and the
regulators) identify opportunities for improvements. In many cases, further analysis of a recommendation,
beyond that provided in this report, might be needed prior to implementation of the recommendation. Note
that the recommendations are based on an independent evaluation by the RSE team, and represent the
opinions of the RSE team. These recommendations do not constitute requirements for future action, but
rather are provided for the consideration of all site stakeholders. This RSE report pertains to conditions
that existed at the time of the RSE site visit, and any site activities that have occurred subsequent to the
RSE site visit are not reflected in this RSE report (unless otherwise noted).
The A-Z Automotive site was selected by EPA OUST, in coordination with NJDEP. This report
provides a brief background on the site and current operations, a summary of the observations made
during a site visit, and recommendations for changes and additional studies. The cost impacts of the
recommendations are also discussed.
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1.2
TEAM COMPOSITION
The team conducting the RSE consisted of the following individuals:
Peter Rich, Civil and Environmental Engineer, GeoTrans, Inc.
Doug Sutton, Water Resources Engineer, GeoTrans, Inc.
EPA OUST is jointly conducting this RSE Pilot Study for UST sites with EPA OSRTI.
1.3
DOCUMENTS REVIEWED
Author
Peter R. Spinney, Inc.
Peter R. Spinney, Inc
NJDEP
NJDEP
NJDEP (Bureau of
Wellfield Remediation)
NJDEP
NJDEP
NJDEP
Converse Consultants
East
NJDEP
NJDEP
NJDEP
Handex
Tri-Tech Engineering
NJDEP
NJDEP
NJDEP
Various
Date
October 19, 1990
October 29, 1990
August 8, 1991
May 1992
June 16, 1992
September 1, 1992
May 19, 1994
October 21, 1994
Novembers, 1994
March 15, 1995
May 15, 1995
March 11, 1997
March 11, 1997
February 11, 1999
May 28, 1999
July 25, 2001
July 2003
Various
Title
Household Water Supplies Quarterly Report
Underground Storage Tank Decommissioning letter
report (partial)
Case Transfer memorandum
Groundwater Investigation Results fact sheet
Ground Water Impact Area memorandum
Decision Document
October-December 1993 Progress Report memo
Well Sampling memorandum
Report on Contamination of Potable Well Supplies
October-December 1994 Progress Report memo
Alternatives Analysis Report
Potable Well Sampling memorandum
Soil Sample Results
Remedial Action Report (UST and Soil Removal)
Permit Authorization to Discharge Treated
Groundwater
Contract to Engage Handex
Well Sampling Data
Well Logs, Well Permits
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1.4 PERSONS CONTACTED
The following individuals associated with the site were present for the visit:
Ted Hayes, NJDEP
Tom O'Neill, NJDEP
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS
1.5.1 LOCATION
The A-Z Automotive site is a former gasoline retail outlet and automobile service station. It is located on
Union Valley Road between St. George Street and Lou Ann Boulevard in West Milford, Passaic County,
New Jersey. The site location is shown on Figure 1-1. St. George Street and Lou Ann Boulevard extend
southeast about 900 feet from Union Valley Road before they join and end. Approximately 25 residences
are located on St. George Street and Lou Ann Boulevard to the east of the A-Z site. The topography of
this area slopes from west to east, with an elevation difference of about 50 feet between the A-Z site and
the eastern end of the subdivision. Belcher Creek is about 1,000 feet further to the east of the
subdivision.
1.5.2 POTENTIAL SOURCES
Petroleum impacts were discovered at the site in 1989 initially due to a diesel spill that occurred during the
filling of a UST. Subsequent investigations found UST leaks, basement vapor issues, and potable well
impacts. The seven USTs containing diesel, gasoline, and kerosene were removed in 1990. Numerous
holes were observed in five of the USTs. In addition, stained soils, petroleum odors, and a sheen on
ground water were observed in the excavation. Approximately 1,022 tons of contaminated soil was
removed with the USTs, but contamination was known to remain in place after the tank removal. An
infiltration system was constructed in the former tank pit, which may have increased the potential for any
contamination in that area to impact ground water and/or to spread contaminated ground water.
In 1998 the pump islands, piping, and additional soil were removed. In 1999 a waste oil UST and a
heating oil UST (and associated contaminated soil) were removed, and post-excavation sampling indicated
all soil levels below New Jersey soil criteria (residential, non-residential, and impact to ground water).
1.5.3 HYDROGEOLOGIC SETTING
The site is located in the Green Pond Mountain Region of the New Jersey Highlands Physiographic
Province. Glacial deposits overlie bedrock at the site. Shallow ground water occurs in a glacial deposit
overburden that is reported to be about 80 feet below ground surface (bgs). Depth to ground water at the
site and in the downgradient impacted area ranges from about 5 to 35 feet bgs. In the deeper part of the
overburden (from about 50 to 80 feet bgs) large cobbles and a fluid sand zone have been noted. The
potable wells in the area are completed in the underlying bedrock (potable wells are reported to average
about 150 feet bgs).
