REMEDIATION SYSTEM EVALUATION
SMS INSTRUMENTS
DEER PARK, NEW YORK:
Report of the Remediation System Evaluation,
Site Visit Conducted at the SMS Instruments Superfund Site
July 16, 2003
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Office of Solid Waste EPA 542-R-03-015
and Emergency Response December 2003
(5102G) www.epa.gov/tio
clu-in.org/optimization
Remediation System Evaluation
SMS Instruments
Deer Park, New York
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NOTICE
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 Dynamac Corporation Prime Contract No. 68-C-02-092, Work Service Request Nos.
ST-1-20 and ST-1-15. Mention of trade names or commercial products does not constitute endorsement
or recommendation for use.
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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:
ซ 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.
The SMS Instruments Superfund Site is located at 120 Marcus Boulevard in Deer Park, Suffolk County,
New York. The site consists of a 34,000 square foot building located on a 1.5-acre lot that is surrounded
by other light industrial facilities. A recharge basin is located adjacent to the property to the east. Facility
operations occurred between 1967 and 1990 and primarily involved overhauling of military aircraft
components. These activities consisted of cleaning, painting, degreasing, refurbishing, metal machining,
and testing components. The current uses, under different ownership, include the manufacturing of
wooden kitchen utensils. Site contamination was first discovered in 1980 when the Suffolk County
Department of Health Services sampled a leaching pool on the south side of the facility. Investigative and
remedial activities have included pumping out the leaching pond and backfilling it, removal of an
underground storage tank, and operation of a soil vapor extraction system. A P&T system was
constructed and began operation in 1994. This RSE report pertains to that P&T system and other site
conditions that directly affect the performance of this system.
The RSE team observed a site where the soil remedy had effectively removed soil contamination, which
had been providing a continuing source of dissolved ground water contamination. Ground water
concentrations have decreased substantially, indicating the initial success of the remedies. The ground
water remedy has continued to extract and treat contaminated ground water in an attempt to achieve its
remediation objectives, but the system has failed to meet its discharge criteria on multiple occasions and
the annual costs of operation are significantly more than the RSE team would expect for this site. 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.
The RSE team suggests the following recommendation to improve system effectiveness:
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The data analysis and reporting should be improved. Current reports include little or no data
analysis, no figures, no water level data, and no information about the treatment system. In
addition, the reports reviewed by the RSE team were submitted seven months to one year after
the associated sampling event. The reports should be improved to include these items and should
be submitted in a timely manner. These improvements are particularly important given that plume
capture has not been evaluated since a new extraction well became operational in 1998 and given
that the treatment system has had two recent exceedances of the discharge standards.
The RSE team suggests the following recommendations for cost reduction:
Over 80% of the O&M costs are devoted to labor. Approximately $130,000 per year is used to
fund a full time plant operator, and approximately $150,000 per year is used to fund project
management, technical support, and reporting. The amount of labor (and therefore the labor
cost) can and should be reduced without sacrificing the system effectiveness. The system is
automated and does not require a full time operator, and the project management, technical
support, and reporting should not exceed $110,000 for this site. The RSE team suggests that
approximately $113,000 per year can be saved by reducing labor without sacrificing system
effectiveness.
The monitoring program can be optimized by both reducing the sampling frequency at a number
of wells and discontinuing the analysis for SVOCs and metals from the ground water samples.
Reductions in laboratory analysis will not result in cost savings because the analyses are
conducted through the Contract Laboratory Program, but approximately $9,000 can be saved
from the reductions in sampling labor.
Because the influent concentrations are orders of magnitude lower than the design influent
concentrations, it may be possible to reduce the frequency of vapor phase GAC replacements.
The RSE team encourages the site team to evaluate the influent and effluent to the GAC units
and determine if the replacement frequency can be reduced without sacrificing effectiveness. A
cost savings of $3,000 to $5,000 might result if the frequency can be reduced.
No recommendations are provided in the technical improvement category. Rather, the RSE team
suggests that emphasis be placed on the effectiveness and cost reduction recommendations. One
recommendation is provided with regard to site closeout. The RSE team recommends developing an exit
strategy and provides three potential approaches. The risks that the ROD highlighted as the reason for
active remediation are no longer present at the site. Therefore, two of the approaches provided include
discontinuing the P&T system and monitoring for potential plume migration. In addition to the above
recommendations, the RSE team provides options for the site team to consider if the system is expected
to continue for a number of years and maintenance becomes a problem.
A table summarizing the recommendations, including estimated costs and/or savings associated with those
recommendations, is presented in Section 7.0 of this report.
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PREFACE
This report was prepared as part of a project conducted by the United States Environmental Protection
Agency (USEPA) Office of Superfund Remediation and Technology Innovation (OSRTI). The objective
of this project is to conduct Remediation System Evaluations (RSEs) at selected pump and treat (P&T)
systems that are jointly funded by EPA and the associated State agency. The project contacts are as
follows:
Organization
USEPA Office of Superfund
Remediation and Technology
Innovation
(OSRTI)
GeoTrans, Inc.
(Contractor to USEPA)
Key Contact
Jennifer Griesert
Doug Sutton
Contact Information
1200 Pennsylvania Avenue, NW
Mail Code 520 1G
Washington, DC 20460
phone: 703-603-8888
griesert.jennifer@epa.gov
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
(732) 409-0344
Fax: (732) 409-3020
dsutton@geotransinc.com
111
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TABLE OF CONTENTS
EXECUTIVE SUMMARY i
PREFACE iii
TABLE OF CONTENTS iv
1.0 INTRODUCTION 1
1.1 PURPOSE 1
1.2 TEAM COMPOSITION 1
1.3 DOCUMENTS REVIEWED 2
1.4 PERSONS CONTACTED 2
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS 3
1.5.1 LOCATION 3
1.5.2 POTENTIAL SOURCES 4
1.5.3 HYDROGEOLOGIC SETTING 4
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 EXTRACTION SYSTEM AND INJECTION SYSTEM 6
2.3 TREATMENT SYSTEM 7
2.4 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 WATER LEVELS 10
4.2.2 CAPTURE ZONES 10
4.2.3 CONTAMINANT LEVELS 11
4.3 COMPONENT PERFORMANCE 13
4.3.1 EXTRACTION SYSTEM WELLS, PUMPS, AND HEADER 13
4.3.2 EQUALIZATION/INFLUENT TANK 13
4.3.3 AIR STRIPPER 13
4.3.4 GAC 13
4.3.5 GYLCOL HEATING UNIT 13
4.3.6 SYSTEM CONTROLS 13
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF O&M COSTS 14
4.4.1 UTILITIES 14
4.4.2 NON-UTILITY CONSUMABLES 15
4.4.3 LABOR 15
4.4.4 CHEMICAL ANALYSIS 15
4.5 RECURRING PROBLEMS OR ISSUES 16
4.6 REGULATORY COMPLIANCE 16
iv
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4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL CONTAMINANT/REAGENT RELEASES
16
4.8 SAFETY RECORD 16
5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT 17
5.1 GROUND WATER 17
5.2 SURFACE WATER 17
5.3 AIR 18
5.4 SOILS 18
5.5 WETLANDS AND SEDIMENTS 18
6.0 RECOMMENDATIONS 19
6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS 19
6.1.1 IMPROVE REPORTING AND DATA ANALYSIS (INCLUDING EVALUATING PLUME CAPTURE) .... 19
6.2 RECOMMENDATIONS TO REDUCE COSTS 20
6.2.1 REDUCE OPERATOR AND PROJECT MANAGEMENT/TECHNICAL SUPPORT/REPORTING LABOR
20
6.2.2 OPTIMIZE MONITORING PROGRAM 21
6.2.3 CONSIDER DECREASING THE FREQUENCY OF VAPOR PHASE GAC REPLACEMENTS 21
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT 22
6.4 CONSIDERATIONS FOR GAINING SITE CLOSE OUT 22
6.4.1 DEVELOP AND EXIT STRATEGY 22
6.4.2 CONSIDERATIONS IF P&T is REQUIRED FOR A NUMBER YEARS AND MAINTENANCE is AN
INCREASING CONCERN 23
6.5 SUGGESTED APPROACH TO IMPLEMENTATION 25
7.0 SUMMARY 26
List of Tables
Table 7-1. Cost summary table
List of Figures
Figure 1-1. Site Location Map
Figure 1-2. The Former SMS Instruments Facility, Surrounding Area, and Well Locations.
