REMEDIATION SYSTEM EVALUATION
MORGAN TERMINAL
BROOKLYN, NEW YORK
Report of the Remediation System Evaluation,
Site Visit Conducted at the Morgan Terminal Site
June 4, 2003
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Office of Solid Waste EPA 542-F-04-029
and Emergency Response June 2004
(5102G) www.epa.gov/tio
clu-in.org/optimization
Remediation System Evaluation
Morgan Terminal
Brooklyn, New York
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NOTICE AND DISCLAIMER
Work described herein was performed by GeoTrans, Inc. (GeoTrans) for the U.S. Environmental
Protection Agency (U.S. EPA). Work conducted by GeoTrans, including preparation of this report, was
performed under S&K Technologies Prime Contract No. GS06T02BND0723 and under Dynamac Prime
Contract No. 68-C-02-092, Work Assignment ST-1-08. 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.
The Morgan Terminal site is an abandoned oil terminal located at 200 Morgan Avenue in Brooklyn, New
York. The site has historically been contaminated with diesel fuel, No.6 fuel oil, and BTEX/MTBE.
Current contamination largely consists of No. 6 fuel oil and relatively low concentrations of
BTEX/MTBE. The surrounding area is comprised of industrial facilities and warehouses. Morgan
Avenue borders the site to the west and the English Kills borders the site to the north and east. Figure 1
depicts the primary features of the site and the site's location with respect to the English Kills.
Site-related contamination was first reported in 1992 by the Coast Guard when oil was found seeping
into the English Kills. Between December 1992 and January 1993 a remedial investigation was
conducted including the installation of 20 ground water monitoring wells and tank testing. The tanks
were cleaned in 1994, and a remediation system became operational in June 1995. The State does not
own the property. The current owner reportedly lives in Florida and, at the time of the interim consent
order in 1994, over $800,000 in back taxes were owed. The State has a lien on the property to recover
costs if the property is ever sold.
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 are as
follows:
Analysis of chlorinated solvents and polynuclear aromatic hydrocarbons (PAHs) should be added
to the ground water monitoring program for at least two quarters to determine if ground water is
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contaminated with these constituents. It does not appear that ground water has been sampled for
these constituents. Site records indicate that chlorinated solvents were present at the mg/L level
in some of the tanks that may have leaked. PAHs are often associated with No. 6 fuel oil.
The site structures, including the storage tanks and loading docks, should be removed. The
contaminated soil found beneath these structures and located above the water table could be
investigated and/or excavated. Although the property is in a favorable business location given its
proximity to the water, the presence of these structures and the underlying contamination are
substantial business risks. Removing these structures and either delineating or removing the
underlying contamination will help the future development of the property and assist in remedial
activities.
The site conceptual model should be updated after the demolition and excavation. Changes in
infiltration and ground water flow may be expected. In addition, much of the source material
may be removed. The site conceptual model should also be updated with respect to chlorinated
solvent or PAH contamination if any is detected in the above-recommended sampling and
analysis.
The site team could not locate a discharge permit for its remediation system and no sampling of
the effluent is conducted. The discharge permit/agreement should either be located or a new one
should be obtained and sampling should be conducted accordingly.
The RSE team does not provide any specific recommendations for cost reduction but does agree with
recent cost reduction measures undertaken by the site team, including the elimination of vacuum
enhanced fluid recovery events and a reduction in the well-gauging frequency. Recommendations are
provided for technical improvement, including improving the site reports and simplifying the treatment
system. One recommendation is provided for gaining site closeout, or rather, system closeout. It is to
consider an alternative remedial approach based on institutional controls and passive skimming of free
product. The rationale for this approach is the immobility and relatively low toxicity of the No. 6 fuel,
the absence of free product discharges to surface water, and the high cost of removing the remaining free
product and impacts that reach below the water table. The success of implementing this type of
approach, however, is contingent on finding no significant chlorinated solvent and PAH ground water
contamination.
A table summarizing the recommendations, including estimated costs and/or savings associated with
those recommendations, is presented in Section 7.0 of this report.
11
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PREFACE
This report was prepared as part of a pilot project conducted by the United States Environmental
Protection Agency (USEPA) 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
USEPA Office of Underground
Storage Tanks (OUST)
Joe Vescio
Joseph P. Vescio
EPA Headquarters 5401G
Ariel Ross Building
1200 Pennsylvania Ave, N.W.
Washington, D.C. 20460
phone: 703-603-0003
fax: 703-603-0175
vescio j oseph@epa.gov
USEPA Office of Superfund
Remediation and Technology
Innovation
(USEPA OSRTI)
Kathy Yager
11 Technology Drive (ECA/OEME)
North Chelmsford, MA 01863
phone: 617-918-8362
fax: 617-918-8427
yager.kathleen@epa.gov
USEPA Office of Superfund
Remediation and Technology
Innovation
(USEPA OSRTI)
Ellen Rubin
5102G
USEPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, N. W.
Washington, DC 20460
703-603-0141
rubin.ellen@epa.gov
GeoTrans, Inc.