The NJDEP (June 16, 1992 memorandum) provides estimates of hydraulic conductivity of 38.1 feet per
day (based on West Milford MUA Birch Hill Well 1 A) for the overburden and 6.4 feet per day for the
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bedrock. The reported gradient in the overburden (in the 1992 memo) was 0.022 feet per foot to the
southeast to east. This is consistent with water level data collected in June 1999. The bedrock gradient
was estimated at 0.03 feet/feet (in the 1992 memo, based on review of water levels in the same rock units
at the nearby Leroy's Mobil site), and was assumed at the time to be to the northeast due to the influence
of the Greenbrook Water Company supply wells located 3,000 feet northeast of the site. The RSE team
was not able to locate water level data that could confirm these assumptions.
1.5.4 RECEPTORS
As discussed earlier, potable wells in the area are screened in the bedrock aquifer. The glacial deposits
are presumably a source of recharge to the bedrock aquifer. The shallowest potable well was completed
to 90 feet bgs at a residence on Lou Ann Boulevard. That well was replaced with a deeper well, and the
former potable well was converted to a remedial system recovery well.
Between 1989 and 1992, potable well sampling indicated exceedances of NJDEP ground water standards
at nine potable wells, and detectable contaminant concentrations in twelve additional wells. Gasoline
odors were noted at that time in the basements of several residences.
Approximately 19 point of entry treatment (POET) systems with Granular Active Carbon (GAC)
treatment were in place as of May 1995, and most of these are still in place. Ground water quality is
monitored at the locations with POETs and 16 additional residences. Soil vapor extraction wells are
operated in the area and at three specific residences that have historically had vapor intrusion issues.
During the site visit, NJDEP stated that the POET systems were successful in providing potable water to
the residences and that the SVE system has been successful in preventing further vapor issues.
The 1995 NJDEP Alternatives Analysis Report estimates potential contaminant migration rates in the
overburden and bedrock. For benzene, the rates are 1.8 feet per day and 0.6 feet per day, respectively.
For MTBE, the rates are 3.8 feet per day and 1.5 feet per day, respectively. These estimated
contaminant migration rates indicate that contaminants may migrate through the overburden aquifer to
Belcher Creek within three years from 1995. The bedrock migration rates indicate that MTBE could
migrate to the Greenbrook Water Company wells within six years and benzene could migrate to the wells
within 14 years of 1995.
1.5.5 DESCRIPTION OF GROUND WATER PLUME
Contaminants of concern include typical gasoline constituents such as benzene, toluene, ethylbenzene,
xylenes (BTEX), methyl tertiary butyl ether (MTBE) and tertiary butyl alcohol (TEA). Benzene is
present above NJDEP standards in the most widespread area. Figure 1-3 depicts the extent of VOCs in
the overburden in May 2001, and Figure 1-4 depicts the extent of VOCs in the overburden in July 2003.
Analytical results for ground water samples taken in July 2003 show a marked decrease in the extent and
magnitude of dissolved concentration from earlier results. However, some of the wells sampled in 2001
were not resampled in 2003. For example, MW-37, the easternmost well, had elevated benzene and
MTBE concentrations in 2001 but was not resampled in 2003. The RSE team does not know the reason
why some of the wells were not resampled in 2003.
Free product has been observed at the site, reaching as far downgradient as RW-13 (300 feet east of the
abandoned gas station), where up to three feet of product has been observed during pumping conditions.
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During the site visit, it was reported that free product was recently noted in MW-9, MW-15, and MW-16.
There is concern that a large volume of product is trapped below the water table.
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2.0 SYSTEM DESCRIPTION
2.1 SYSTEM OVERVIEW
A P&T system was installed by the responsible party in 1990. The NJDEP took over operations at the
site in 1991. As of 1992, the remediation system included ten ground water recovery wells along St.
George Street and eleven vapor recovery points. Ground water was pumped from the wells to an
oil/water separator and then to an air stripper with GAC polishing. Twenty percent of treated water was
reported to be reinjected into the former tank field area while the remainder was discharged to the storm
sewer. The percentage of reinjected water was apparently increased between 1993 and 1999. Air
emissions from the air stripper were treated through vapor-phase GAC. Emissions from the vapor
recovery points were treated through a catalytic oxidizer. As of September 1992, NJDEP estimated that
4,500 gallons of petroleum product had been removed from the subsurface.
The system was upgraded in late 1993 and early 1994. Five new recovery wells with pneumatic total
fluid pumps replaced the previous extraction system. The extraction rate during this time was about 22
gpm. In late 1994, the air stripper was removed from the treatment system and GAC was used
exclusively for dissolved contaminant removal.
The system was altered in 1999 using RW-13 as the sole recovery well due to its relatively high yield and
high constituent concentrations relative to other wells. An electrical submersible pump was installed in
RW-13, and piping upgrades were made that allowed pumping of RW-13 up to about 20 gpm. The on-site
infiltration system was not capable of handling the discharge rate, so all treated water was discharged to
surface water. Free product was also collected from RW-13, and high vapor concentrations led to
reactivation of the SVE system.
The current P&T system consists of one main recovery well for hydraulic control (RW-13) with an
electrical submersible pump. Other wells are periodically pumped to lower the water table for SVE
application (MW-15 was being pumped at the time of the site visit). The discharge from the wells is
pumped to an equalization sump. The water from the sump is pumped on a batch basis at about 45 gpm
through two bag filters in series, followed by two 1,500-pound GAC units in series. The water flow is
measured with a totalizing flow meter before it is discharged to the storm sewer. The recent (May to July
2003) system flow rate has been about 20 gpm. One GAC unit is changed out about once per month.