Figure 4-1. VOC Concentration Trend in MW-6S
Figure 4-2. The Extent of Site-Related and Non-Site Related Contamination.
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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 has incorporated RSEs into a larger post-construction complete strategy for Fund-
lead remedies. During fiscal year 2003, RSEs at up to 6 Fund-lead sites are planned in an effort to
improve or optimize the sites. GeoTrans, Inc., an EPA contractor, is conducting these evaluations, and
representatives from EPA OSRTI 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.army.mil/library/guide/rsechk/rsechk.html
An 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 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.
The SMS Instruments site was selected by EPA OSRTI based on a recommendation from EPA Region 2
and the annual costs of operating the remedy. 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.
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.
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The RSE team was also accompanied by the following observers:
Jennifer Griesert from EPA OSRTI
Matthew Charsky from EPA OSRTI
1.3
DOCUMENTS REVIEWED
Author
US EPA
COM
US EPA
Advanced Environmental
US EPA
COM
COM
COM
Date
9/29/1989
7/7/1993
3/1995
12/1995
5/31/2001
3/25/2003
10/23/2003
7/2003
Title
Record of Decision, OU1
Various figures from the Remedial
Investigation/Feasibility Study
Cost and Performance Report, Soil Vapor
Extraction at the SMS Instruments Superfund Site
(Excerpt from Remediation Case Studies: Soil
Vapor Extraction)
Operation and Maintenance Groundwater
Treatment Facility, Volume I, Main Text
Superfund Five-Year Review Report, SMS
Instruments
Data Summary Report, Quarterly Sampling,
December 2001 and April 2002, SMS Instruments
Remedial Action
Data Summary Report, Quarterly Sampling,
December 2002 and March 2003, SMS Instruments
Remedial Action
Excel Spreadsheet of Sampling Data (updated
through April 2002)
1.4
PERSONS CONTACTED
The following individuals associated with the site were present for the visit:
Mark Dannenberg, RPM, EPA Region 2
Rob Alvey, Hydrogeologist, EPA Region 2
John Malleck, EPA Region 2
Gerald J. Rider, Jr., New York State Department of Environmental Conservation
Carl R. Hoffman, New York State Department of Environmental Conservation
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Paul Hagerman, Project Manager, CDM
Kenneth F. Roberts, Plant Operator, CDM
Demetrios Klerides, Principal Engineer, CDM
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS
1.5.1 LOCATION
The SMS Instruments Superfund Site is located at 120 Marcus Boulevard in Deer Park, Suffolk County,
New York. The site consists of a 34,000 square foot building located on a 1.5-acre lot that is surrounded
by other light industrial facilities, and a recharge basin is located adjacent to the property to the east.
Facility operations occurred between 1967 and 1990 and primarily involved overhauling of military aircraft
components. These activities consisted of cleaning, painting, degreasing, refurbishing, metal machining,
and testing components. The current uses, under different ownership, include the manufacturing of
wooden kitchen utensils. The location of the facility and the surrounding area are depicted in Figure 1-1.
The site plan, including monitoring well locations and source areas, is depicted in Figure 1-2.
Site contamination was first discovered in 1980 when the Suffolk County Department of Health Services
sampled a leaching pool on the south side of the facility. This leaching pool was pumped out and
backfilled with sand in 1983. Other investigative and remedial activities conducted at the site include the
following:
1986 - The EPA included the site on the National Priorities List.
1987-89 - The EPA performed a Remedial Investigation/Feasibility Study (RI/FS) at the site and
detected organic and inorganic contamination of soils and ground water.
1988 - An underground storage (UST) tank located to the east of the facility building was
removed from the site.
1989 - A Record of Decision (ROD) was issued for the site. The ROD identified soil vapor
extraction (SVE) and P&T as remedies for site-related soil and ground water
contamination. It also indicated that a second operable unit (OU-2) would be established
to address potential upgradient sources.
1992-94 - An SVE system was operated near the former leaching pond and UST tank areas to
remediate soils. Cleanup criteria were met and demobilization occurred in March 1994.
1993 - No upgradient sources were identified, and the ROD for OU-2 specified "no-action".
1994 - Construction of the P&T system was completed, and the system began operating.
1995 - The Removal Action Branch of EPA completed the removal of approximately 50 drums
from a drum storage shed located on the north-east portion of the site.
This RSE report pertains to the operating P&T system and other site conditions that directly affect the
performance of this system.
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1.5.2 POTENTIAL SOURCES
The site had three main contaminant source areas:
the leaching pool that was closed in 1983
the UST tank that was excavated in 1988
the drum storage area where the drums were removed in 1995
Approximately 1,250 cubic yards of soil in the former locations of the leaching pond and UST were
treated with SVE from April 1992 to November 1993. Of 14 confirmation samples collected in
November 1993, only two exceeded the standards and in each of these two samples, the exceedance
pertained to only one constituent. Therefore, it was determined that the remedy achieved its goal and
treatment with the SVE system could be discontinued. No soil remediation was conducted near the drum
storage area.
Given that soil has been effectively cleaned to standards and that non-aqueous phase liquid (NAPL) has
not been identified at the site, it is likely that there are no continuing sources of dissolved ground water
contamination. Ground water sampling data (discussed in the following sections) further confirm that
continuing sources are likely not present.
1.5.3 HYDROGEOLOGIC SETTING
The site overlies a recharge zone for the Magothy aquifer, a sole-source aquifer for Long Island. The
depth to water is approximately 16 to 24 feet, and the hydraulic conductivity (as determined by a slug test
conducted during the Remedial Investigation) was estimated at approximately 268 feet per day. Water
levels suggest a hydraulic gradient for the site of approximately 0.001 feet per foot directing ground water
flow to the south east. This gradient, the hydraulic conductivity provided above, and an assumed porosity
of approximately 0.3 suggests a ground water velocity of approximately foot per day to the southeast.
More updated information was not available for review. The majority of the site and the surrounding area
are covered by asphalt, concrete, or buildings. Therefore, recharge to the aquifer within the property
boundary is fairly limited.
1.5.4 RECEPTORS
The primary potential receptors are water supply wells. The closest downgradient supply well is located
approximately 1 mile south of the site along Brook Avenue and is over 300 feet deep. As of the time of
the RSE site visit, the site team was unaware of any impacts to that well from site-related contamination.
The closest downgradient surface water body is Guggenheim Lake, which is located approximately 1.5
miles south of the site.
1.5.5 DESCRIPTION OF GROUND WATER PLUME
In April 2002, the following wells had contamination that exceeded the cleanup criteria. More recent data
were not available at the time of the RSE.
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Well
MW-6S
MW-15
EW-1
EW-3
Contaminant Exceeding
Standard
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
Chlorobenzene
Ethylbenzene
n-Propylbenzene
Xylenes
sec-Butylbenzene
1 , 1 -Dichloroethane
1 ,2-Dichlorobenzene
Chlorobenzene
Chlorobenzene
April 2002
Concentration (ug/L)
90
13
8.4
13
28
12
6.2
20
4.9
39
39
Cleanup Standard
(ug/L)
5
5
5
5
5
5
5
5
4.7
5
5
Figure 1-2 presents the locations of these wells and shows that MW-6S and EW-3 are located adjacent to
each other in the area of the former leaching pond. No monitoring points are located between this area
and EW-1, but given the continued contamination at EW-1, it is likely that this intermediate area has
contamination above cleanup standards.
Contamination is generally limited to less than 70 feet below ground surface. MW-6D is installed to a
depth of 102 feet, is screened from 87 to 97 feet below ground surface, and has no contamination above
cleanup standards. Similarly, site-related contamination has not been found at MW-16D or MW-13D.