(Contractor to USEPA)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
(732) 409-0344
Fax: (732) 409-3020
dsutton@geotransinc.com
in
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TABLE OF CONTENTS
EXECUTIVE SUMMARY i
PREFACE iii
TABLE OF CONTENTS iv
1.0 INTRODUCTION 1
.1 PURPOSE 1
.2 TEAM COMPOSITION 2
.3 DOCUMENTS REVIEWED 2
.4 PERSONS CONTACTED 3
.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS 3
1.5.1 LOCATION 3
1.5.2 POTENTIAL SOURCES 3
1.5.3 HYDROGEOLOGIC SETTING 4
1.5.4 RECEPTORS 5
1.5.5 DESCRIPTION OF GROUND WATERPLUME 5
2.0 SYSTEM DESCRIPTION 6
2.1 SYSTEM OVERVIEW 6
2.2 MONITORING PROGRAM 6
3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE CRITERIA 7
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA 7
3.2 TREATMENT PLANT OPERATION STANDARDS 7
4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT 8
4.1 FINDINGS 8
4.2 SUBSURFACE PERFORMANCE AND RESPONSE 8
4.2.1 PLUME CAPTURE 8
4.2.2 AQUIFER RESTORATION 8
4.3 COMPONENT PERFORMANCE 9
4.3.1 EXTRACTION SYSTEM WELLS, PUMPS, AND HEADER 9
4.3.2 SEPARATORS 9
4.3.3 GAC 9
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF ANNUAL COSTS 9
4.4.1 UTILITIES 10
4.4.2 NON-UTILITY CONSUMABLES 10
4.4.3 LABOR 10
4.4.4 CHEMICAL ANALYSIS 10
4.5 RECURRING PROBLEMS OR ISSUES 10
4.6 REGULATORY COMPLIANCE 11
4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL CONTAMINANT/REAGENT RELEASES .... 11
4.8 SAFETY RECORD 11
5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT . 12
5.1 GROUND WATER 12
5.2 SURFACE WATER 12
5.3 AIR 12
5.4 SOILS 12
5.5 WETLANDS AND SEDIMENTS 13
iv
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6.0 RECOMMENDATIONS 14
6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS 14
6.1.1 DETERMINE IF CHLORINATED SOLVENTS AND PAHs ARE PRESENT IN GROUND WATER 14
6.1.2 IMPROVE THE SITE CONDITION BY DEMOLISHING STRUCTURES AND INVESTIGATING AND/OR
EXCAVATING UNDERLYING CONTAMINATED SOILS 14
6.1.3 DEVELOP A REVISED SITE CONCEPTUAL MODEL AND SET MEASURABLE OBJECTIVES 16
6.1.4 OBTAIN A DISCHARGE AGREEMENT AND COLLECT EFFLUENT SAMPLES 17
6.2 RECOMMENDATIONS TO REDUCE COSTS 17
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT 17
6.3.1 IMPROVE REPORTS 17
6.3.2 CONSIDER REMOVING THE GAC EFFLUENT TANK 18
6.3.3 REPAIR INSULATION OR RELOCATE TREATMENT COMPONENTS 18
6.4 CONSIDERATIONS FOR GAINING SITE CLOSE OUT 18
6.4.1 CONSIDER AN ALTERNATIVE REMEDIAL APPROACH 18
6.5 SUGGESTED APPROACH TO IMPLEMENTATION 19
7.0 SUMMARY 20
List of Tables
Table 7-1. Cost summary table
List of Figures
Figure 1-1. Site map and the observed extent of free product
Figure 1-2. Extent of dissolved contamination above the most stringent State standards as observed in July
2002
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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 at up to 3 State-managed UST sites are planned in an effort to evaluate the
effectiveness of this optimization tool for this class of sites. GeoTrans, Inc., an EPA contractor, is
conducting these evaluations, and representatives from EPA OUST are attending 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.armv.mil/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 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 (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.
The Morgan Terminal facility was selected by EPA OUST, in coordination with State agencies. 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:
Rob Greenwald, Hydrogeologist, GeoTrans, Inc.
Peter Rich, Civil and Environmental Engineer, GeoTrans, Inc.
Doug Sutton, Water Resources Engineer, GeoTrans, Inc.
The RSE team was also accompanied by the following observers:
Joe Vescio, EPA OUST
Judy Barrows, EPA OUST
EPA-OUST is jointly conducting this RSE Pilot Study for UST sites with EPA-OSRTI.
1.3
DOCUMENTS REVIEWED
Author
NYSDEC
Fenley & Nicol
Environmental
Fenley & Nicol
Environmental
Fenley & Nicol
Environmental
Fenley & Nicol
Environmental
Fenley & Nicol
Environmental
Fenley & Nicol
Environmental
Fenley & Nicol
Environmental
Miller Environmental
Group
EcoTest Laboratories, Inc.
EcoTest Laboratories, Inc.
Miller Environmental
Group
Date
12/3/1992
3/6/1993
2/14/1995
6/20/1996
2/26/1997
4/9/1998
3/2/1999
8/14/1999
6/2001
7/26/2001
8/8/2002
1 1/2002
Title
Interim Order on Consent
Subsurface Investigation at Morgan Terminal
Remediation Proposal, Morgan Terminal
Status Report - November 1995 - April 1996
Semi-Annual Status Report Morgan Terminal
Status Report, Morgan Oil Terminal
Status Report, Morgan Oil Terminal
Status Report, Morgan Oil Terminal, July 1998 -
March 1999
Site Status Report, January 200 1 - June 200 1
Laboratory Data
Laboratory Data
Site Status Monitoring Report, July 2002 -
November 2002
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1.4 PERSONS CONTACTED
The following individuals associated with the site were present for the visit:
Skip Taylor, Miller Environmental Group
Louis Nardolillo, Miller Environmental Group
Karen Sheridan, Miller Environmental Group
Jennifer Rommel, NYSDEC
Kerry Foley, NYSDEC
Jeff Vought, NYSDEC
Ben Singh, EPA Region II
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS
1.5.1 LOCATION
The Morgan Terminal site is an abandoned oil terminal located at 200 Morgan Avenue in Brooklyn, New
York. The site consists of a two story terminal operations building and maintenance building, seven bulk
fuel oil storage tanks, and several underground storage tanks. The site has historically been impacted by
diesel fuel and No. 6 fuel oil and dissolved hydrocarbons. Current contamination largely consists of No.
6 fuel oil. The surrounding area is comprised of industrial facilities and warehouses. Morgan Avenue
borders the site to the west, the English Kills borders the site to the north and east, and an alley and other
industrial properties border the site to the south. Figure 1-1 depicts the primary features of the site and
the site's location with respect to the English Kills.