The RSE team was not provided with any data indicating whether or not NPDES discharge limits are
met.
The current SVE system consists of several wells that can recover vapors from near residences.
Recovery wells are operated as needed to prevent contaminant migration to residences, and to remove
mass. The vapors are extracted a rate of approximately 70 to 100 cfm, and are currently treated by a
catalytic oxidizer. NJDEP reports that the catalytic oxidizer operates with an influent concentration of
approximately 10 ppm and uses approximately $680 per month in electricity. RW-13, MW-15 (on the
former station property), MW-8, MW-13, MW-16, MW-20 and MW-9 and other wells along St. George
Street have been used as vapor recovery points. On multiple occasions since October 2001, an internal
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combustion engine has been used for enhanced extraction at select monitoring wells (MW-1, MW-2,
MW-3, MW-4, MW-7, MW-9, MW-12, MW-15, and MW-16).
Within the source/high concentration area a significant volume of petroleum has been removed over time
by a combination of fluid extraction, vapor recovery, and hand bailing. An NJDEP status memo indicated
that 4,500 gallons of gasoline were recovered over a 12-month period beginning in the summer of 2001.
In addition to continuing P&T and SVE, NJDEP is beginning to conduct air sparging tests in St. George
Street area wells to determine if significant petroleum mass remains in the area. If petroleum mass is
found, ground water pumping to expose soil to SVE or possibly an air sparging system will be used.
2.2 MONITORING PROGRAM
The monitoring program has included sampling of monitoring wells on decreasing frequency since 1990.
Wells were sampled quarterly in 1990, semiannually in 1992 through 1997, annually from 1998 to 2001 and
again in 2003. It is unclear what future sampling frequency is proposed. The 2001 contract with Handex
specifies quarterly monitoring which has not been accomplished. Forty-one monitoring and five recovery
wells have been sampled either in 2001 or 2003, including ten wells that were installed in 2001.
Approximately eight of the monitoring wells are completed in bedrock while the remainder are overburden
wells. Ground water level data, except those associated with a pumping test in 1999, were not provided to
the RSE team. In addition, the RSE team was not provided with information that identifies the specific
wells completed in the bedrock.
Water quality is monitored at about 35 area potable wells on a regular basis including influent, first-GAC
effluent, and final effluent samples at POET systems. These monitoring schedules have been arranged
with and agreed to by homeowners.
Monitoring at the site remediation system includes weekly analysis of first-GAC effluent, monthly influent,
and final effluent. Vapor emissions are monitored by organic vapor analyzer (OVA) screening.
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3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE
CRITERIA
3.1
CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA
The main goal of the remediation at the site has been the protection of the residents' health by
maintenance of the POET systems and the vapor recovery systems. The ground water extraction and
treatment system has been historically used to prevent further migration of impacted ground water to
residences and remove contaminant mass. It appears that the current goal of the ground water extraction
is to capture ground water from the area near and upgradient of the lone recovery well (RW-13), which is
located approximately 300 feet downgradient of the site boundary. Other activities in the area upgradient
of RW-13 are intended to remove additional mass and hasten progress toward NJDEP standards. These
activities include SVE, sporadic ground water extraction at wells other than RW-13 (to expose screen
area to SVE), and air sparging (testing is ongoing). The area downgradient of RW-13 is apparently being
allowed to naturally attenuate, although there is no documented plan regarding this effort.
The following table outlines the most stringent NJDEP ground water standards for BTEX compounds,
MTBE and TEA.
Contaminant
Benzene
Ethylbenzene
Toluene
Xylenes
MTBE
TEA
NJDEP Standard
lug/L
700 ug/L
lOOOug/L
1000 ug/L
70 ug/L
100 ug/L
The number of wells impacted above these levels has decreased considerably since the mid-1990s, as
have the ground water concentrations. However, ground water concentrations continue to exceed
standards in wells near the source area and up to 900 feet downgradient of the site. Due to the long-term
impacts to potable water in this neighborhood and the potential migration of contaminants to public water
supply wells, any variance to the NJDEP standards is not likely.
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3.2
TREATMENT PLANT OPERATION STANDARDS
The system NPDES permit requires effluent reporting for the following parameters:
Parameter
Flow
Total Suspended Solid (TSS)
Total Organic Carbon (TOC)
Benzene
Naphthalene
MTBE
TEA
Total Petroleum Hydrocarbons (TPH)
pH
Lead
Daily Maximum
No limit
25mg/L
20mg/L
7ug/L
59ug/L
No limit
No limit
15mg/L
6 to 9
No sample required
Samples are analyzed monthly for the above parameters, except TPH andpH, for which samples are analyzed
quarterly
The key parameter requiring treatment is benzene. The concentration of benzene in RW-13 in July 2003
was 21 ug/L (the total BTEX concentration was 1,543 ug/L). No MTBE or TEA have been detected in
this well since initial sampling in 1997.
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4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT
4.1 FINDINGS
The observations provided below are not intended to imply a deficiency in the work of the system
designers, system operators, or site managers but are offered as constructive suggestions in the best
interest of EPA, NJDEP, and the public. These observations obviously have the benefit of being
formulated based upon operational data unavailable to the original designers. Furthermore, it is likely that
site conditions and general knowledge of ground water remediation have changed over time.