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2.0 SYSTEM DESCRIPTION
2.1
SYSTEM OVERVIEW
The original system design included extraction from two downgradient wells (EW-1 and EW-2) at a
combined rate of 500 gpm. Ground water was to be treated and then reinjected through reinjection wells
upgradient of the site. The actual system, however, was constructed to extract ground water from one
well (EW-1) at 90 gpm. Due to repeated fouling, the reinjection wells were taken offline in 1996, and
treated ground water was discharged to the adjacent recharge basin. The current system includes
extraction of 90 gpm evenly divided between EW-1 and EW-3, a new well installed in the 1998 near the
source area at a depth of 40 feet.
The following table summarizes the contaminant concentrations in the plant influent for 2001. For all
compounds detected above cleanup standards in the influent, the maximum 2001 concentration and
effluent standards are provided.
Parameter
1 ,2-Dichlorobenzene
1 ,4-Dichlorobenzene
Chlorobenzene
P-xylene and m-xylene
O-xylene
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
Ethylbenzene
Total
Maximum 2001 Influent
Concentration
(ug/L)
24.0
15.0
110
130
12
24
7.7
27
349.7
Effluent Standard
(ug/L)
4.7*
5.0
5.0
5.0
5.0
5.0
5.0
NA
* the standard of 4.7 ug/l is for the sum of these compounds
Given this influent concentration and an extraction rate of 90 gpm, the mass loading to the treatment
system is under 0.40 pounds of VOCs per day. The average concentration is much lower and a mass
loading is likely closer to 0.2 pounds of VOCs per day.
2.2
EXTRACTION SYSTEM AND INJECTION SYSTEM
The current extraction system includes EW-1 downgradient of the site and EW-3 in the area of the
former leaching pond. EW-2 was drilled, but never converted to an extraction well. EW-1 is
approximately 70 feet deep, and EW-3 is approximately 40 feet deep. Each well is outfitted with a 5 HP
pump that reportedly extracts approximately 45 gpm for an estimated total of 90 gpm between the two
wells. EW-1 has heat tracing and conductivity high and low probes to control extraction, but the well
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operates continuously. To minimize the capital costs of installation, EW-3 was installed without heat
tracing or conductivity probes. EW-3 was piped to the original line extending from EW-1 to the treatment
plant. All piping is 4-inch HDPE.
2.3 TREATMENT SYSTEM
The treatment system consists of the following components:
7,300 gallon influent tank with a 7.5HP effluent pump (plus a parallel redundant pump)
chemical metering pump
flow meter (currently bypassed to eliminate frequent cleaning)
50-foot tall packed tower with a 5 HP blower designed to provide 665 cfm of air (plus a
redundant blower that is currently out of service)
1,000 gallon effluent tank (currently out of service)
12.3 kW glycol heat exchanger, 1.5 HP glycol pump, and dehumidifier
four 2,000 pound vapor GAC units arranged in two parallel trains each with two units in series
a 55 gallon GAC vessel to treat the vapors in the head space above the influent tank
All units except for the chemical metering and heat exchanger are located outside, insulated, and heat
traced. Extracted water flows into the influent tank, and pumping from the influent tank to the air stripper
is regulated by a recycle valve. The tank is sealed and emissions are vented through the 55-gallon GAC
vessel. About one drum of sludge is drained from the tank each year. Approximately 2.5 gallons per day
of a polyphosphate sequestering agent (AquaMag) is dosed into the water prior to the air stripper.
Process water then enters the air stripper to remove VOCs and is then discharged by gravity to the
adjacent recharge basin. Off gas from the air stripper is dehumidified and then routed through the GAC
vessels to remove the VOCs.
2.4 MONITORING PROGRAM
All 20 site monitoring wells, the two extraction wells, and system influent and effluent are sampled
quarterly (about 100 samples per year total excluding QA/QC samples) and analyzed for VOCs, SVOCs
and metals. The resulting data are presented in a quarterly monitoring report, but little analysis and no
figures are provided. Depths to water are measured during the sampling events, but the measurements
are not converted to water levels, used to develop potentiometric surface maps, or presented in the
quarterly reports.
Ground water samples are collected by purging the well of three volumes and collecting a sample with a
peristaltic pump. The purge water is emptied into the treatment plant influent tank and is treated by the
system. EW-1 can be sampled with a sampling port. EW-3 is sampled by shutting down EW-1 and
collecting a sample at the treatment plant. All laboratory analyses are conducted through the Contract
Laboratory Program at no direct cost to the site.
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3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE
CRITERIA
3.1
CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA
The 1989 ROD specifies two operable units (OUs) of the remedy:
OU1 - the remediation of on site soils through SVE and ground water through P&T
OU2 - the identification and remediation of upgradient sources
Further investigation found no upgradient sources and a "no-action" ROD was issued for OU2 in 1993.
The soils portion of the OU1 remedy was also completed in the 1993. The OU1 ROD specifies the
following objective for the ground water portion of the OU1 remedy:
The ground water will be remediated by extraction, treatment, and reinjection to meet either
Federal or State drinking water levels except in those cases where the upgradient
concentrations are above such standards. In such a case, the contamination will be reduced
to upgradient levels so as to eliminate any significant contribution from the SMS site.
The 1989 ROD further stated that remediation would be expected within four years of operation.
Although this decision document specifically addresses aquifer cleanup, the 1992 monitoring plan indicates
that the P&T system was designed to provide a hydraulic barrier across the width of the SMS property
(approximately 300 feet).
The cleanup standards for the primary contaminants of concern that remain at the site as of the RSE are
summarized in the following table.
Contaminant Exceeding Standard
sec-Butylbenzene
Chlorobenzene
1 ,2-Dichlorobenzene
1 ,1-Dichloroethane**
Ethylbenzene
n-Propylbenzene
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
Xylenes
Cleanup Standard (ug/L)
5
5
4.7*
5
5
5
5
5
5
* this standard applies to the combined concentration of 1,2-Dichlorobenzene and
1,4-Dichlorobenzene
** as discussed in Section 4.2.3 of this report, 1,1-Dichloroethane is likely associated
with upgradient sources and should not be considered a contaminant of concern at the
SMS site
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3.2
TREATMENT PLANT OPERATION STANDARDS
Although the treatment plant was originally designed to reinject the treated water through injection wells
upgradient of the SMS property, fouling of those injection wells resulted in the site team discharging the
water to a recharge basin located to the east (sidegradient) of the site. The effluent standards for the
primary constituents of concern that remain in the treatment plant influent are provided in the following
table. These standards are based on the water quality standards of the receiving ground water and are
documented in the O&M manual.
Parameter
1 ,2-Dichlorobenzene
1 ,4-Dichlorobenzene
Chlorobenzene
P-xylene and m-xylene
O-xylene
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
Ethylbenzene
Effluent Standard
(ug/L)
4.7*
5.0
5.0
5.0
5.0
5.0
5.0
' the standard of 4.7 ug/l is for the sum of these compounds
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4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT
4.1 FINDINGS
The RSE team observed a site where the soil remedy had effectively removed soil contamination, which
had been providing a continuing source of dissolved ground water contamination. Ground water
concentrations have decreased substantially, indicating the initial success of the remedies. The ground
water remedy has continued to extract and treat contaminated ground water in an attempt to achieve its
remediation objectives, but the system has failed to meet its discharge criteria on multiple occasions and
the annual costs of operation are significantly more than the RSE team would expect for this site. 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 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 WATER LEVELS
Although depth to water measurements are collected quarterly and converted to water elevations these
measurements are not presented in the quarterly reports or used to generate potentiometric surface maps.
Water levels from March 2003 confirm suggest a hydraulic gradient of approximately 0.001 feet per foot.
The water elevation is approximately 55.7 feet a MW-8 and MW-9 and decreases to approximately 54.7
feet per foot at MW-11, MW-12, and MW-13. The influence of pumping is not discernible from plotted
water levels, but this is expected given the relatively flat hydraulic gradient, a productive aquifer, and
limited points to measure water elevation.
The site team maintains that discharging the treated water to the recharge basin has little or no effect on
the capture provided by the extraction system because there was a limited or undetectable change in the
water elevation at site after discharge to the basin began. This finding is not documented in site reports
and was not confirmed by the RSE team, but the productive nature of the aquifer supports the finding.