Site-related contamination was first reported in 1992 by the Coast Guard when oil was found seeping
into the English Kills. Between December 1992 and January 1993 a remedial investigation (RI) was
conducted including the installation of 20 ground water monitoring wells and tank testing. Primary
recommendations included additional subsurface investigation, removal of floating product from
monitoring wells, emptying and cleaning of tanks, and design of a remediation system. Additional
investigations have occurred and the site now has over 40 monitoring wells. The tanks were cleaned in
1994, and a remediation system became operational in June 1995.
The State does not own the property. The current owner reportedly lives in Florida and, at the time of the
interim consent order in 1994, over $800,000 in back taxes were owed. The State has a lien on the
property to recover costs if the property is ever sold.
1.5.2 POTENTIAL SOURCES
The fuel oil storage tanks and other operations were the likely sources of contamination. The following
table outlines for each storage tank the construction material, capacity, and former contents. Other
smaller underground storage tanks are also present on the site and are indicated on Figure 1-1.
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Tank
Number
1
2
o
J
4
5
6
7
Type
Steel/Carbon Steel
Steel/Carbon Steel
Steel/Carbon Steel
Steel/Carbon Steel
Steel/Carbon Steel
Steel/Carbon Steel
Steel/Carbon Steel
Capacity
645,000
7,000
55,000
67,000
507,000
400,000
244,000
Product Formerly Stored
Nos. 5 or 6 Fuel Oil
Nos. 1, 2, or 4 Fuel Oil
Nos. 1, 2, or 4 Fuel Oil
Nos. 1, 2, or 4 Fuel Oil
Nos. 5 or 6 Fuel Oil
Nos. 1, 2, or 4 Fuel Oil
Nos. 1, 2, or 4 Fuel Oil
Though some tanks have been removed and other tanks have been cleaned, the conditions beneath the
large storage tanks (including ST-1 through ST-5 on Figure 1-1) have not been investigated and this area
may have significant free product in the soil. The wells with the highest dissolved hydrocarbon
concentrations (in the vicinity of FN-26) are not near the wells with free product as shown in Figures 1-1
and 1-2, but the remaining free product at the site may serve as a continuing source for other dissolved
phase contamination. Analysis of the contents from some of the tanks in 1994 revealed chlorinated
hydrocarbons (tetrachloroethene, 1,1,1-tetrachloroethane, and trichloroethene) at the mg/L level. As of
the RSE site visit, ground water samples had not been analyzed for these constituents.
It is generally understood that the free product remaining at the site is No. 6 fuel oil and that the majority
of the lighter oils have either discharged to the English Kills or have been removed with the remediation
system.
1.5.3
HYDROGEOLOGIC SETTING
According to the 1993 subsurface investigation conducted by Fenley & Nicol, the site is underlain by
dark, very loose to medium compacted, fine to medium-grained sand with traces of pebbles, silt, brick,
and concrete (fill). The predominant native formation consists of fine to medium sand with traces of
pebbles. A peat layer is present at 12 feet below ground surface. The ground water table is generally 2
to 6 feet below ground surface.
Ground water flow is generally to the northwest toward the English Kills at an approximate hydraulic
gradient of 0.01 feet/foot. Ground water flow, however, is substantially influenced by mounding near the
storage tanks. As a result, ground water near the southern boundary of the property flows off site to the
south. MTBE contamination has been found over 50 feet to the south of the site (FN-22 as depicted in
Figure 1-2).
The wells yield very little water (i.e., approximately 1 gpm) but this may be predominantly due to fouling
of the wells over time rather than the hydraulic properties of the aquifer. No record of pump tests were
found, and the extraction rate of the remediation system is not provided. For reference, however,
approximately 625 gallons of total fluids were removed by 5 vacuum enhanced fluid recovery events
conducted in two wells (FN-11A and FN-15A), or approximately 6 gallons of total fluids per well per
event.
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1.5.4 RECEPTORS
The primary receptor is the English Kills. Discharges to the English Kills are no longer visible and may
not be occurring. No investigation of the Kills or its sediments has taken place since the original
reporting of the contamination.
Workers would also be potential receptors if trenching or other subsurface activity is required. Though
not specifically identified from a well search, supply wells are present in the area, including one that is
advertised at a car wash along on Morgan Avenue. This well or other wells are not likely receptors
unless substantial dissolved contamination is present. Ground water sampling and analysis to date
suggest that dissolved hydrocarbon contamination is not a threat to these receptors; however, samples
have not been analyzed for chlorinated hydrocarbons.
1.5.5 DESCRIPTION OF GROUND WATER PLUME
Contaminants of concern include both free product and dissolved phase contamination. Figure 1-1
depicts the site monitoring wells and indicates those where free product has recently been observed.
Figure 1-2 depicts the extent of MTBE and BTEX (benzene, toluene, ethylbenzene, and xylene)
dissolved phase contamination. Although the extent of free product is smaller than it historically has
been, the remaining free product is generally No. 6 fuel oil, which has been difficult to remove through
either extraction or in-situ degradation.
Ground water samples have only been analyzed for hydrocarbons, including BTEX and MTBE.
Although concentrations are above State standards in some locations, they are generally within an order
of magnitude of the standards, with the exception of benzene in a limited area around FN-26. Although
chlorinate hydrocarbons where detected within some of the storage tanks in 1994 at the mg/L range,
ground water samples have not been analyzed for these constituents.
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2.0 SYSTEM DESCRIPTION
2.1 SYSTEM OVERVIEW
The remediation system became operational in June 1995, extracts ground water from select monitoring
wells, and treats the water prior to discharge to the sewer. Historically, extraction has been achieved
from 10 monitoring wells outfitted with ejector pumps that are powered by a 5 HP compressor. At the
time of the RSE site visit, only three of the pumps (FN-17, FN-28, and FN-30) were working, and the
total extraction flow rate was estimated to be about 1 gpm. FN-37 was also online but was not functional.
