Final Report

   Pilot Region-Based Optimization
    Program for Fund-Lead Sites
          in EPA Region 3

     Site Optimization Tracker:
AIW Frank/Mid-County Mustang Site
        Exton, Pennsylvania

            EPA Region III

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               Solid Waste and        EPA 542-R-06-006a
               Emergency Response     December 2006
               (5102P)             www.epa.gov
Pilot Region-Based Optimization Program
   for Fund-Lead Sites in EPA Region 3

       Site Optimization Tracker:
  AIW Frank/Mid-County Mustang Site
           Exton, Pennsylvania

               EPA Region III

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      Site Optimization Tracker:

AIW Frank/Mid-County Mustang Site
         Exton, Pennsylvania
            EPA Region III
             December 30, 2005

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         SECTION 1:



CURRENT SITE INFORMATION FORM

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Date:
12/30/05
Filled Out By:    GeoTrans, Inc.
A. Site Location, Contact Information, and Site Status
1 . Site name 2. Site Location (city and State) 3. EPA Region
AIW Frank/Mid-County _ . „, „,..., , T „. m
~ , ^ Exton, W. Whiteland Twp., PA HI
Mustang l
4a. EPA RPM 5a. State Contact
Charlie Root Dave Ewald
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-3193 484-250-5725
4c. EPA RPVI Email Address 5c. State Contact Email Address
Root.Charlie@epa.gov Dewald@State.pa.us
5. Is the ground water remedy an interim remedy or a final remedy? Interim | | Final IXI
6. Is die site EPA lead or State-lead with Fund money? EPA ^ State O

B. General Site Information
la. Date of Original ROD for Ground Water Remedy
09/29/1995
2a. DateofO&F
3/29/2001
3 . What is the primary goal of the P&T system
(select one)?
1 1 Contaminant plume containment
1 I Aquifer restoration
1X1 Containment and restoration
1 I Well-head treatment
lb. Dates of Other Ground Water Decision Documents (e.g., ESD. ROD Amendment)
N/A
2b. Date for transfer to State
09/30/2011
4. Check those classes of contaminants that are
contaminants of concern at the site.
£3 VOCs (e.g., TCE, benzene, etc.)
D SVOCs (e.g., PAHs, PCP, etc.)
1 1 metals (e.g., arsenic, chromium, etc.)
IXI other 1,4-Dioxane (not official COC)
5. Has NAPL or evidence of NAPL been observed at the site? Yes I I No IXI
6. What is the approximate total pumping rate? 100 gpm
7. How many active extraction wells .
(or trenches) are there?
9. How many samples are collected
from monitoring wells or piezometers __
each year? (e.g., 40 if 10 wells are
sampled quarterly)
1 1 . What above-ground treatment processes are usec
1 I Air stripping
IXI Carbon adsorption (liquid phase only)
1 I Filtration
1 | Off-gas treatment
| 	 | Ion exchange
8. How many monitoring wells are -_
regularly sampled?
10. How many process monitoring samples
(e.g., extraction wells, influent, effluent, etc.) ~-
are collected and analyzed each year? (e.g., 24
if influent and effluent are sampled monthly)
(check all that apply)?
1 I Metals precipitation
I | Biological treatment
O UV/Oxidation
I | Reverse osmosis
O Other
12. What is the approximate percentage of system downtime per year? 10% |/\l 10 - 20% | | >20% | |