4.2.2 CAPTURE ZONES
An analysis of capture has not been recently conducted or documented. However, a preliminary capture
zone analysis can be conducted by performing a water budget analysis and by reviewing water quality
data from sentinel wells.
A water budget analysis calculates the amount of ground water entering the site from upgradient and
compares this value to the amount extracted. In general, the amount extracted should exceed the amount
entering from up gradient by a factor of 1.5 or 2.0. As stated in Section 1.5.3 of this report, the hydraulic
gradient is approximately 0.001 feet per foot and the hydraulic conductivity estimated at approximately
268 feet per day. This translates to a Darcy velocity of 0.27 feet per day. The saturated thickness from
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the water table to the bottom of EW-1 is approximately 50 feet assuming a water table depth of 20 feet
below ground surface and a total depth for EW-1 of 70 feet. The contaminated portion of the site is
approximately 100 feet in width, which suggests a total cross-sectional area of approximately 5,000
square feet (50 feet deep by 100 feet across). Therefore, approximately l,350cubic feet per day (0.27
feet per day times 5,000 square feet) enter the site from upgradient during non-pumping conditions. This
is equivalent to approximately 10,000 gallons per day. The pumping rate from EW-1 is approximately 45
gpm (64,800 gallons per day), and the combined pumping rate from EW-1 and EW-3 is approximately 90
gpm (129,600 gallons per day). Therefore, the amount extracted is approximately a factor of 10 greater
than the amount entering the site based on the hydraulic data from the Remedial Investigation. A water
budget analysis, therefore, strongly supports that capture is provided.
An evaluation of water quality data from downgradient wells MW-12, MW-13, MW-14, MW-15, and
MW-16S,M,D reveals a number of exceedances for 1,1-dichloroethane and 1,1,1-trichloroethane. As
discussed in Section 4.2.3 of this report, the 1,1-dichlorothane and the 1,1,1-trichloroethane likely result
from upgradient sources and therefore, in the opinion of the RSE team, should not be considered
contaminants of concern for this site. Their presence in sentinel wells for the SMS site therefore do not
indicate failed capture of site-related contamination.
In addition, to the exceedances of 1,1-dichloroethane and 1,1,1-trichloroethane, there was a series of
exceedances between October 2001 and April 2002 for chlorobenzene in MW-13 and a single
exceendance of bis (2-ethylhexyl) phthalate in MW-16S in April 2002. The RSE team might attribute this
series of exceedances, that are indicative of a contaminant spike, to a potential extended shutdown in the
treatment system that might have resulted in a temporary failure to provide capture. This should be
verified by the site team. As calculated in Section 1.5.3 of this report, the estimated contaminant
transport velocity for ground water at this site is approximately 1 foot per day. Therefore, an extended
shutdown of the treatment system one year earlier may have resulted in contamination migrating toward
MW-13, which is approximately 300 feet downgradient of EW-1.
4.2.3
CONTAMINANT LEVELS
Ground water contamination at the site has decreased substantially since the Remedial Investigation. The
RSE team attributes this decrease to removal of the contaminated soil by the SVE system and the
productive aquifer (augmented by injection of treated water between 1994 and 1998) that has flushed
contaminated ground water toward EW-1 or even beyond EW-1 before it became operational. The
following tables provide representative ground water concentrations from the Remedial Investigation and
the maximum concentrations from the April 2002 sampling event.
Contaminant Exceeding Standard
"Representative"
Remedial Investigation
Concentration (ug/L)
Maximum April 2002
Concentration
(ug/L)
SVOCs
1 ,3-Dichlorobenzene
1 ,2- and 1 ,4-Dichlorobenzene
Napthalene
22.5
119.5
34.5
<5
4.9
<5
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Contaminant Exceeding Standard
"Representative"
Remedial Investigation
Concentration (ug/L)
Maximum April 2002
Concentration
(ug/L)
VOCs
Chlorobenzene
1 ,2-Dichloroethane
1 , 1 -Dichloroethane
Ethylbenzene
Tetrachloroethene
Trichloroethene
Total xylenes
568
530
7
215
20.8
4,396
1,750
39
<5
20
13
<5
<5
12
As is evident from the tables, most contaminant concentrations have decreased by over an order of
magnitude from the time of the Remedial Investigation. For many of the chlorinated compounds, such as
tetrachloroethene and trichloroethene, the decrease in concentration may also be due to dechlorination
caused by microbial activity using the other organics as nutrients and the chlorinated compounds as
electron acceptors. Figure 4-1 shows that total VOC concentrations at MW-6S were decreasing
between 1994 and 1998 and that the decrease was substantially accelerated by the addition of EW-3.
Figure 4-2 also shows that concentrations have been low since 1998. They are, however, not low enough
to meet the cleanup standards and conditions have been nearly stable (with fluctuations) for
approximately four years.
If capture of the source area is complete with EW-3, the RSE team would expect concentrations in EW-1
to decrease over time and fall below cleanup standards. During the first year of operation, concentrations
in EW-1 appeared to decline substantially, but asymptotic behavior and fluctuations in the concentrations
have prevented cleanup standards from being met at this downgradient location. The RSE team expects
that this same behavior will continue for a number of years and perhaps decades before the cleanup
standards are consistently met over a number of sampling events. Although the extraction at EW-3 helps
remove mass near the source area, it also likely creates a zone of stagnation immediately downgradient,
which will delay the flushing of contamination that is between EW-3 and EW-1 toward EW-1 for
extraction.
The RSE team also believes that ground water contamination from upgradient will continue to flow
through the site and will affect the ability of the site team to close the site if it does not distinguish
between the contamination that is site-related and the contamination that is not site-related. In particular,
the RSE team sees 1,1-dichlorothane and 1,1,1-trichloroethane as contaminants from upgradient. As
shown in Figure 4-2, these constituents are found throughout the site, including the upgradient wells.
Contrastingly, the site-related contaminants, including a variety of benzene-related compounds, are limited
to the former source area and the immediate area downgradient (EW-1, EW-3, and for a brief period,
MW-13). In addition, 1,1-dichloroethane and 1,1,1-trichloroethane were not detectable in the surface or
subsurface soils during the Remedial Investigation indicating that they were not part of the original site-
related source material.
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4.3 COMPONENT PERFORMANCE
4.3.1 EXTRACTION SYSTEM WELLS, PUMPS, AND HEADER
The extraction wells continue to operate as expected, pumping approximately 45 gpm each. The lack of
controls and heat tracing has not adversely affected the performance of EW-3 for over four years. The
lines between EW-1 and the treatment system were cleaned once since the system became operational to
remove iron fouling.
4.3.2 EQUALIZATION/INFLUENT TANK
Approximately 55 gallons of sludge accumulates in the bottom of the 7,300-gallon influent tank per year.
This sludge is removed and disposed of as non-hazardous waste.
4.3.3 AIR STRIPPER
The 50-foot tall air stripper is acid washed once per month. The pH in the influent tank is lowered to
approximately 3.5 or 4.5 and water is recirculated through the air stripper. In addition, polyphosphate is
added prior to the air stripper in an attempt to prevent it from precipitating onto the packing material. In
1998, chemicals from the cleaning of EW-1 inadvertently passed through the air stripper, perhaps resulting
in further cleaning. The system failed to meet discharge standards on based on the 10/17/01 and 12/11/01
sampling results. Troubleshooting identified a failed blower motor as a cause of the decreased efficiency
and failure to meet discharge standards. Sampling in April 2002, December 2002, and March 2003
indicate that the system is meeting discharge requirements and that the failed blower motor was the
primary cause of the previous exceedances.
4.3.4 GAC
The GAC in the four 2,000-pound vapor phase GAC vessels is replaced every 18 months. This
replacement frequency is based primarily on the historical frequency but OVA readings are taken
regularly. Given that treatment plant removes less than 0.4 pounds of VOCs per day (216 pounds every
18 months), this translates to approximately 37 pounds of vapor GAC per pound of contaminants.
4.3.5 GYLCOL HEATING UNIT
This system functions as expected to dehumidify the air stripper off gas before treatment via vapor phase
GAC.