The RSE team notes a lack of formal reporting at this site over time. This makes it extremely difficult to
review this site for protectiveness, compliance with NPDES and air discharge requirements, and progress
toward meeting cleanup goals.
4.2 SUBSURFACE PERFORMANCE AND RESPONSE
4.2.1 PLUME CAPTURE
The NJDEP project manager at the site, Ted Hayes, believes in "splitting" the plume by containing the
source and high concentration areas and allowing the dilute plume to attenuate. This practice is used at
many sites and is generally reasonable. RW-13, which is screened in the overburden, is being used to
provide hydraulic containment, but data are not being collected or evaluated to indicate how effective the
hydraulic containment is. Concentrations in downgradient wells (MW-32, MW-37) remained well above
NJ standards in May 2001.
A simple water balance calculation indicates that at a pumping rate of about 20 gpm, a 77-foot wide
capture zone might be expected in the overburden based on previous estimates of hydraulic conductivity
and hydraulic gradient (see Section 1.5.3).
Q = WBKi
where
W (capture zone width)
Q (extraction rate)
B (saturated thickness) = 60 feet
K (hydraulic conductivity) = 38.1 feet/day
i (gradient) = 0.022 feet/feet
when Q = 20gpm (3,850 ft3/day), W = 77feet
This capture zone width is likely not sufficient to contain the plume. The distance between Lou-Ann
Boulevard and St. George Street is approximately 300 feet, and the plume appears to be wider than this
distance. Contamination stretches from northeast of Lou-Ann Boulevard (MW-24) to southwest of St.
10
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George Street (MW-13), which is a distance of approximately 700 feet. Because of an irregular plume
shape, however, this 700 feet may overestimate the width of the plume. Regardless, the estimated width
of the capture zone appears to be insufficient to provide adequate capture.
A pumping test was run in 1999 by pumping at RW-13. The analysis of this pumping test was not
provided for review by the RSE team. Results of that test could be used to confirm the estimate of
hydraulic conductivity.
4.2.2
AQUIFER RESTORATION
Significant volume of free product has been removed since remediation was initiated. For example,
approximately 4,500 gallons of product was collected over a one year period between 2001 and 2002.
The progress toward cleanup is commendable as nearly all wells show significant decreasing
concentration trends, and many have reached concentration levels below NJDEP ground water standards.
Dissolved BTEX and MTBE contamination exceed standards in 15 of the 46 sampled wells sampled since
2001. The following table presents concentrations for wells where dissolved contamination exceeded
standards in the latest sample taken at that well since 2000. For clarity, an analytical result for a
particular parameter from a particular well is not shown if it is less than the NJDEP standard.
Monitoring
Well
NJDEP
Standard
MW-6
MW-8
MW-12
MW-16
MW-19
MW-24
MW-26
MW-29
MW-31
MW-32
MW-37
MW-38
RW-11
RW-13
RW-14
Well
Location
near
source area
50' SE
250' SE
50' SE
150' SE
400' East
600' SE
400' East,
(Bedrock)
200' SE
600' SE
700' East
700' East
(Bedrock)
St. G. St.
300' SE
600' SE
Date of Most
Recent Sample
5/01
7/03
7/03
7/03
7/03
7/03
7/03
5/01
5/01
7/03
7/01
7/01
7/03
7/03
5/01
MTBE
(ug/L)
70
946
1.1
1.1
87
479
126
13.8
Benzene
(ug/L)
1
20
12
6
815
18.4
21
Ethylbenzene
(ug/L)
700
908
Xylenes
(ug/L)
1000
2,680
3,480
3,480
2,280
1,290
11
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Based on the July 2003 sampling of RW-13 (approximately 1,500 ug/L of VOCs), and using a flow rate of
20 gpm, the P&T system was removing about 0.4 pounds of BTEX per day.
20gal. 1,500 ug BTEX 3.785L 1440min. 2.21bs 0.361bsBTEX
x x x x— =
min. L gal. day 10 ug day
This is significantly less than the 5.3 pounds per day being removed based on the May 2001 sampling,
(when concentrations were much higher). This drop in mass removal between 2001 and 2003 may be
due to the aggressive remediation that occurred with the internal combustion engine between 2001 and
2003.
The SVE system, when operating at about 100 cfm with an influent concentration of 10 ppm
(approximately 40 mg/m3 of benzene, toluene, ethylbenzene and xylene) is also removing about 0.4 pounds
of VOCs per day.
100 ft3 40 mg BTEX 0.0283 m3 1440 mm. 2.2 Ibs 0.36 Ibs BTEX
•X X X X- —
min. m ft day 10 mg day
In addition to continuing P&T and SVE, NJDEP is conducting air sparging tests in St. George Street area
wells to determine if significant petroleum mass remains in the area. If petroleum mass is found, ground
water pumping to expose soil to SVE (or possibly an air sparging system) will be implemented.