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C. Site Costs
1. Annual O&M costs
O&M Category
Labor: project management, reporting,
technical support
Labor: system operation
Labor: ground water sampling
Utilities: electricity
Utilities: other
Consumables (GAC, chemicals, etc.)
Discharge or disposal costs
Analytical costs
Other (parts, routine maintenance, etc.)
O&M Total
Actual1 Annual
Costs for FY04
$29,909
$86,416
$31,845
$21,180
$14,824
$27,108
$3,803
$12,500**
$45,894
$273,479
Estimated Annual
Costs for FY052
$28,000
$80,000
$32,000
$22,000
$14,000
$25,000
$2,000
$12,500**
$48,000
$263,500
Estimated Annual
Costs for FY063
$28,000
$80,000
$32,000
$7,000*
$14,000
$25,000
$2,000
$8,000**
$48,000
$244,000
The O&M total should be equal to the total O&M costs for the specified fiscal years, including oversight from
USAGE or another contractor. For costs that do not fit in one of the above cost categories, include them in the
"Other " category.  If it is not possible to break out the costs into the above categories, use the categories as best
as possible and provide notes in the following box.
2. Non-routine or other costs

$90,000***
$90,000***
Additional costs beyond routine O&M for the specified fiscal years should be included in the above spaces. Such
costs might be associated with additional investigations, non-routine maintenance, additional extraction wells, or
other operable units.  The total costs billed to the site for the specified fiscal years should be equal to the O&M
total plus the costs entered in item 2.
Notes on costs:

1. Costs, with the exception of the analytical costs, were provided by the RPM.
2. FY05 costs, with the exception of the analytical costs, were projected by the RPM.
3. FY06 costs were estimated by the ROET based on the RPM FY05 projections, discussions
and discussions during the optimization follow-up meetings.
* Decrease in electricity reflects the expected savings in reduced electricity usage from
implementing an optimization evaluation recommendation to streamline the VOC removal
process. The RPM estimates savings between $12,000 and $18,000 per year.
** Analytical  costs were estimated by the ROET based on the sampling program.  The
analytical costs are not incurred by the EPA site team because the samples are analyzed by the
CLP program.  However, analytical costs similar to those estimated by the ROET, will likely
be incurred by the State if/when the site is transferred to the State after LTRA.  The decrease
from FY05 to FY06 reflects a sampling reduction undertaken by the site team.
*** The $90,000 spent in FY05 reflects the application of in-situ chemical oxidation. The
same expenditure in FY06 assumes that a second application would occur.

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D. Five-Year Review
1. Date of the Most Recent Five-Year Review       N/A - Initial Syr Review - 11/2005
2. Protectiveness Statement from the Most Recent Five-Year Review

    I  |   Protective                               I  I   Not Protective

         Protective in the short-term                 	   Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
E. Other Information
If there is other information about the site that should be provided please indicate that information in the space
below.  Please consider enforcement activity, community perception, technical problems to be addressed, and/or
areas where a third-party perspective may be valuable.

Residences near the site that have wells have been placed on public water. Their wells have not been
abandoned so that they can continue to be monitored as part of the ground water monitoring program.
Three wells are sampled annually. This sampling is included in the value for item B.9 of this form.

1,4-Dioxane has been found in ground water at approximately 250 ug/L and in the influent at 8 to 10
ug/L. No reduction in 1,4-Dioxane is expected through the treatment train,  and the site team does not
have a documented discharge limit for it.  For reference, the most stringent Pennsylvania Medium
Specific Concentration (MSC) for 1,4-Dioxane is 5.6 ug/L. Recent efforts by the site team suggest tlia
the discharge limit, if applied to the site, might be as high as 200 ug/L.

Section B.I 1  of this form indicates liquid phase carbon is utilized for treatment and reflects recent
implementation of recommendation to streamline the VOC removal process. Previously, the treatment
plant included air stripping with off-gas treatment and liquid phase GAC.

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                             SECTION 2:

               FOLLOW-UP HISTORY AND SUMMARIES
Note: Follow-up summaries are provided in reverse chronological order and include updated
and/or new recommendations.