4.3.6 SYSTEM CONTROLS
The system has a series of alarms that can indicate problems to the plant operator, and these alarms are
connected to an autodialier that can contact the operator during off hours.
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4.4
COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
O&M COSTS
According to the RPM, the annual costs for system O&M are approximately $378,000 per year. A
breakdown of those costs is provided in the following table and subsections based on information provided
by the contractor project manager during the RSE site visit. It should be noted that this annual cost
exceeds the ROD estimate of $123,000 by more than 200%. Both the RSE team and the representatives
from NYSDEC expected that such a system should likely cost approximately $200,000 per year.
Furthermore, as discussed below, the current costs do not include any analytical costs because the
laboratory analysis is provided at no cost to the site by the Contract Laboratory Project, which further
inflates the actual O&M costs relative to the expectations of the ROD, NYSDEC, and the RSE team.
At the RSE site visit, the site team reported that during one recent year, the annual costs were reduced to
approximately $260,000 for the year in order to accommodate reduced funding. The cost cutting
measures included reduced operator hours (perhaps by 50%), reduced maintenance measures, and
omitting replacement of the vapor phase GAC. As is evident from reviewing the following table, other
measures were also likely taken to reduce costs by $118,000 (i.e., from approximately $378,000 for the
year to approximately $260,000 for the year).
Item Description
Labor: Project management, technical support,
reporting
Labor: Plant operator (hours)
Labor: Groundwater monitoring (events, durations,
number of teams)
Utilities: Electricity
Non-utility consumables: GAC
Non-utility consumables: chemicals and supplies
for non-routine maintenance
Waste disposal
Chemical analysis under Contract Laboratory
Program
Total Estimated Cost
Estimated Cost
$150,000 per year
$130,000 per year
$36,000 per year*
$30,000 per year
$11, 000 per year
$20,000 per year
$1,000 per year
No cost to project
$378,000
Percentage of
Total Cost
39.7%
34.4%
9.5%
7.9%
2.9%
5.3%
<1%
0%
100%
4.4.1
* This cost is estimated relatively conservatively by the RSE team based on professional experience
with labor and equipment costs for ground water sampling
UTILITIES
At any given time, the treatment system has approximately 23 HP of pumps and blowers operating plus
the 12.3 kW glycol heating unit. Heat tracing that is used during the winter would also add to the
electrical usage when used. The contractor project manager indicated that utilities cost approximately
$30,000 per year, which is consistent with an unit electrical cost of approximately $0.10 per kWh.
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4.4.2 NON-UHLTTY CONSUMABLES AND DISPOSAL COSTS
GAC is the single largest non-utility consumable cost at approximately $11,000 per year as reported by the
contractor project manager. This cost covers replacement of the GAC in the four 2,000 pound vapor
phase GAC vessels every 18 months, which translates to a unit cost of approximately $2 per pound of
GAC. Other non-utility consumable costs include approximately $20,000 per year for 16 drums of
polyphosphate per year, hydrochloric acid for the air stripper acid washes, and other materials and
supplies. These other materials and supplies likely include insulation, which is reportedly replaced each
winter, and replacement pumps or parts for the system.
4.4.3 LABOR
Labor is the largest component of annual costs, contributing over 80% of those costs. The plant operator
consistently works a 40 hour week (including responding to alarm calls) at a reported cost of $130,000 per
year. This translates to an hourly rate, including overhead, of approximately $60 to $65 per hour. With
respect to project management, technical support, and reporting, a reported cost of $150,000 per year and
an estimated hourly rate of $100 per hour, including overhead, should translate to approximately 1,500
hours per year, or approximately 28 hours in a 40-hour week. The cost for sampling labor is estimated by
the RSE team based on information provided by the contractor. The contractor reports that there are four
sampling events per year and that each sampling event requires three people working approximately three
days. At an relatively conservative estimated cost of $3,000 per day for labor and equipment, this
translates to an annual cost of approximately $36,000 per year.
In addition to contributing over 80% of the annual O&M costs, the actual labor costs also vary widely
compared with the original ROD estimates. All actual costs were relatively equivalent with the ROD cost
estimate except for operating labor and project management/technical support/reporting labor. The ROD
estimated 312 hours per year of operating labor for $15,600 per year compared to the actual 2,080 hours
per year for $130,000 per year. Therefore, the actual labor cost is over 8 times higher than expected.
The project management/technical support/reporting labor was estimated in the ROD at an unusually low
figure of $1,200 per year. The actual expense is $150,000 per year, which is unusually high, especially
considering the lack of figures and analysis provided in reports and the lack of changes to the system
since EW-3 was added.
4.4.4 CHEMICAL ANALYSIS
The site does not incur any costs for chemical analysis because the Contract Laboratory Program
provides the laboratory analysis. The turnaround time between the collection of the sample and the report
from the laboratory is approximately 6 to 8 weeks. Given the current process monitoring program,
approximately 12 samples (including QA/QC samples) are analyzed per year for VOCs, SVOCs, and
metals. Given the current ground water monitoring program, approximately 100 samples (including
QA/QC samples) are analyzed for VOCs, SVOCs, and metals. Typical costs for these analyses on one
sample would be approximately $400 per sample at a private laboratory, which would translate to a total
analytical cost of approximately $45,000 per year.
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4.5 RECURRING PROBLEMS OR ISSUES
The contractor reports the following recurring problems.
annual insulation repairs
electrical storms during the summer, which are the most common causes for system shut downs
and alarm calls
snow accumulation during the winter
4.6 REGULATORY COMPLIANCE
The treatment plant exceeded the discharge criteria for four VOCs in October 2001 and for one VOC in
December 2001. The criteria, however, were met in April 2002, December 2002, and March 2002..
4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS , ACCIDENTAL
CONTAMINANT/REAGENT RELEASES
No reagent releases or accidents were reported to the RSE team.
4.8 SAFETY RECORD
No reagent releases or accidents were reported to the RSE team.
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5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
HEALTH AND THE ENVIRONMENT
5.1 GROUND WATER
The ROD indicates that the carcinogenic risk and the noncarcinogenic hazard at the time of the Remedial
Investigation were well below the criteria for active remediation when considering casual ingestion,
dermal adsorption, and vegetable consumption. The carcinogenic risks for these three exposure routes
were less than 5xlO"7 and the noncarcinogenic hazard indices were less than IxlO"2. The potential use of
ground water downgradient from the site was evaluated as a hypothetical scenario because it was
assumed that all downgradient residences were connected to public water. Under this hypothetical
scenario, the carcinogenic risk (calculated with measured data) was 2.27xlO"5 and the noncarcinogenic
hazard index was 6.86x10"'. These values were calculated using trans-1,2-dichloroethene,
tetrachloroethene, and trichloroethene because they were among the most toxic components found at the
site and had elevated concentrations in ground water based on the Remedial Investigation data. These
compounds are no longer present at the site above background concentrations. They were likely removed
during the soil remedy and through natural degradation. As early as 1994 (i.e., when the P&T system
began operating), few, if any, samples had concentrations of these compounds over ground water cleanup
standards and the measured concentrations were comparable to the background concentrations from
MW-8 and MW-9.
It appears that the remedy has largely been protective with respect to site related contamination. Based
on the limited hydraulic information available, it appears that the capture zone is likely sufficient to prevent
further migration of site-related contamination. In one or two instances, site-related contamination
(primarily chlorobenzene) was able to migrate off site, perhaps due to a temporary lack of capture when
the system was shut down for extended maintenance or repairs. This migration is smaller in extent and
magnitude than the downgradient migration of 1,1-dichloroethane and 1,1,1-trichloroethane that likely
result from upgradient sources and the SMS remedy, in its current form, is incapable of providing
complete capture of this contamination coming from upgradient.
It is beyond the scope of the RSE to evaluate the current risks associated with the site, but given the
relatively low risks/hazards that were present at the time of the Remedial Investigation and the fact that
the most toxic contaminants have been removed, it is likely that the incremental carcinogenic risk to the
public is less than 1x10"6 and that the noncarcinogenic hazard index is less than 1x10"2
5.2 SURFACE WATER
The closest downgradient surface water is Guggenheim Lake, located approximately 1.5 miles from the
site. The potential risks to this and other surface water bodies were not discussed as part of the RSE.