4.3 COMPONENT PERFORMANCE
4.3.1 EXTRACTION SYSTEM WELLS , PUMPS , AND HEADER
The current system has one main recovery well, RW-13, which has an electric submersible pump. The
line from the extraction well to the equalization sump near the treatment system building was upgraded in
1999 and allows 20 gpm or greater flow rates. Other wells, primarily located along St. George Street, are
periodically pumped to lower the water table for SVE application. The ground water extraction system
apparently functions as designed.
Vapor extraction is applied at various wells, primarily along St. George Street (including MW-16). Vapor
extraction header lines lead to these wells and valving allows application of a vacuum at these wells when
desired.
4.3.2 GAC
Water from the equalization sump is pumped on a batch basis at about 45 gpm through two bag filters,
followed by two 1,500-pound GAC units prior to discharge. Samples are taken at the effluent of the first
GAC unit on a weekly basis to check for breakthrough. It was reported that GAC is changed out about
12 times per year, which appears to be extremely high based on the most recent recovery well sampling
12
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data from July 2003. These sampling data indicated an influent concentration of about 1,500 ug/L from
RW-13. At this concentration, the GAC usage should be approximately eight pounds of GAC per pound
of contaminant using isotherms from Dobbs and Cohen, 1980 (EPA-600/8-80-023). As calculated in
Section 4.2.2 of this report, the mass loading to the GAC based on the July 2003 data is approximately 0.4
pounds per day. Therefore, over the course of a year, the GAC usage should be approximately 1,200
pounds, unless substantial mass loading results from temporary pumping in other wells. By contrast, 1,500
pounds is replaced every month for a total GAC usage of 18,000 pounds per year. This change out
frequency would have been appropriate for the higher influent concentrations in previous years, but if the
influent concentrations remain this low, the site team should consider a reduced GAC replacement
frequency. System influent and effluent analytical results were not provided for this review. We
therefore cannot determine actual GAC usage or if treatment plant operational standards are being met.
4.3.3
CATALYTIC OXIDIZER
The catalytic oxidizer, likely a 100 cfm unit, is appropriately sized for the application. The electrical costs
to run the unit are $680 per month (approximately $8,000 per year), which is relatively high for the
contaminant mass that is treated. As calculated in Section 4.2.2 of this report, approximately 0.4 pounds
per day of contaminants are extracted in vapor form. This translates to approximately 150 pounds per
year, or approximately $50 per pound. By contrast, vapor phase GAC could likely provide treatment for
about half that cost or less.
4.4
COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
ANNUAL COSTS
The approximate annual O&M costs were discussed during the RSE site visit. Based on the input from
NJDEP and review of the July 25, 2001 memo describing the Handex engagement, the RSE team
estimates that O&M will cost approximately $225,000 per year in the upcoming years. More recent
scopes and associated costs were not provided to the RSE team, so these estimates may be somewhat
out of date. However, the provided breakdown allows a clear picture of where the larger percentages of
costs were being spent and potentially where savings are possible.
Item Description
Weekly inspections (8-hrs/wk)
P&T operations laboratory analysis
P&T/S VE equipment rental
1 500 pound LGAC unit changeouts (12 per year)
Bag filters and VGAC changeouts
Monitoring well sampling labor
Monitoring well sampling analysis
Electricity
System maintenance/upgrades
Operations review/management/permitt ing
POET system sampling and GAC changeouts + bottled water
Total Estimated Cost
Estimated Cost per Year
$22,880
$8,012
$51,280
$27,000
$2,884
$10,560
$9,825
$20,000
$12,240
$17,750
$42,945
$225,376
13
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The Handex engagement scope also included piping repairs at $29,556 and an upgrade to the injection
gallery at $25,204. These items should not be recurring annual costs, so they are not included in the cost
breakdown.
4.4.1 UTILITIES
The site utilities costs are mainly related to electricity requirements for the catalytic oxidizer (reported to
be about $680 per month), pump operation, and building heating.
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS
Replacement of the 1,500 pound GAC units used for adsorbing VOCs from ground water is the main
consumable cost item.
4.4.3 LABOR
Labor consists of weekly inspections and monitoring well sampling plus operations review, management,
and permitting.
• Eight hours per week are allocated for weekly site inspections including inspection of
ground water recovery, vapor recovery, and POET systems (including pressure and flow
readings, weekly visual inspections of the storm sewer discharge, recovery pump
operation, and maintaining the on-site compressor). Also included are water level and
product thickness measurements.
• Weekly entries in the site log book showing pressure and flow measurements indicate
that system checks are being accomplished. The frequency of water level measurements
is not clear.
• System operations review and permitting is allocated 290 hours over a year period in the
Handex engagement. It is not clear how this time is (or would be) spent because the
RSE team was not provided with any recent reports regarding system operation.
• Labor is allocated for sampling 35 monitoring wells on a quarterly frequency; however,
only one sampling event was reported to the RSE team between June 2001 and August
2003.
4.4.4 CHEMICAL ANALYSIS
Chemical analysis costs include those for POET sampling, P&T system process sampling, and monitoring
well sampling. With decreasing influent concentrations, the weekly frequency of sampling the first GAC
unit effluent may be excessive. The Handex engagement has analysis of 140 well samples per year
scheduled based on a quarterly sampling frequency, but actual sampling has occurred much less
frequently.
14
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4.4.5 SYSTEM MAINTENANCE
The Handex engagement allocates 80 hours each for a plumber, electrician, and laborer for repairs or
replacement of treatment equipment.