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                              FOLLOW-UP HISTORY
 Date of Original Optimization Evaluation
            December 15, 2004 (Evaluation meeting)
            July 29, 2005 (Final Report)	
           Meeting Date
             July 20, 2005
           November 7, 2005
 Report Date
Item
  July 29, 2005       Follow-Up #1 (conducted as part of pilot project)


December 30, 2005     Follow-Up #2 (conducted as part of pilot project)


                   Follow-Up #3


                   Follow-Up #4


                   Follow-Up #5


                   Follow-Up #6


                   Follow-Up #7


                   Follow-Up #8
"x" in box indicates the item has been completed

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                  SUMMARY OF FOLLOW-UP #2
Site or System Name
Date of This Follow-Up Summary
Date of Follow-Up Meeting or Call
(Indicate if Meeting or Call)
AIW Frank/Mid-County Mustang Site
December 30, 2005
November 7, 2005 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Kathy Davies
Paul Leonard
Peter Schaul
Peter Rich
Rob Greenwald
Doug Sutton
Steve Chang
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
GeoTrans, Inc.
U.S. EPAOSRTI
Phone
215-814-3130
215-814-3315
215-814-3350
215-814-3183
410-990-4607
732-409-0344
732-409-0344
703-603-9017
Email
kuluj ian. norm@epa.gov
davies .kathvtgjepa. gov
Leonard.paul(@,epa. gov
schaul.peter(@,epa.gov
prich(@,geotransinc.com
rgreenwald(@,geotransinc.com
dsutton(@,geotransinc.com
Chang. steven(g),epa. gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Charlie Root
Affiliation
U.S. EPA Region 3 (RPM)
Phone
215-814-3193
Email
Root. charlie(@,epa. gov

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IMPLEMENTATION STATUS OF ALL RECOMMENDATIONS UNDER CONSIDERATION BUT NOT
PREVIOUSLY IMPLEMENTED
Recommendation
Recommendation
Reason
E-2.1 Verify Appropriate Discharge and Cleanup Standards for 1,4-Dioxane
Protectiveness
Implementation
Status
In progress
  Comments: The site team has not yet completed implementation of this recommendation but has initiated
  discussion with the State. Until the issue is resolved, the site team will likely assume that the most stringent
  MSC of 5.6 ug/L (based on potential impacts from discharge to surface water) will apply to both the cleanup
  and discharge limits. During the follow-up meeting, members of the ROET indicated that ground water
  standards for 1,4-Dioxane at other sites in Pennsylvania range from 5.6 ug/1 to 200 ug/1.  The highest observed
  ground water concentration in the last sampling round (May 2005) was 140 ug/1.
Recommendation
Recommendation
Reason
E-3.1 Streamline VOC Removal Processes
Cost Reduction
Im plementation
Status
Implemented
  Comments: The site team coordinated a pilot test of bypassing the tray aerator (e.g., relying on liquid phase
  GAC for treatment) with the most recent GAC replacement. The pilot lasted approximately 3 months and the
  site team has learned that liquid phase GAC will provide reliable treatment of the influent VOCs (excluding 1,4-
  Dioxane).  The site team has moved forward with adopting this treatment approach and estimates savings on the
  order of approximately $1,000 to $1,500 per month due to reduced electrical costs. The absence of the air
  stripper lias also reduced the fouling of the GAC. The site team anticipates that GAC usage will remain the
  same but that the changeouts will be easier. Savings may result from the easier GAC changeouts. Given the
  success of this pilot test and the simplicity of moving forward with this approach, the site team will not evaluate
  bypassing  the liquid phase GAC and relying on air stripping for VOC removal. The site team recognizes that
  both air stripping and GAC are ineffective at removing 1.4-Dioxane and that other treatment technologies will
  likely be required if the 1,4-Dioxane requires treatment.
Recommendation
Recommendation
Reason
E-5.1 Consider In-Situ Chemical Oxidation (Fenton's Reagent) Pilot Test in the
Source Area
Site Closeout
Implementation
Status
Implemented
  Comments: The site team is moving forward with a variation of this recommendation. To save cost and
  increase the likelihood that oxidant will be injected into the same fractures that are impacted, the site team will
  inject the oxidant into an old injection well (thought to be used for previous discharges of contamination by the
  facility) or into EW-4, which lias some of the highest TCE and 1,4-dioxane concentrations at the site. The
  evaluation team agrees with this approach. The site team has also decided to inject permanganate instead of
  Fenton's Reagent (which was suggested by the ROET).  Injections occurred in November, and overall cost for
  the work is approximately $90,000, including a total of five sampling events. The use of permanganate in place
  of Fenton's Reagent has both advantages and disadvantages.  An advantage is mat permanganate has a longer
  residence time in the subsurface, allowing injection from few locations to address a larger area. The use of
  permanganate is therefore one of the factors that has allowed the site team to apply in-situ chemical oxidation
  (along with the appropriate sampling) for approximately $90,000 compared to the higher estimate of $250,000
  to $300,000 for Fenton's Reagent.  However, permanganate is not a strong enough oxidant to remediate the 1,4-
  Dioxane, and a primary intent of the ROET's recommendation was to address the 1,4-Dioxane. This
  disadvantage is mitigated by recent findings by EPA that suggest an appropriate discharge standard for 1,4-
  Dioxane might be as high as 200 ug/L due to the relatively small effects on aquatic life.
        Key for recommendation numbers:
          * E denotes a recommendation from the original optimization evaluation
          * Fl, F2, etc. denote recommendations from the first, second, etc. follow-up meeting
          * The number corresponds to the number of the recommendation as stated in the optimization
              evaluation or follow-up summary where the recommendation was provided