The current degree of plume capture should provide adequate protection to surface water.
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5.3 AIR
The primary route for impacts to the air is from the air stripper off gas. Given that the current mass
loading is orders of magnitude lower than expected and that the vapor phase GAC is still replaced, the
measures taken at the site are likely protective.
Site wells do not indicate elevated levels of ground water contamination, and soil contamination has been
remediated to the soil cleanup standards. Therefore, vapor intrusion in this light industrial area is not likely
an issue requiring attention.
5.4 SOILS
The soil contamination was remediated to cleanup standards via SVE between 1992 and 1994. No further
protectiveness issues related to soil are expected.
5.5 WETLANDS AND SEDIMENTS
The RSE team is not aware of wetlands or sediments that may be impacted by site-related contamination.
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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 IMPROVE REPORTING AND DATA ANALYSIS (INCLUDING EVALUATING PLUME
CAPTURE)
The contractor provides quarterly sampling data summary reports to the EPA. The summary report
reviewed by the RSE team was prepared in March 2003 and summarized the data from December 2001
and April 2002. It had no figures, no water level data, and limited data analysis. Although monthly
reports are prepared by the operator and provided to the prime contractor, EPA does not receive reports
that have system operating information, including flow rates, mass removal, discharge quality, and major
maintenance.
Discharge sampling is not required by permit but is conducted on a quarterly schedule. The results are
included in the quarterly report but are not discussed in the report text. In reviewing the quarterly report
dated March 2003, the RSE team found that in the October 2001 and December 2001 sampling events
several VOCs in the system effluent were above discharge criteria. During the RSE, EPA indicated that
they were not aware of this problem. This indicates a failure of the report to adequately inform the
project manager of important site-related issues and may also be a function of the unacceptably long
delay (over one year) between sampling events and the submission of the associated report.
The quarterly reports should be improved and should be submitted in a timely manner. Improvement might
include the following:
a site map detailing the ground water sampling results
a potentiometric surface map indicating the pumping rate and the interpreted or estimated capture
zone
a method of highlighting exceedances of the discharge criteria or ground water cleanup criteria in
the data tables
descriptions of maintenance to the P&T system
P&T system parameters, including flow rates, mass loading, discharge quality, etc.
a written evaluation (perhaps 1 to 2 pages) of the system performance with respect to capture of
the contaminant plume, progress toward cleanup, and compliance with air and water discharge
standards
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Normally, the RSE team would expect the reports to be submitted within 1 to 2 months of the sampling
event, but given the unusually long turnaround time associated with the Contract Laboratory Program (6
to 8 weeks), submitting the reports within 3 months of the sampling event is reasonable. For this
particular site, the RSE team estimates that each report (as described above) should cost $10,000 to
generate. This $10,000 is the total cost of each report and not additional to the existing costs. Therefore,
the total annual reporting cost for this site should be approximately $40,000 if reports including the above-
mentioned items are prepared. The first report might cost an additional $5,000 to generate base maps and
templates, but given the history of an exceptionally high project management/technical support/report
expense, these items should have already been completed.
The current budget for reporting was not provided to the RSE team; therefore, the change in annual
O&M costs for implementing this recommendation cannot be reliably calculated. Section 6.2.1 discusses
cost reductions for project management, technical support, and reporting. That discussion assumes this
recommended level of reporting and the above-mentioned estimated cost of $40,000 per year when
stating the RSE team's opinion of appropriate labor costs for this site. Therefore, the costs associated
with implementing this recommendation are included in the estimated cost savings discussed in Section
6.2.1.
6.2 RECOMMENDATIONS TO REDUCE COSTS
6.2.1 REDUCE OPERATOR AND PROJECT MANAGEMENT/TECHNICAL SUPPORT/REPORTING
LABOR
After discussion during the RSE site visit, it is not clear to the RSE team why a full-time operator is
necessary at the site. The contractor stated significant time was necessary for maintenance of the
insulation and other weather related issues, including alarms during electrical storms and snow removal.
Other items may include acid washing the air stripper once a month and maintaining the polyphospate
addition approximately once every three to four weeks. Basic O&M activities, such as checking the
system, responding to alarms, maintaining chemical addition should, and acid washing the tower should be
accomplished for approximately 16 hours per week or less. Additional time might be required on a semi-
annual basis, but this should be no more than two additional 40-hour weeks per year. This labor estimate
translates to approximately 912 hours per year compared to the current 2,080 hours per year and an
annual cost of approximately $57,000 per year or more compared to the current $130,000 per year.
Reductions should also be made in the project management/technical support/reporting costs. As stated in
Section 6.1.1, the recommended level of reporting will likely cost approximately $40,000. Reviewing
invoices, coordinating site activities, and overall project management should likely cost approximately
$36,000 per year (approximately $3,000 per month) for this relatively simple system. The RSE team
acknowledges that technical support is necessary during O&M, and for the SMS site, approximately
$30,000 per year (approximately 200 to 300 hours per year of senior time) is likely sufficient. The sum of
these three cost estimates equals approximately $106,000 per year. Therefore, rounding up, this category
of labor should cost approximately $110,000 per year. Instead, however, it costs an additional $40,000
even though a number of basic items are not provided.
The quarterly reports require significant improvements including data analysis, basic figures, and
information on the treatment system.
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The quarterly reports are delayed by more than a year from the time of the sampling event (i.e.,
the report summarizing the December 2001 and April 2002 data was submitted in March 2003).
The treatment system had two exceedances of the discharge criteria in 2001, EPA (the client)
was unaware of these exceedances, more exceedances may have occurred since that time, and
influent/effluent sampling data since April 2002 is not yet available as of July 2003.
Ground water sampling still continues quarterly for VOCs, SVOCs, and metals even though
VOCs are the only remaining contaminants of concern.
The RSE team recommends reducing labor as stated above. A total savings of approximately $113,000
per year could be expected. Subtracting these costs from the current annual O&M costs of
approximately $378,000 would yield approximately $265,000, which is similar to the reduced annual O&M
costs ($260,000 for the year) that were achieved during one year to accommodate reduced funding.
6.2.2 OPTIMIZE MONITORING PROGRAM
All 20 site monitoring wells, the two extraction wells, and system influent and effluent are sampled
quarterly (about 100 samples per year total, excluding QA/QC samples) and analyzed for VOCs, SVOCs
and metals. Analysis for SVOCs and metals is not necessary at any wells because they are not being
treated by the groundwater treatment system and SVOC and metals plumes do not exist. SVOC and
metals analysis should continue only in the treatment system effluent to verify the discharge water quality.
Eliminating the unnecessary analyses will not result in direct cost savings to the site because analyses are
provided by the Contract Laboratory Program, but it should be done because it will reduce the amount of
data to manage, the number of bottles in the field to manage, and the sample load on the laboratory.
Sampling at many monitoring wells could be reduced from a quarterly to annual frequency or eliminated
altogether. For example, MW-01, MW-02, MW-03, MW-04, MW-05, MW-6D, and MW-07 repeatedly
have concentrations that are either consistent with background concentrations or are undetectable.
Eliminating these wells from the sampling program would not compromise the ability of the sampling
program to evaluate the performance of the remedy. At the very least, the sampling frequency in these
wells should be reduced to annual.
Monitoring should continue on a quarterly basis at the extraction wells and the monitoring wells in and
downgradient of the source area (MW-6S, MW-6D, MW-15, MW-16S,M,D, MW-11, MW-12, MW-
13S,D, and MW-14) because they are valuable for either documenting progress to cleanup (MW-6S) or
verifying plume capture. MW-08 and MW-09 should also continue to be monitored because they provide
background samples for the site and there is a history of background contamination. The above
recommended revisions to the sampling program would reduce the number of monitoring well samples per
year from approximately 80 to 59. Therefore implementing this recommendation should reduce sampling
costs by approximately 25% from an estimated $36,000 per year to $27,000 per year.