4.5 RECURRING PROBLEMS OR ISSUES
The area residents are very interested in the remediation progress. It was reported that relations between
NJDEP and the residents are generally good at this time.
4.6 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL
CONTAMINANT/REAGENT RELEASES
The site team did not indicate any treatment process excursions or releases.
4.7 SAFETY RECORD
The site team did not indicate any reportable incidents.
15
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5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
HEALTH AND THE ENVIRONMENT
5.1 GROUND WATER
The release from the site has impacted numerous residential potable wells. Point of entry treatment
(POET) systems were installed and are maintained at several residences and other potable wells are
sampled on a regular basis. Bottled water is also supplied to affected residents. The RSE team is not
aware of any reports of recent problems with potable wells in the area above and beyond those addressed
by the remedy.
Some of the highest dissolved contaminant concentrations recently detected at the site were in MW-37, a
well about 900 feet east of the contaminant source area. Contaminants were also detected in the bedrock
well at this location. Given that no monitoring wells are located further east in overburden or northeast in
bedrock from these wells, it is unclear how far the plume extends toward the supply wells to the northeast.
5.2 SURFACE WATER
It is not known if any contaminants are discharging to Belcher Creek about 900 feet downgradient of the
closest monitoring well. The RSE team does not know of any surface water sampling efforts. Modeling in
the Alternatives Analysis report indicates that the contaminant plume would be expected to reach the
creek. The RSE team notes that contaminants would likely be diluted in the surface water and/or volatilize
such that detection in surface water would be unlikely.
5.3 AIR
Vapor intrusion has been a problem in at least three residences. The site soil vapor extraction systems
have been effectively operated to prevent continued vapor migration into the houses. Vapor
concentrations have apparently decreased considerably, but it is not clear if the vapor sources have been
completely removed. NJDEP is investigating if additional VOCs can be removed by air sparging.
5.4 SOILS
Contaminated soil has been removed from the site on several occasions and soil vapor extraction has been
conducted with wells in the former tank field and dispenser areas. Depth to water at the former service
station site is about 30 feet bgs, which suggests that all of the impacted vadose zone soil was not removed
with the excavations at the site. The SVE system has likely been effective at removing much of the
remaining source mass above the water table, based on the significantly decreased concentrations in
monitoring wells near the source area. Due to the presence of an asphalt cover, there is no exposure
pathway to contaminated soils.
16
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5.5 SURFACE WATER AND SEDIMENTS
The highest levels of dissolved contaminants at the site are currently found in MW-37, which is the closest
well to the nearby wetlands and Belcher Creek. No information is available to assess any potential
impacts to wetlands. Contaminants would likely volatilize such that detection in surface water of wetlands
would be unlikely. The contaminants at this site do not generally sorb strongly on sediments.
17
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6.0 RECOMMENDATIONS
Cost estimates provided herein have levels of certainty comparable to those done for CERCLA Feasibility
Studies (-307+50%), and these cost estimates have been prepared in a manner consistent with EPA 540-R-
00-002, A Guide to Developing and Documenting Cost Estimates During the Feasibility Study, July
2000.
6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS
6.1.1 DELINEATE CONTAMINATION IN OVERBURDEN AND BEDROCK TO THE EAST AND
NORTHEAST
Based on the July 2001 sampling results, the well furthest downgradient to the east (MW-37), had levels of
benzene and MTBE at 815 ug/L and 126 ug/L, respectively. MW-38, the bedrock well at this location, also
has elevated contaminant levels. This is a concern for contaminant delineation in the overburden, and
more importantly, in bedrock. The 1995 Alternative Analysis Report indicated that contamination could
migrate in bedrock from the site toward potable supply wells to the northeast. This concern is not
addressed by the current monitoring well network. We understand that installing additional wells to the
east of MW-37/38 is difficult. At a minimum, an overburden and bedrock well pair should be installed
about 500 to 1,000 feet north-northeast of MW-37/38 to serve as a sentinel well for migration toward
Camp Hope and the Greenbrook Water Company wells. The cost for this well installation should be about
$25,000.
In addition, water levels from bedrock and overburden wells should be analyzed on at least an annual basis,
and piezometric and cross section maps should be produced to indicate the direction of ground water flow
and contaminant migration laterally and vertically. This information should be included in the annual report
discussed in Section 6.3.1. Naming bedrock wells with a "B" identifier (such as "MW-38B") would assist
in data analysis, reporting, and review efforts.
6.1.2 EVALUATE CAPTURE ZONE
A simple water budget analysis (presented earlier) indicates that the capture zone due to pumping at RW-
13 is likely not wide enough to capture the width of the plume. Results of the pumping test in 1999 should
be reviewed. A target capture zone should be clearly specified and illustrated, and this target capture zone
should be consistent with the goals of the remedy. Additional evaluation of the capture zone should then be
conducted, using various potential lines of evidence. In addition to a simple water budget analysis, potential
lines of evidence that are appropriate for this site might include interpretation of potentiometric surface
maps, evaluation of hydraulic gradients at well pairs, and evaluation of concentration trends at wells
located downgradient of the target capture zone. This effort could require an initial expenditure of $10,000,
plus an additional $3,000 per year thereafter.