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RECOMMENDATIONS PREVIOUSLY IMPLEMENTED OR THAT WILL NOT BE IMPLEMENTED
Recommendation
Recommendation
Reason
E-4.1 Add Influent Concentration Trend Graphs to the Monitoring Reports
Technical Improvement
Im plementation
Status
Implemented
Comments: The site team reports that these changes have been implemented.

Recommendation
Recommendation
Reason
E-4.2 Modify Discussion of 1,1,1-Trichloroethane hi the Reports
Technical Improvement
Im plementation
Status
Implemented
Comments: The site team reports that these changes have been implemented.
      Key for recommendation numbers:
        * E denotes a recommendation from the original optimization evaluation
        * Fl, F2, etc. denote recommendations from the first, second, etc. follow-up meeting
        • The number corresponds to the number of the recommendation as stated in the optimization
           evaluation or follow-up summary where the recommendation was provided
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP

   •  None.
NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP
      None.

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                  SUMMARY OF FOLLOW-UP #1
Site or System Name
Date of This Follow-Up Summary
Date of Follow-Up Meeting or Call
(Indicate if Meeting or Call)
AIW Frank/Mid-County Mustang Site
July 29, 2005
July 20, 2005 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Kathy Davies
Paul Leonard
Peter Rich
Rob Greenwald
Doug Sutton
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
GeoTrans, Inc.
Phone
215-814-3130
215-814-3315
215-814-3350
410-990-4607
732-409-0344
732-409-0344
Email
kuluj ian. norm@epa. gov
davies .kathvtgjepa. gov
Leonard.paul(@,epa. gov
prich(@,geotransinc.com
rgreenwald(@,geotransinc.com
dsutton(@,geotransinc.com
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Charlie Root
Bruce Rundell
Affiliation
U.S. EPA Region 3 (RPM)
U.S. EPA Region 3 (Hydro)
Phone
215-814-3193
215-814-3317
Email
Root. charlie(@,epa. gov
Rundell.bruce(@,epa.gov