The total fluids (both free product and water) are pumped to the head of the treatment system and flow by
gravity through phase separation components before being pumped through GAC and then pumped to the
discharge point. The treatment system as a whole consists of the following components:
1,000 gallon oil/water separator tank
550 gallon oil collection tank with secondary containment
secondary 300 gallon separator
275-gallon influent tank with Teel 0.5 HP sump pump
55 gallon Carbtrol GAC vessel
275-gallon effluent tank with Teel 0.5 HP sump pump
The pumps are operated by level switches. Hi-hi switches are provided at the pumped tanks and the oil
collection tank to prevent spills by stopping the compressor if a hi-hi level is reached. System piping is
2-inch diameter Schedule 40 PVC. The GAC unit is located in a shed with the compressor. All other
components are outside and are insulated and heat traced.
Ground water extraction and treatment was augmented by vacuum enhanced fluid recovery (VEFR) that
was conducted by a mobile unit. VEFR was discontinued in 2002, due to low recovery.
2.2 MONITORING PROGRAM
The monitoring program has historically consisted of gauging wells on a bi-weekly basis, but has recently
been modified to gauging wells on a monthly basis and conducting quarterly sampling and analysis for
BTEX and MTBE at approximately 9 perimeter well (FN-7, FN-13, FN-19, FN-20, FN-21, FN-23, FN-
25, FN-29, and FN-46). For sampling, the wells are purged by low-flow pumps and the samples are
taken with bailers. Wells are not sampled if free product is observed. EPA Method 602 is used for
analysis. Although product thickness is measured, the measurements are not accurate because the No. 6
fuel oil coats the interface probe and prevents an accurate reading of the oil/water interface. Site status
reports are provided to NYSDEC on a semi-annual basis.
The treatment plant influent and effluent are not sampled and the extraction rate is not measured.
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3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE
CRITERIA
3.1
CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA
The remediation goals are not clearly stated in the reports, but NYSDEC stated during the site visit that
the goal is to eliminate measurable product. The presence of dissolved BTEX and MTBE contamination
also suggests that site goals include decreasing the ground water concentrations to below applicable
standards. The following table outlines the most stringent NYSDEC ground water standards for BTEX
and MTBE as well as the chlorinated hydrocarbons that were detected in the storage tanks in 1994. The
applicable standards for this site might be less stringent depending on the classification of ground water
and surface water in the area.
Contaminant
Benzene
Ethylbenzene
Toluene
Xylene (each isomer)
MTBE
Trichloroethene
Tetrachloroethene
1,1,1 -Trichloroethane
NYSDEC Standard
lug/L
5ug/L
5ug/L
5ug/L
lOug/L
5ug/L
5ug/L
5ug/L
3.2
TREATMENT PLANT OPERATION STANDARDS
NYSDEC representatives at the RSE site visit did not know if there is a permit to discharge treated water
to the sewer or where water in the sewer is discharged. Sampling of the effluent is not conducted.
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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 the EPA, NYSDEC, 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.
4.2 SUBSURFACE PERFORMANCE AND RESPONSE
4.2.1 PLUME CAPTURE
Although the original extraction system, comprised of 10 extraction wells, might have provided sufficient
extraction to provide a hydraulic barrier between the contamination and the English Kills, the current
system, comprised of 3 to 4 wells pumping approximately 1 gpm, likely does not. As stated by NYSDEC
and their contractors during the site visit, the system is operating to maximize product removal.
4.2.2 AQUIFER RESTORATION
Discharges to the English Kills are no longer observable. Although free product is present, it is relatively
immobile. This immobility prevents further discharge to surface water, but it also complicates extracting
it from the subsurface. The site team estimates that approximately 10 to 20 gallons of product were
removed during the past year of system operation. In addition, VEFR events conducted in 2002 generally
recovered little product, and additions of Biosolve did not prove effective. As a result, the VEFR events
have been discontinued. The following monitoring wells had observable free product between July and
October 2002: FN-1 la, FN-15a, FN-17a, FN-28a, FN-3 la, FN-32, FN-33a, FN-34. These wells are
indicated on Figure 1. The product thickness is not provided. Accurate measurements could not be
obtained because the oil coated the interface probe and prevented it from identifying the product/water
interface.
Dissolved BTEX and MTBE contamination exceed standards in few of the site wells. The following
table presents those monitoring wells where dissolved contamination exceeded standards in July 2002.
This dissolved contamination is also presented in Figure 1-2. The operating recovery wells are not in the
vicinity of the monitoring wells with elevated dissolved contaminant concentrations. Wells with free
product were not sampled but might have included dissolved contamination.
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Monitoring Well
State Standard
FN-2
FN-4
FN-20
FN-22
FN-23
FN-24
FN-26
FN-40
MTBE
(ug/L)
10
12
27
<1
4
20
19
94
51
Benzene
(ug/L)
1
85
15
<1
<1
<1
<1
130
<1
Toluene
(ug/L)
5
3
13
5
<1
<1
<1
5
<1
Ethylbenzene
(ug/L)
5
<1
10
15
2
<1
<1
1
<1
Xylene*
(ug/L)
5
<2
50
69
15
<2
<2
7
<2
* There are multiple isomersfor xylenes. The concentration for the isomer with the highest concentration is presented.
4.3
COMPONENT PERFORMANCE
4.3.1
EXTRACTION SYSTEM WELLS, PUMPS, AND HEADER
The majority of the ejector pumps are not operating because they are in need of repair. The pumps are
now obsolete and, as a result, the parts are hard to obtain. According to the site contractor, the timing
mechanisms are the most troublesome aspects. Parts have been used from some pumps to keep others
running.
The low well yield may partially be due to fouling of the well screens. Cleaning of the wells is planned
for the Summer of 2003.
4.3.2
SEPARATORS
The separators appear to be functioning as intended. Separated product from the primary separator is
discharged to a storage tank. The product in the secondary separator, however, must be removed
manually. During the RSE site visit there was thin layer of product in the bottom of the secondary
containment structure for the primary separator. The separators and the other tanks outside of the
maintenance shed are insulated and heat traced. Freezing has not been a problem.