18
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6.1.3 SET UP M ONITORING WELL SAMPLING PROGRAM
A regular ground water monitoring program should be initiated at the site. We recommend annual
monitoring at select wells. The select wells should include the perimeter network (MW-33 through MW-
42) plus MW-6, MW-16, MW-31, MW-24, MW-29, MW-26, MW-30, MW-32, and RW-13. Monitoring
the wells upgradient of RW-13 will provide an indication of progress toward aquifer restoration, and
monitoring wells downgradient of RW-13 should provide information with regard to capture and aquifer
restoration.
NJDEP is currently contracting for quarterly sampling at 35 to 40 wells. The sampling program suggested
above would have a total of 19 wells with a lower sampling frequency. This program might reduce
sampling and analysis costs by about $10,000 to $15,000 per year.
6.1.4 VAPOR M ONITORING AT NEARBY RESIDENCES
NJDEP has run the SVE system on and off to recover vapor and prevent vapor intrusion at residences on
St. George Street, and there are and have been vapor monitoring points with alarms within four houses in
this area. The monitoring points likely were based on lower-explosive limit (LEL) sensors and activated the
secondary SVE blowers at specific residences. However, there does not appear to be any recent indoor
air sampling events. It would seem reasonable that all of the houses with POET systems should have
indoor air checked at least once, especially those that historically had relatively elevated concentrations in
ground water or soil vapor on the property. This would involve sampling up to 19 houses. With sampling
labor and analyses, this sampling event might cost $10,000.
6.2 RECOMMENDATIONS TO REDUCE COSTS
6.2.1 CLARIFY CONTRACTOR SCOPE
Activities at the site do not appear to be organized effectively enough to control costs systematically.
Handex's engagement letter includes activities that are not occurring and "extra" activities occur
frequently. This may cause difficulty in tracking costs relative to forecasts or budgets. The control also
includes a significant expense in long-term equipment rental. The money spent on the rental of this
equipment is likely more than enough to have purchased it. If P&T and SVE or other activities are to
continue for several years, we encourage NJDEP to produce a clear scope of work for actual continuing
regular activities, including reporting and contract with Handex based on the revised scope. Equipment
that is currently rented and still needed should be available at a purchase price that is a fraction of the new
cost. Any non-routine work, such as air-sparging testing, should be described in a brief work plan, and
contractor assistance can be contracted as a contingent work order. The exact cost savings possible from
this recommendation cannot be estimated.
6.2.2 EVALUATE CATALYTIC OXIDIZER USAGE AND GAC CHANGE-OUT FREQUENCY
The current influent vapor concentration to the catalytic oxidizer is relatively low and requires a significant
electric usage to continue operating the system. Unless significant new vapor mass can be removed at the
site, use of the catalytic oxidizer should be suspended. Vapor phase GAC units can be used to replace the
catalytic oxidizer. At the estimated VOC removal rate of less than one pound per day, use of the vapor
phase GAC should require less than $5,000 per year in comparison to the $30,000 per year in rental costs
19
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and about $8,000 per year in electric costs for the catalytic oxidizer. The predicted cost savings is
approximately $33,000 per year.
With respect to the liquid phase GAC units, we did not find any documentation for the practice of changing
out 12 GAC vessels per year. Influent concentrations and flow rates should be used to estimate the GAC
change-out frequency. If the influent concentration remains at 1,500 ug/L or lower, monthly monitoring
should be sufficient to evaluate breakthrough. Based on the July 2003 sampling at RW-13 (as discussed in
Section 4.3.2), the change-out frequency should be reduced to 1-4 units per year.
If GAC replacements could be reduced to four per year, it would save at least $18,000 per year.
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT
6.3.1 START/IMPROVE REPORTING
Although this site is progressing toward cleanup and human health is apparently being protected, the lack
of documentation of decisions and reporting of data is an issue. The lack of reports for this site (including
treatment system operation data, such as effluent analysis, water pumped at each well, vapor extracted by
well, and water level data) makes it extremely difficult to review this site for protectiveness, compliance
with NPDES and air discharge requirements, and progress toward meeting cleanup goals.
At a minimum quarterly reports describing treatment system operation (wells pumped, flows, SVE wells
operated, vapor concentrations) with sampling results should be produced, and annual reports with ground
water concentration data/trends and capture zone evaluation should be produced. Handex is being paid for
project overview which should include some reporting requirements. However, we will assume that
additional funding of $15,000 per year will be needed to produce useful reports.
6.4 CONSIDERATIONS FOR GAINING SITE CLOSE OUT
6.4.1 DEFINE Exrr STRATEGY
Remediation efforts have made significant progress in reducing contaminant concentrations at the site, but
mass removal rates have decreased considerably. The site remediation progress is at a good stage to
define and evaluate the current state of the site and determine what will be necessary to suspend active
treatment system operations.
The site project manager is already using air sparging tests to determine if there are any remaining areas
where significant amounts of contaminant mass can be removed. Once this effort has concluded, an
evaluation should be made as to whether or not aquifer restoration is possible with the current approach of
P&T plus SVE. If so, a time frame for shutting down the system should be estimated, and a specific
monitoring program to indicate when the system can be shut off (including post-shut-down monitoring)
should be determined. In addition, a plan for delineating and remediating (actively or passively)
contamination downgradient of the RW-13 capture zone should be developed. Review and development of
this strategy should require about $8,000.