6.2.3 CONSIDER DECREASING THE FREQUENCY OF VAPOR PHASE GAC REPLACEMENTS
The O&M manual provides the potential impact from air stripper off-gas and the New York State
Ambient Guideline Concentrations (AGCs). The system was designed to comfortably meet the AGCs
with the highly elevated concentrations measured during the Remedial Investigation. Now that influent
concentrations and mass loading are substantially lower, it is likely that with the reduced influent
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concentrations, the AGCs can be met with less frequent GAC changeouts. This was demonstrated during
the year with reduced funding when the site team opted to not replace the vapor phase GAC. The RSE
team recommends screening both the influent and effluent to the vapor phase GAC to determine if the
replacement frequency can be reduced to once every two years or once every three years. If this
reduction is possible, a savings of approximately $3,000 to $5,000 per year may result without sacrificing
protectiveness.
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT
No specific recommendations are provided in this category. Rather, the site team is encouraged to focus
on the recommendations in the other categories.
6.4 C ONSIDERATIONS FOR GAINING SITE CLOSE OUT
6.4.1 DEVELOP AND EXIT STRATEGY
Although the remedy has not yet achieved its specific objectives (i.e., restoration to applicable standards),
the risks that the ROD stated were the reason for active remediation are no longer present. It may
therefore be appropriate to discontinue the P&T system now or in the near future and rely on other
mechanisms to reach the cleanup goals. The RSE team sees the following potential approaches that
could be adopted as the basis for the remedy exit strategy.
Continue operating the P&T system until all contaminants of concern are at or below background
concentrations
Given that concentrations have not substantially decreased over the past four to five years with the
current P&T system, this approach will likely take a number of years. This approach would provide the
best measure of capture relative to the other approaches, but it would also likely cost more than the other
approaches. With an optimized system, the annual costs will likely be on the order of $250,000 per year.
Discontinue the P&T system to determine if contamination will migrate offsite above specified
concentration criteria
Under this approach, the site managers would discontinue the P&T system but would continue monitoring
to verify that the remaining, relatively low level contamination, does not migrate off site at concentrations
that would be of concern. To proceed with this approach, the site team should develop a set of criteria
that, if exceeded when the system is shut down, would cause the P&T system to be restarted. The
criteria should include sampling locations, concentrations for each contaminant of concern at those
locations, and the number of samples with elevated concentrations that would be needed to justify
restarting the P&T system. The RSE team suggests that the monitoring program discussed in Section
6.2.2 provides the necessary monitoring locations. The concentration criteria for each contaminant might
be the MCL, background, or some risk-based concentration. The site team may determine that at least
two quarterly samples over the course of a year with concentrations above the criteria might be required
to justify restarting the P&T system.
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The site team would continue with its monitoring program to 1) monitor for attainment of the cleanup
criteria and 2) monitor for contaminant migration, and this monitoring would continue until cleanup is
reached, whether or not the P&T system is restarted. Developing this exit strategy should cost
approximately $20,000 but annual O&M would likely consist only of monitoring, data analysis, and
reporting. The annual O&M cost could likely be under $100,000 per year. Discontinuing the P&T
system before cleanup goals are met in favor of monitoring only would likely require a ROD Amendment.
Pilot an alternative technology and determine if either that technology or another approach should
replace the P&T system
Various alternative technologies are available for reducing mass of VOCs, including air sparging,
bioaugmentation, and chemical oxidation. Any of these three approaches (and many others) rely on
effective delivery of reagents and a method to monitor effectiveness. Unfortunately, many of the
reagents that can be added may damage the wells and prohibit them from being effectively used in the
future, if necessary. Providing oxygen in the form of air or oxygen releasing compound might enhance
iron fouling of the wells, and chemical oxidation will generate substantial heat that could damage the well
casing. In addition, air sparging would release contaminant vapors into the unsaturated zone. Although
ground water monitoring suggests low VOC concentrations in the subsurface, it is possible that vapors
that are released to the unsaturated zone could migrate into nearby facilities. If this approach is taken, the
RSE team suggests the use of oxygen releasing compound (ORC) or the use of air sparging, provided that
steps are taken to monitor the release of vapors into nearby facilities.
Following this approach could be similar to the above approach for discontinuing the P&T system. The
site team could discontinue pumping for the duration of the pilot test, use select existing wells or newly
installed direct-push injection points for delivery, and use the monitoring program discussed in Section
6.2.2 to monitor effectiveness. The test would occur in much the same way as the approach above, with
the exception that active remediation is occurring. Because the active remediation should reduce
contamination, there should be a reduced potential for contamination to migrate offsite. Because this is a
pilot test, the costs for planning and executing should be relatively low beyond the cost of the reagents or
air sparging equipment. The monitoring for effectiveness would likely continue well beyond the period of
active remediation, and the pilot test would end with either 1) restarting the P&T system due to
unacceptable plume migration or 2) monitoring demonstrating that cleanup levels have been reached at
some point in the future without having to restart the P&T system. The RSE team envisions limiting the
total cost for the planning and remediation to under $125,000 and the cost for developing the exit strategy
to approximately $20,000. On an annual basis, this option would require additional level of effort beyond
the option of monitoring only. The cost for this option would likely be under $150,000 per year. Because
this is a pilot test, a ROD Amendment or ESD is not likely required unless the alternative technology is
fully accepted and it is known that the P&T system will be permanently shut down.
6.4.2 CONSIDERATIONS IF P&T is REQUIRED FOR A NUMBER YEARS AND MAINTENANCE is
AN INCREASING CONCERN
It is possible that P&T may need to continue at this site for a number of years (e.g., greater than 5 years),
depending on the exit strategy chosen by the site time and/or the outcome of an active remediation pilot
test. If this is the case, and the treatment system requires an increasing amount of maintenance (perhaps
due to fouling or damage from weather), modifications or replacement may necessary.
23
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If a future problem with the air stripper is determined to be fouling of the air stripper packing, replacing
the packing should restore the air stripper to near its original efficiency. The air stripper would likely need
to be dismantled to accomplish this, especially if fouling is significant. The RSE team estimates that a
capital cost of $10,000 up to $60,000 would be required to either remove and replace the packing or
replace the air stripping tower entirely (depending on the degree of fouling). The RSE team notes that
replacement of the packing is likely not necessary at this point. Since the blower was replaced, the air
stripper has met its discharge standards and VOCs in the effluent have largely been undetectable. The
packing, however, should be inspected to evaluate the degree of fouling and the effectiveness of the
current acid washing and polyphosphate addition.
If future problems require replacement of the air stripper, the RSE team provides the following options for
consideration.
Replace the air stripper with Liquid Phase GAC
This option would involve replacing the current air stripper with two 5,000-pound liquid phase GAC units.
The units themselves would cost approximately $30,000, and installation might require an additional
$100,000. An additional $70,000 is estimated to remove existing unnecessary equipment and provide for
contingencies. The units could be insulated and placed outside with the other equipment. The vapor GAC
and associated glycol heater would no longer be necessary. Utility costs would decrease by about
$15,000 per year based on the removal of the glycol heating unit and the air stripper blower. The
polyphospate and hydrochloric acid would also no longer be needed, and much of the current maintenance
would be reduced yielding potential savings of $10,000 per year in chemicals and maintenance parts. Due
to improved reliability and automation, operator labor costs would be similar to or less than those discussed
in Section 6.2.1.
Based on the influent data from October 2001 (a sampling event with relatively high concentrations
compared to other recent events) and documented carbon isotherms, the RSE team estimates that
approximately 150 to 200 pounds of GAC would be required to remove each pound of VOCs. Assuming
an average mass loading to the treatment system of 0.2 pounds per day, this would translate to
approximately replacing the lead GAC vessel two to three times per year based on chemical loading. This
would likely translate to an estimated cost of approximately $25,000 per year, which is similar in
magnitude to the decreased costs in utilities and chemicals described in the above paragraph.
With liquid phase GAC, fouling may be an issue. Including bag filters in the treatment train prior to the
GAC units would help reduce the fouling, and the replacement frequency of two to three times per year
for chemical loading may also be an appropriate replacement frequency for addressing fouling. The
influent and effluent tanks should likely remain in place to allow for backwashing. Before proceeding, the
RSE team would recommend further discussions with vendors and a pilot test to better estimate the
replacement frequency based on chemical loading and fouling. This pilot test should be conducted for
under $25,000 by diverting some of the influent through a test vessel of approximately 500 pounds of
GAC. In sum, this approach may require $225,000 in capital costs, and the annual costs for chemicals,
materials, and utilities would likely remain the same relative to operating the current system under the
reduced labor as described in Section 6.2.1.