4.3.3
GAC
The GAC is replaced approximately 3 times per year based on an increase in pressure to 10 psi or
greater. No sampling of the influent and effluent is conducted, so the performance of the GAC cannot be
determined.
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
the contractors, the RSE team estimates that O&M will cost approximately $22,000 in the upcoming
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years. This is a decrease in O&M cost from previous years primarily due to reductions in scope, such as
the elimination of the VEFR events and reduction of well gauging frequency from biweekly to monthly.
Item Description
System operation and maintenance
Semi-annual reporting
Sampling and well gauging
Electricity
GAC replacement
Laboratory analysis
Total Estimated Cost
Estimated Cost
per Year
$6,000
$2,400
$3,500
$3,300
$1,200
$5,200
$21,600
4.4.1
UTILITIES
The site utilities are primarily due to the compressor and process pumps. Electricity bills suggest that the
site uses, on average, 55 kWh per day at a cost of $0.16 per kWh. This translates to approximately
$3,200 per year. Service and miscellaneous charges of approximately $100 brings the total annual
electricity cost to approximately $3,300 per year.
4.4.2
NON-UTILITY CONSUMABLES AND DISPOSAL COSTS
GAC is the only consumable used at the site. Replacements occur approximately 3 times per year at a
cost of approximately $400, including GAC, labor, and disposal. There is apparently no cost for
discharging treated water to the sewer.
4.4.3
LABOR
Labor primarily consists of servicing the treatment system and ejector pumps, sampling, gauging, and
reporting. Project management is included in the costs, and a discount is provided to the State.
4.4.4
CHEMICAL ANALYSIS
Chemical analysis costs are estimated by the RSE team assuming approximately $100 per sample and 13
samples per quarterly event, including QA/QC samples.
4.5
RECURRING PROBLEMS OR ISSUES
The ejector pumps require frequent servicing and parts are difficult to obtain. Another recurring problem
is the inability to obtain an accurate product thickness measurement. When submerged into the free
product, the interface probe is coated with the No. 6 fuel oil and cannot detect the interface between the
product and the underlying water.
During the RSE site visit, one of the well vaults was flooded, allowing free product to rise to within an
inch of ground surface.
10
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The site also faces a security issue. The New York Police Department, in cooperation with NYSDEC,
conducts frequent raids to address vagrants, trespassers, and associated criminal acts.
4.6 REGULATORY COMPLIANCE
The site team is unaware of a discharge permit, and no effluent sampling is conducted. It is therefore
difficult to determine if the treatment system is in compliance.
4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL
CONTAMINANT/REAGENT RELEASES
The site team did not indicate any treatment process excursions or releases.
4.8 SAFETY RECORD
The site team did not indicate any reportable incidents.
11
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5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
HEALTH AND THE ENVIRONMENT
5.1 GROUND WATER
Under the current conceptual model, surface water is the only receptor of contaminated ground water.
However, there may be private water supply wells in the area. Because the No. 6 fuel oil is relatively
immobile, it does not pose an immediate threat to supply wells, if they are present. Dissolved
BTEX/MTBE contamination is present in relatively low concentrations and should not adversely affect
nearby potential receptors. Dissolved chlorinated compounds might be present in the subsurface but
have not been sampled in ground water as part of the site activities. If chlorinated compounds are present
in the ground water, they might be the most likely contaminants to impact nearby supply wells.
5.2 SURFACE WATER
Surface water was historically affected by discharges of fuel oil from ground water. Such discharges,
however, have not been visually observed since the site characterization and remedial activities began in
1994. Dissolved contamination might be discharging to surface water. Dissolved BTEX/MTBE is
present at low concentrations but above State standards. The remediation system likely does not provide
a hydraulic barrier between contamination sources and surface water. Dissolved contamination is not
expected to adversely impact surface water unless substantial chlorinated solvent contamination is
detected. The surface water quality has not been determined as part of the site activities, but if
contamination is detected in surface water it could result from other facilities.
5.3 AIR
Indoor air has not been considered a potential receptor at this site. Dissolved site-related hydrocarbons
are relatively limited in extent and sufficiently low in concentration that they are likely not adversely
affecting indoor air at any of the neighboring buildings. Chlorinated hydrocarbons, if present in
sufficient quantities, could adversely affect indoor air quality of surrounding buildings or of future
buildings on this site. Benzene in the vicinity of FN-26 could potentially adversely affect indoor air
quality if the concentrations do not decline and the property is developed without appropriate engineering
controls.
5.4 SOILS
The site is covered in either concrete or asphalt, and contaminated soils are not present at the surface.
Subsurface activities, such as trenching and construction, however, could expose workers to
contaminated soils.
12
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5.5 WETLANDS AND SEDIMENTS
There are no wetlands in the vicinity of the site. Sediments in the English Kills have not been sampled as
part of the site activities. If they are contaminated, the contamination is not necessarily due to the
Morgan Oil site given the presence of other industrial facilities in the area.
13
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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 DETERMINE IF CHLORINATED SOLVENTS AND PAHs ARE PRESENT IN GROUND
WATER
Analysis of liquid in Tank #5 and a vacuum truck on June 21, 1994 indicate elevated concentrations (e.g,
over 1 mg/L) of tetrachloroethene, trichloroethene, 1,1,1-trichloroethane, and trichlorofluoromethane.
Given the history of discharges from tanks at this facility, there is potential for these contaminants to be
present in ground water. In addition, some potentially hazardous polynuclear aromatic hydrocarbons
(PAHs) are typically associated with No. 6 fuel oil and may be present in the dissolved phase. There is
no indication in site records that chlorinated solvent or PAH contamination of ground water has been
investigated as part of site activities. These compounds should be added to the ground water monitoring
program for two quarters and should be included in the ground water monitoring program for longer if
they are detected in ground water above State standards. This recommendation could be implemented by
analyzing the samples from the next two events with method 8260b and 8270c instead of method 602.
The added cost should be less than $4,000 for the two events. If the current monitoring network does not
adequately delineate the plume of these newly analyzed constituents, then additional investigation may
be required.