20
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6.5 SUGGESTED APPROACH TO IMPLEMENTATION
All the recommendations are relatively straightforward and easily to implement. Using the information
from the delineation efforts associated with 6.1.1, the monitoring results from 6.1.3, and useful reports
(Section 6.3.1) will allow effective analysis for defining an exit strategy (Section 6.4.1). If this strategy
includes capturing ground water upgradient of RW-13, then analysis of the capture zone (Section 6.1.2)
should be conducted and additional actions may then be required.
21
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7.0 SUMMARY
The observations and recommendations contained in this report are not intended to imply a deficiency in
the work of either the system designers or operators but are offered as constructive suggestions in the best
interest of the EPA and the public. These recommendations have the obvious benefit of being formulated
based upon operational data unavailable to the original designers.
Recommendations to improve the effectiveness of the system include further delineation of ground water
impacts beyond MW-37 and MW-38, performing capture zone analysis (including the development of a
target capture zone), formalizing a well sampling program, and conducting vapor monitoring at nearby
residences. Recommendations to reduce costs include clarifying the scope of the site contractor, switching
from the catalytic oxidizer to vapor phase carbon, and reducing the frequency of GAC changeouts. A
recommendation for technical improvement is to begin more formal reporting regarding the status and
progress of the system. A recommendation for site closeout is to start formulating a site-specific exit
strategy that includes an estimated time frame for shutting down the system, and a specific monitoring
program to indicate when the system can be shut off (including post-shut-down monitoring). All of these
recommendations can be easily implemented, and a prioritization of the recommendations is provided.
Table 7-1 summarizes the costs and cost savings associated with each recommendation in Sections 6.1
through 6.4. Both capital and annual costs are presented. Also presented is the expected change in life-
cycle costs over a five-year period for each recommendation both with discounting (i.e., net present value)
and without it.
22
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Table 7-1. Cost Summary Table
Recommendation
6.1.1 Delineation to the
Northeast
6. 1 .2 Evaluate Capture Zone
6. 1 .3 Set up a Monitoring
Program (*)
6.1.4 Residence Vapor
Monitoring
6.2.1 Clarify Contractor Scope
6.2.2 Evaluate Catalytic
Oxidizer Usage and GAC
Change-out Frequency
6.3.1 Reporting
6.4.1 Exit Strategy
Reason
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Cost
Cost
Technical
Improvement
Gain
Site/ System
Closeout
Additional
Capital
Costs
($)
$25,000
$10,000
$10,000
not quantified
$8,000
Estimated
Change in
Annual
Costs
($/yr)
$3,000
($12,500)
$0
not quantified
($51,000)
$15,000
Estimated
Change
in Life-cycle
Costs
(S)1
$25,000
$25,000
($62,500)
$10,000
not quantified
($255,000)
$75,000
$8,000
Estimated
Change
in Life-cycle
Costs
($)2
$25,000
$23,600
($57,000)
$10,000
not quantified
($232,000)
$68,000
$8,000
Costs in parentheses imply cost reductions.
1 assumes five years of operation with a discount rate of 0% (i.e., no discounting)
2 assumes five years of operation with a discount rate of 5% and no discounting in the first year
(*) Calculated savings vs. existing proposed sampling (not actual sampling program)
23
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FIGURES
-------
FIGURE 1-1. SITE LOCATION MAP
' fi"'
/•=£**•—•
.-• • •••—fi
1500
SCALE IN FEET
3000
-N-
(Note: This figure is taken from Greenwood Lake, NY-NJ U.S.G.S. Quadrangle, 1954
Quadrangle Location
-------
FIGURE 1-2. WELL LOCATION MAP
MW-38
FORMER A-Z
AUTOMOTIVE
PROPERTY
(Note: This figure is developed based on a site plan
developed by Accutech in 1998 and discussions during
the RCE site visit.)
0 100
SCALE IN FEET
200
LEGEND
® MONITORING WELL USED AS SPARGE POINT
0 MONITORING WELL
A ACTIVE RECOVERY WELL
A INACTIVE RECOVERY WELL
PROPERTY LINE
MW-41 f
MW-42
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FIGURE 1-3. EXTENT OF VOC CONTAMINATION IN MAY 2001
.MW-33
-------
FIGURE 1-4. EXTENT OF VOC CONTAMINATION IN JULY 2003
MW-36
V.
\
FORMER A
AUTOMOTIVE
PROPERTY
o
(Note: This figure is developed based on a site plan
developed by Accutech in 1998 and site data provided
by NJDEP.)
0 100
SCALE IN FEET
200
BTEX AND MTBE SAMPLED AND
BELOW NJDEP STANDARDS
BTEX AND/OR MTBE CONCENTRATIONS
THAT ARE 1 TO 10 TIMES GREATER
THAN NJDEP STANDARDS
BTEX AND/OR MTBE CONCENTRATIONS
THAT ARE 10 TO 100 TIMES GREATER
THAN NJDEP STANDARDS
BTEX AND/OR MTBE DETECTED
AT CONCENTRATIONS THAT ARE
MORE THAN 100 TIMES GREATER
THAN NJDEP STANDARDS
MW-38
MW-41
MW-42
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