24
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Replace the air stripper with a low-profile tray aerator
The existing packed tower air stripper could also be replaced with a low-profile tray stripper that can
reliably provide 99% or greater removal efficiency for the contaminants of concern. A low-profile model,
such as the North East Environmental Products (NEEP) models, can be easily serviced and cleaned to
address iron fouling that may occur. There would be an increase in electrical costs for operating a larger
blower, but these would likely be offset by reduced maintenance and discontinuing the acid washing and
polyphospate addition. Due to improved reliability and automation, operator labor costs would be similar to
or less than those discussed in Section 6.2.1. The stripper should be enclosed in a small, heated enclosure
to avoid some of the weather problems reported by the current operator. A pilot test, however, would not
be necessary because air stripping has already been proven effective at the site. With equipment,
installation, electrical, and plumbing, and the enclosure, the RSE team estimates that the necessary
modifications can be made for approximately $300,000.
6.5 SUGGESTED APPROACH TO IMPLEMENTATION
The RSE team suggests implementing recommendations 6.1.1, 6.2.1, 6.2.2, and 6.2.3 immediately and
reducing annual O&M costs to approximately $250,000. The site team should then focus on the exit
strategy as described in Section 6.4.1.
With respect to recommendation 6.4.1, the RSE team suggests proceeding with the second or third option,
both of which involve discontinuing the P&T system, monitoring the potential for plume migration, and
restarting the system if migration occurs at unacceptable levels. The RSE team further suggests adopting
the selected exit strategy and approach by the end of calendar year 2003, while the site is still in the Long-
Term Remedial Action phase. This would allow nearly a year and a half to determine if the P&T system
will need to be restarted before the site is transferred to the state. If it does need to be restarted, EPA
should evaluate the condition of the air stripper packing to determine if replacement of the packing is
required.
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7.0 SUMMARY
The RSE team observed a site where the soil remedy had effectively removed soil contamination, which
had been providing a continuing source of dissolved ground water contamination. Ground water
concentrations have decreased substantially, indicating the initial success of the remedies. The ground
water remedy has continued to extract and treat contaminated ground water in an attempt to achieve its
remediation objectives, but the system has failed to meet its discharge criteria on multiple occasions and
the annual costs of operation are significantly more than the RSE team would expect for this site. The
observations provided 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 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 one recommendation to improve effectiveness in protecting human health and the environment is to
improve the data analysis and reporting. Recommendations to reduce costs include reducing operator
labor and project management/technical support/reporting labor. These components of labor comprise
approximately 80% of the total O&M costs, and labor at this level is not necessary to operate and
maintain this system. No recommendations are provided for technical improvement. Instead, emphasis
should be placed on implementing the other recommendations. For site closeout, the RSE team
recommends developing an exit strategy and provides three potential approaches for consideration. The
risks that the ROD indicates as the reason for active remediation are no longer present. Therefore, two
of the three approaches include discontinuing the P&T system and monitoring for potential plume
migration. In addition, the RSE team provides considerations if the P&T system requires significant
modifications or replacement in the future.
Table 7-1 summarizes the costs and cost savings associated with each recommendation. 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.
26
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Table 7-1. Cost Summary Table
Recommendation
6.1.1 Improve Reporting and
Data analysis (Including
Evaluating Plume Capture)
6.2. 1 Reduce Operator and
Project Management/
Technical Support/Reporting
Labor
6.2.2 Optimize Monitoring
Program
6.2.3 Consider Decreasing the
Frequency of Vapor Phase
GAC Replacements
6.4.1 Develop an Exit Strategy
Continue with P&T
Monitoring only
Aggressive remediation
(e.g., air sparging)
6.4.2 Considerations if P&T is
Required for a Number Years
and Maintenance is an
Increasing Concern3
Reason
Effectiveness
Cost
Reduction
Cost
Reduction
Cost
Reduction
Site Closeout
Site Closeout
Additional
Capital
Costs
(S)
$0
$0
$0
$0
$0
$20,000
$145,000
$225 000
to
$300,000
Estimated
Change in
Annual
Costs
(S/yr)
Included in
62 1
($113,000)
($9,000)
($3,000)
to
($5,000)
Estimated
Change
In Life-cycle
Costs
(S)1
Included in
62 1
($1,130,000)
($90,000)
($30,000)
to
($50,000)
Estimated
Change
In Life-cycle
Costs
(S)2
Included in
62 1
($915,000)
($73,000)
($23,000)
to
($41,000)
Annual costs would likely be as follows:
$250,000 per year for approximately 10 years
$ 1 00,000 per year for approximately 1 0 years
$150,000 per year for one year and $100,000 per
year for 1 to 10 years thereafter
$0
$225 000
to
$300,000
$225 000
to
$300,000
Costs in parentheses imply cost reductions.
1 assumes 10 years of operation with a discount rate of 0% (i.e., no discounting)
2 assumes 10 years of operation with a discount rate of 5% and no discounting in the first year
3 this is a consideration for the future only and not a recommendation for specific action at this point.
27
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FIGURES
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FIGURE 1-1. SITE LOCATION MAP.
SMS
Instruments
t
*v' '- *
T. c tWl
i / >;>.i
'
,/
(Note: This figure is taken from the USGS Greenlawn Quadrangle.)
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FIGURE 1-2. THE FORMER SMS INSTRUMENTS FACILITY, SURROUNDING AREA, AND WELL LOCATIONS.
MW-08^
MW-09
FORMER
ABOVE-GROUND
DRUM STORAGE AREA
ฎ
MW-01
ฎMW-02 MV3
FORMER
SMS
INSTRUMENTS
A FORMER-
MW-07 LEACHING POOL
CURRENT GROUNDWATER
TREATMENT PLANT
r
MW-12^
MW-1 1
ISO
300
SCALE IN FEET
(Note: This figure is taken from various figures generated by CDM Federal under work assignment 019-2LR5.)
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FIGURE 4-1. VOC CONCENTRATION TREND IN MW-6S
7000
_ 6000
O)
3
o
o
O
O
>
3
o
Operation of EW-
3 begins
5000
4000
3000
2000
1000
Declining concentration
Concentrations are relatively low
but have remained above cleanup
standards for over 4 years
11/27/93 4/11/95 8/23/96 1/5/98 5/20/99
Date
10/1/00
2/13/02
6/28/03
The VOC concentration in MW-6S (source area) declined between 1994 and 1998 due to the natural flushing of clean water through the site. EW-1,
located at the downgradient boundary of the site, was installed to capture contamination before it moved offsite. The 1998 installation of EW-3 in the
source area accelerated aquifer restoration. Concentrations are orders of magnitude lower than during the original investigations; however, they have
remained consistently above cleanup standards. Data collected in sampling events since April 2002 have not been processed or reported as of July
2003.
(Note: This figure was compiled by the RSE team based on electronic data provided by CDM in July 2003.)
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FIGURE 4-2. THE EXTENT OF SITE-RELATED AND NON-SITE RELATED CONTAMINATION.
-n*0
MW-08
MW-09,-,
^ FORMER
ABOVE-GROUND
DRUM STORAGE AREA
O
MW-01
r^
UMw-02
MW-03
FORMER
SMS
INSTRUMENTS
-J
O FORMER
MW-07 LEACHING POOL
CURRENT GROUNDWATER
TREATMENT PLANT
RECHARGE
BASIN
FORMER
SVE TRENCH
MW-14
(ป)MW-13
MW-12
MW-1 1
LEGEND
O
ฎ
WELLS WITH A REGULAR HISTORY OF 1,1-DCA
AND 1,1,1-TCA CONTAMINATION
WELLS WITH A REGULAR HISTORY OF CONTAMINATION
WITH BENZENE RELATED COMPOUNDS
150
SCALE IN FEET
300
(Note: This figure is taken from various figures generated by CDM Federal under work assignment 019-2LR5.)
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