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IMPLEMENTATION STATUS OF PREVIOUSLY IDENTIFIED RECOMMENDATIONS
Recommendation
Recommendation
Reason
2.1 Verify Appropriate Discharge and Cleanup Standards for 1,4-Dioxane
Protectiveness
Implementation
Status
In progress
 Comments: The site team lias not yet completed implementation of this recommendation but lias initiated
 discussion with the State. Until the issue is resolved, the site team will likely assume that the most stringent MSC
 of 5.6 ug/L will apply to both the cleanup and discharge limits.
Recommendation
Recommendation
Reason
3.1 Streamline VOC Removal Processes
Cost Reduction
Implementation
Status
Substantial Progress
 Comments: The site team coordinated a pilot test of bypassing the tray aerator (e.g., relying on liquid phase GAC
 for treatment) with the most recent GAC replacement. The pilot has lasted approximately 3 months and the site
 team lias learned that liquid phase GAC will provide reliable treatment of the influent VOCs (excluding 1,4-
 Dioxane). The site team is planning to move forward with adopting this treatment approach and is attempting to
 quantify the estimated savings. Given the success of this pilot test and the simplicity of moving forward with this
 approach, the site team will not likely evaluate bypassing the liquid phase GAC and relying on air stripping for
 VOC removal. The site team recognizes that both air stripping and GAC are ineffective at removing 1,4-Dioxane
 and that other treatment technologies will likely be required if the 1,4-Dioxane is not removed by the in-situ
 methods.
Recommendation
Recommendation
Reason
4.1 Add Influent Concentration Trend Graphs to the Monitoring Reports
Technical Improvement
Implementation
Status
Implemented
 Comments: The site team reports that these changes have been implemented.
Recommendation
Recommendation
Reason
4.2 Modify Discussion of 1,14-Trichloroethane in the Reports
Technical Improvement
Implementation
Status
Implemented
 Comments: The site team reports that these changes have been implemented.
  Recommendation
5.1 Consider In-Situ Chemical Oxidation (Fenton's Reagent) Pilot Test in the Source
Area
  Recommendation
       Reason
Site Closeout
Implementation
     Status
In progress
 Comments: The site team is moving forward with a variation of this recommendation. To save cost and increase
 the likelihood that oxidant will be injected into the same fractures that are impacted, the site team will inject the
 oxidant into an old injection well (thought to be used for previous discharges of contamination by the facility) or
 into EW-4, which has some of the highest TCE and 1,4-dioxane concentrations at the site.  The evaluation team
 agrees with this approach. The RPM expects a scoping document and cost estimate for die pilot test by die end of
 July and expects that field work may begin in September. The expected cost is substantially lower than that
 estimated by the evaluation team due to the use of existing wells (RPM indicated diey have requested $90,000 for
 this effort).

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OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP




   •  None.






NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP




   •  None.

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                                              UPDATED COST SUMMARY TABLE
Recommendation
Reason
Implementation
Status
Estimated
Capital Costs
($)
Actual Capital
Costs
(S)
Estimated Change
in Annual Costs
(S/yr)
Actual Change in
Annual Costs
(S/yr)
Original Optimization Evaluation Recommendations
2.1 Verify Appropriate
Discharge and Cleanup
Standards for 1,4-Dioxane
3 . 1 Streamline VOC Removal
Processes
4.1 Add Influent Concentration
Trend Graphs to the Monitoring
Reports
4.2 Modify Discussion of
1,1,1 -Trichloroethane in the
Reports
5.1 Consider In-Situ Chemical
Oxidation (Fenton's Reagent)
Pilot Test in the Source Area
Protectiveness
Cost Reduction
Technical
Improvement
Technical
Improvement
Site Closeout
In progress
Implemented
Implemented
Implemented
Implemented
$0
$0
$0
$0
$250,000 to
$300,000

$0*
<$500
<$500
$90,000
$0
($12,000 to
$20,000)*
$0
$0
Not quantified

($12,000 to $18,000)
<$500
<$500
To be determined
New or Updated Recommendations from Follow-up #1, July 20, 2005
None.






New or Updated Recommendations from Follow-up #2, November 7, 2005
None.






Costs in parentheses imply cost reductions.

* In the original evaluation, there were two options (GAC-only and stripping-only). The GAC-only option is the one the site team indicated they piloted and are
  implementing. After making the change to GAC-only, the RPM estimated an annual cost reduction from electricity usage of approximately $12,000 to $J 8,000 per year.
  Actual capital costs are noted as $0 because the site team indicated that the additional costs associated with conducting the pilot were offset by electrical savings.