6.1.2 IMPROVE THE SITE CONDITION BY DEMOLISHING STRUCTURES AND INVESTIGATING
AND/OR EXCAVATING UNDERLYING CONTAMINATED SOILS
The property is not maintained, is a safety hazard, and an attraction for vagrants and vandals.
Furthermore, although the property is in a promising location for potential businesses and could provide
the city with additional tax revenue, the site contamination and presence of the tanks and decrepit
infrastructure makes acquiring the property a substantial business risk.
In addition to improving the site aesthetically and improving the probability of development, removal of
the derelict equipment and structures will allow investigation and remediation of the site to proceed
unimpeded. The site tanks (including retaining/containment walls and mounded soil), structures, pipes,
and loading racks should be removed. The concrete and steel could be disposed in a C&D landfill or
recycled. Some cleaning would be necessary to remove oil staining. Based on a review of the site map,
the footprint of all structures on the property is as follows:
14
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Structure
3 loading docks
Terminal operations building
Maintenance building
Maintenance garage
Fuel storage tanks and containment (southern site
boundary)
Fuel storage tanks and containment (eastern site
boundary)
Dimensions*
20 ft x 75 ft (each)
75 ft x 40 ft
35 ft x 35 ft
40 ft x 75 ft
270 ft x 70 ft
140 ft x 100 ft
Miscellaneous (-10%)
Estimated total
Estimated
Footprint
1,500 ft2
3,000 ft2
1,225 ft2
3,000 ft2
18,900 ft2
14,000 ft2
4,000 ft2
45,625 ft2
* Building dimensions are estimated based on site map provided in Figure 1.
After demolition, the site team could evaluate the need for further investigation and remediation in areas
where structures have been removed. Potential options for addressing contamination in those areas might
include the following:
Option 1 - The site team could investigate, delineate, and document contamination. Even if
contamination is not removed, delineating it reduces risk to potential buyers because they can
better quantify the cost of remediation and compare that cost with the value of the property.
Option 2 - The site team could remove visible contamination (e.g., within one foot of the surface)
and replace removed material with clean material to prevent direct exposure. This level of
remediation could serve as a temporary solution that prevents direct exposure to contamination.
Further remediation could occur, if necessary, during future site development.
Option 3 - The site team could excavate contaminated soils with extensive free product to the
water table (a depth of approximately 5 feet) and replace excavated material with clean material.
No further excavation would likely be necessary. Although contamination would likely remain
below the water table, it would be best addressed through long-term remedial activities.
Excavated soils could be recycled for asphalt, brick, or other construction material, or at worst, placed in
a Subtitle D landfill. For the most part, the material on this site is likely non-hazardous. Petroleum
products are not listed hazardous waste, this site is not a Superfund or RCRA site, benzene levels are not
high enough to even consider the waste to be characteristically hazardous, and even if they were, the
petroleum exemption to RCRA (40CFR 280) would keep the material non-hazardous. The only
constituents that may be an issue are the chlorinated hydrocarbons that were detected in some of the tank
samples. Prior to excavation, and certainly prior to disposal, soil samples should be collected to
determine the extent chlorinated solvent contamination of soils. This sampling is especially merited if
chlorinated solvents are found during ground water sampling events.
The estimated cost for removing the structures and the above presented options are provided in the
following table. The NYSDEC would need to evaluate the cost of each item against available resources
and the improved likelihood of selling the property. Without further information regarding the site and
potential buyers, the RSE team would likely recommend pursuing the demolition followed by Option 1
and/or Option 2, depending on what is found at the surface when the structures are removed.
15
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Item
Demolition of site structures (i.e., tanks,
buildings, pipes, loading docks, etc.)
Option 1 - Investigate, delineate, and document
contamination beneath removed structures
work plan, etc.
3 days of direct push sampling
installation of up to 4 monitoring wells
2 rounds of sampling and analysis at new wells
documentation in a comprehensive report
Option 2 - Excavation of contaminated soil
beneath tanks, including transportation and non-
hazardous disposal (270 ft x 70 ft and 140 ft x
100 ft containment areas to a depth of 1 foot)
Option 3 - Excavation of soil with extensive
contamination to water table (270 ft x 70 ft and
140 ft x 100 ft containment areas to a depth of 5
feet plus an additional 500 cubic yards of
miscellaneous soils)
Quantity
50,000 ft2 of structures at
an average height of 15 ft
1,200 cubic yards
(-1,800 tons)
6,600 cubic yards
(-9,900 tons)
Unit Cost
$0.42/cf *
$75/ton
$75/ton
Estimated
Cost**
$430,000
$85,000
$185,000
$1,000,000
* Architects, Contractors, Engineers 2003 Guide to Construction Costs
** Cost includes a 10% markup for oversight plus an additional 2 5% for contingency
6.1.3
DEVELOP A REVISED SITE CONCEPTUAL MODEL AND SET MEASURABLE OBJECTIVES
Site conditions will be substantially altered during tank removal and soil excavation. Site changes will
likely include the destruction of some monitoring wells, removal of source material, and changes in
infiltration and ground water flow patterns. A site conceptual model should be developed after the tanks
are removed. Visual observations made during the excavation should add to the understanding of the
site. Also, up to 4 to 5 additional monitoring wells in former tank locations may be needed to improve
the current understanding of the site after demolition. Ground water monitoring should continue for at
least four quarters after the excavation to determine water level and contaminant trends after the
excavation. These trends could be the basis for determining the need for future active remediation or the
potential for a more passive approach.
Potential receptors in the area and exposure pathways for those receptors should also be reevaluated
given the understanding of new site conditions and data on chlorinated solvents and PAHs in ground
water. Potential receptors include the English Kills, water supply wells in the area (if any), and indoor
air in nearby buildings. Ground water sampling results to date do not suggest a substantial threat to
supply wells or indoor air, but if chlorinated compounds are found in ground water, the pathway to all
receptors should likely be evaluated.
To date, the objective has been to prevent discharge of free product to the English Kills. The discharge
of free product to surface water has not been observed for a number of years. Although removal of the
product is preferable, it may be technically impracticable without excavation well below the water table.
Given the relatively low toxicity of No. 6 fuel oil, a containment-only objective for free product may be
more appropriate, and that containment is already provided by its immobility.
16
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The addition of the wells, the development of the site conceptual model, and the determination of
applicable remediation objectives will likely require approximately $30,000. This cost estimate does not
include a full evaluation of indoor air because not enough information is available at this time to
determine the scope of an appropriate evaluation or even if one is needed.
6.1.4 OBTAIN A DISCHARGE AGREEMENT AND COLLECT EFFLUENT SAMPLES
The site should have an appropriate discharge permit or agreement and discharge samples should be
collected and analyzed for the applicable constituents. Currently treated water is discharged to the local
sewer that is likely a combined sewer that routes water to a POTW under most circumstances. An
agreement should be in place and in the DEC and contractor's possession so that appropriate sampling
(i.e. quarterly TPH, BTEX, MTBE, and potentially chlorinated solvents) can be conducted and reported.
It is estimated that the increase in costs due to sampling and reporting might be $3,000 per year.
6.2 RECOMMENDATIONS TO REDUCE COSTS
The RSE team does not provide any specific cost reduction recommendations but does agree with the
recent elimination of the VEFR events and the reduction in well gauging from biweekly to monthly.
After another four quarters of ground water sampling, the RSE team advocates evaluating the potential
for reducing the sampling frequency from quarterly to semi-annually. After these four additional
quarters sufficient information should be available to determine concentration trends for both
hydrocarbons and chlorinated hydrocarbons, if they are present.
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT
6.3.1 IMPROVE REPORTS
The semi-annual reports are the primary mechanism for documenting site activities and performance and
should be improved. Suggested improvements include eliminating or reducing errors and including
information about ground water extracted and treated (i.e., flow rates and process sampling data
discussed in Section 6.1.4). Errors identified by the RSE team in the July 2002 - November 2002 Site
Status Monitoring Report include the following:
Tables 1 and 2 have the incorrect site name, dates, and data.
The figures are not numbered.
The MTBE and BTEX plume maps do not accurately represent the concentrations.
The ground water flow map shows depth to water data rather than water level elevations.
The RSE team recommends the use of bubble maps to indicate constituent concentrations. Because no
interpolation is used, bubble maps provide the data rather than interpretations of the data. They are
therefore easier to review and compare to data tables and are less prone to potential errors,
inconsistencies, or potentially faulty interpretations. The bubble map might include a different symbol
for those wells with free product or dissolved contamination, and may use a symbol that is increased or
decreased in size depending on the product thickness or dissolved concentration. In order to convert
water depths to water elevations, survey information is required. These are likely available in the old
Fenley & Nicol reports where water elevations were calculated and plotted.
17
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The RSE team estimates that about $2,000 per year, in addition to the current expenditures, should be
sufficient to improve the semiannual reports.
6.3.2 CONSIDER REMOVING THE GAC EFFLUENT TANK
The GAC effluent tank could be eliminated, allowing discharge directly from the GAC unit. This would
eliminate a 0.5 hp pump and the heat trace requirements for the tank. Removing this tank and pump will
save about $500 per year in utility costs and simplify future system maintenance.
6.3.3 REPAIR INSULATION OR RELOCATE TREATMENT COMPONENTS
If the current treatment system is still used after implementing the recommendations in Section 6.1, the
insulation on the treatment components should be repaired or the components should be located within a
shelter. A flow meter should be added so that discharge flow can be recorded. About $2,000 is necessary
for the flow meter plus insulation repair. If another shed is purchased to house additional components
the cost will likely increase by another $3,000.
6.4 CONSIDERATIONS FOR GAINING SITE CLOSE OUT
6.4.1 CONSIDER AN ALTERNATIVE REMEDIAL APPROACH
Given its current function and the current objectives, the remediation system does not appear to be
effective with respect to ground water remediation. The system most likely does not extract enough
water to provide capture of free product or dissolved contamination and yet, due to the relative
immobility of No. 6 fuel oil, no discharges of free product to surface water have occurred. In addition,
little product is recovered (e.g., less than 20 gallons per year) even with the introduction of Biosolve and
VEFR events. Therefore, the system is not effective for containment or restoration and does not appear
necessary for containment of the free product.
Steam injection was mentioned during the site visit as a possible method for removing additional product.
Although it may be successful in removal of localized product, implementation of a full scale system
would be extremely expensive and has a relatively high probability of being unsuccessful site wide. The
peat layer at 12 feet below ground surface impedes any chemical oxidation and aerobic bioremediation
possibilities.
The only active remediation that would have a good chance of removing a substantial percentage of the
petroleum mass at the site is excavation to below the water table. Boring logs indicate impacts to at least
20 feet below ground surface and impacts are likely present over most of the site (approximately 2 acres).
The volume of soil requiring removal would be approximately 50,000 cubic yards or more, and a
significant dewatering effort would be required during excavation. The cost of this effort would be
above $3,000,000 beyond the cost of the recommendations in Section 6.1. Excavation does not appear to
be warranted at the site due to the apparent lack of exposure pathways and the relatively low toxicity of
the fuel oil.
Assuming chlorinated solvent contamination is not found in ground water, the site team should consider
passive skimming and periodic bailing of product from wells and institutional controls for long-term
remediation. The ground water monitoring frequency could be reduced to annual in order to monitor the
remaining dissolved MTBE/BTEX contamination. If benzene concentrations persist at FN-26, quarterly
VEFR events at FN-26, FN-2, and FN-4 could be conducted for one year to decrease the concentrations.
18
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The cost of implementing this approach is minimal compared to the costs of removing the tanks and
excavating soil. The reduced scope for annual activities would eliminate the costs for system operation,
electricity, and GAC replacement ($10,500 per year). In addition, it would reduce the sampling and
analysis costs by approximately $5,000 per year. Total annual expenses might be under $10,000 per year.
If dissolved ground water concentrations (e.g., chlorinated solvents) are sufficiently high to merit
containment, the extraction system should be reworked to provide ample extraction. New extraction
wells would likely be required, and the pumps should be replaced with currently available pneumatic
submersible total fluids pumps. The monitoring program should also be adapted to evaluate the
performance of plume capture. The specific modifications would require more information regarding the
extent and magnitude of the dissolved constituents of concern, especially for the chlorinated solvents.
6.5 SUGGESTED APPROACH TO IMPLEMENTATION
The first priority should be to sample ground water for chlorinated solvents because many of the other
decisions at the site require knowledge as to whether or not these constituents are present and the
magnitude and extent of any contamination. Off-site investigation may be necessary if significant
chlorinated solvent contamination is found.
The site structures and tanks should be removed as soon as possible. In addition, as described in Section
6.1.2, varying degrees of investigation and/or remediation could also be considered to facilitate sale of
the property. A variety of site development options would be possible. Vapor toxicity is low and
potential vapor intrusion could be addressed by design/construction methods. Businesses would likely be
interested in the property due to its location, which would provide tax revenue to the city and potentially
provide jobs in the neighborhood. With the greater potential for site development, the State and City
would be more inclined to resolve the ownership/liens and outstanding tax issues. Eventually some of
the costs spent in remediation would be recouped by the State and/or City. Moreover, the safety hazards
and attractions to vagrants would be eliminated.
Other recommendations including the discharge agreement, removal of the GAC effluent tank, insulation
repair, flow meter installation, report improvements and consideration of passive skimming/periodic
bailing instead of total fluids pumping can be initiated concurrently with the site demolition or can be
delayed until the post-demolition site conceptual model is developed.
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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 for improving effectiveness in protecting human health and the environment include
analyzing ground water samples for chlorinated solvents and PAHs, demolishing the site structures,
investigating and/or excavating contaminated soils beneath those structures, revising the site conceptual
model to account for the site conditions after the demolition and excavation, and obtaining a permit or
agreement to discharge the treated water. No specific recommendations were offered for cost reduction;
however, the RSE team does agree with the recent elimination of the VEFR events and reduction in well
gauging frequency. Recommendations for technical improvement include improving the semi-annual
reports and removing the GAC effluent tank from the treatment system. One recommendation for
gaining site closeout, or more specially system closeout, is provided. It is to consider an alternative
remedial approach based on institutional controls and passive skimming of free product. The rationale
for this approach is the immobility and relatively low toxicity of the No. 6 fuel, the absence office
product discharges to surface water, and the high cost of removing the remaining free product and
impacts that reach below the water table. The success of implementing this type of approach, however, is
contingent on finding chlorinated solvent and PAH concentrations below standards.
Table 7-1 summarizes the costs and cost savings associated with each recommendation in Sections 6.1
through 6.3. Both capital and annual costs are presented. Also presented is the expected change in life-
cycle costs over a 30-year period for each recommendation both with discounting (i.e., net present value)
and without it.
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Table 7-1. Cost Summary Table
Recommendation
6.1.1 Determine If
Chlorinated Solvents and
PAHs Are Present in Ground
Water
6.1.2 Improve The Site
Condition By Demolishing
Structures and Investigating
and/or Excavating Underlying
Contaminated Soils
6. 1.3 Develop A Revised Site
Conceptual Model and Set
Measurable Objectives
6. 1.4 Obtain A Discharge
Agreement and Collect
Effluent Samples
6.3.1 Improve Reports
6.3.2 Consider Removing The
GAC Effluent Tank
6.3.3 Repair Insulation or
Relocate Treatment
Components
6.4.1 Consider an Alternative
Remedial Approach
Reason
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Technical
Improvement
Technical
Improvement
Technical
Improvement
Gain
Site/System
Closeout
Additional
Capital
Costs
($)
$4,000
$515,000
to
$1,430,0003
$30,000
$0
$0
$0
$2,000
$0
Estimated
Change in
Annual
Costs
($/yr)
$0
$0
$0
$3,000
$2,000
($500)
$0
($15,500)
Estimated
Change
In Life-cycle
Costs
(S)1
$4,000
$515,000
to
$1,430,0003
$30,000
$90,000
$60,000
($15,000)
$2,000
($465,000)
Estimated
Change
In Life-cycle
Costs
($)2
$4,000
$515,000
to
$1,430,0003
$30,000
$48,500
$32,000
($8,000)
$2,000
($250,000)
Costs in parentheses imply cost reductions.
1 assumes 30 years of operation with a discount rate of 0% (i.e., no discounting)
2 assumes 30 years of operation with a discount rate of 5% and no discounting in the first year
3 Implementing any of the options in this recommendation could improve the potential for redevelopment that would
provide increased tax revenues and other benefits.
21
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FIGURES
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FIGURE 1-1. SITE MAP AND OBSERVED EXTENT OF FREE PRODUCT IN 2002.
:u v / ANI\
I S Cn'lf MAINTENANCE
_ğ ' '-=>ağ l-N-1 /,
PROPERTY LINE (APPROX.)
WELL WITH FREE PRODUCT
a WELL WITH EJECTOR: PUMP
D FORMER EJECTOR WELL
Ğ MONITOR WELL WITHOUT FREE PRODUCT OR EJECTOR PUMP
(Note: This figure was generated based on site figures developed by Miller Environmental Group, Inc. and discussions during the RSE site visit.)
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FIGURE 1-2. EXTENT OF DISSOLVED CONTAMINATION ABOVE THE MOST STRINGENT STATE STANDARDS AS OBSERVED IN JULY 2002.
WELL 1WITH EJECTOR PUMP
D FORMER EJECTOR WELL
* MONITOR WELL WITHOUT FREE PRODUCT OR EJECTOR PUMP
(Note: This figure was generated based on site figures developed by Miller Environmental Group, Inc. and discussions during the RSE site visit.)
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