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                          APPENDIX: A




   ARCHIVE OF TECHNICAL ASSISTANCE PROVIDED BY THE ROET






Note: Technical assistance items are provided in reverse chronological order.

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                          Technical Assistance Item #1
                          Provided December 30, 2005
Considerations for evaluating results ofin-situ chemical oxidation

   After modifying the treatment system to use only GAC for VOC removal, the annual
   O&M costs for the P&T system are approximately $230,000, excluding the costs of
   laboratory analyses covered by the CLP program.  A successful application ofin-situ
   chemical oxidation would substantially decrease the amount of time that this treatment
   system would need to operate, preferably allowing system shutdown before the site is
   transferred to the State in 2011. Therefore, the success ofin-situ chemical oxidation is
   closely related to the conditions that would allow the P&T operation to be discontinued.

   The P&T system likely only has an influence as far downgradient as EW-3 and EW-6
   and TCE appears to be the only contaminant that is consistently above cleanup  standards;
   therefore, evaluating the results ofin-situ chemical oxidation should be limited to
   reductions of TCE in EW-3, EW-6, and areas upgradient of these two wells.  Decreases
   in this upgradient area will eventually translate to decreases at downgradient locations.

    As a preliminary  analysis based on historical TCE concentrations, the ROET suggests
    the following example  decision tree. This is only a suggestion that has been prepared
    after a preliminary look at the post-injection sampling results. The site team may have
    more insight on potential decision points after a more comprehensive review of the data.

       •  If TCE concentration decreases of less than 25% are noted in OB-1I, MW-108A,
          MW-111, EW-4, and EW-5 after rebound, a second injection of permanganate
          will probably not be cost-effective and should probably not be conducted.

       •  If TCE concentration decreases of more than 25% but less than 90% are noted in
          the same wells after rebound, then in-situ chemical oxidation will likely
          substantially decrease the amount of time the system will need to operate, and a
          second, and possibly a third, injection of permanganate should be considered.

       •  If TCE concentration decreases of more than 90% are noted in the same wells
          after one or more injections and after rebound, then the maximum TCE
          concentration on site will be approximately 200 ug/L, and the site team should
          consider analyses (potentially including simple analytical modeling) to determine
          under what conditions the P&T system can be shutdown.  Given that there is a
          history of biodegradation and no immediate receptors downgradient of the site, it
          is possible that the P&T system could be shutdown in favor of MNA to
          ultimately achieve cleanup levels.

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           APPENDIX: B

BASELINE SITE INFORMATION SHEET AND
  OPTIMIZATION EVALUATION REPORT

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            Streamlined
   Optimization Evaluation Report

AIW Frank/Mid-County Mustang Site
        Exton, Pennsylvania

            EPA Region III
              July 29, 2005

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          SECTION 1:



BASELINE SITE INFORMATION FORM

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Date:
1/14/05
Filled Out By:     GeoTrans, Inc.
A. Site Location, Contact Information, and Site Status
1 . Site name 2. Site Location (city and State) 3. EPA Region
AIW Frank/Mid-County _ . „, „,..., , T „. m
~ , ^ Exton, W. Whiteland Twp., PA HI
Mustang l
4a. EPA RPM 5a. State Contact
Charlie Root Dave Ewald
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-3193 484-250-5725
4c. EPA RPM Email Address 5c. State Contact Email Address
Root.Charlie@epa.gov Dewald@State.pa.us
5. Is the ground water remedy an interim remedy or a final remedy? Interim | | Final IXI
6. Is die site EPA lead or State-lead with Fund money? EPA ^ State O

B. General Site Information
la. Date of Original ROD for Ground Water Remedy
09/29/1995
2a. DateofO&F
3/29/2001
3 . What is the primary goal of the P&T system
(select one)?
1 1 Contaminant plume containment
1 I Aquifer restoration
IXI Containment and restoration
1 I Well-head treatment
lb. Dates of Other Ground Water Decision Documents (e.g., ESD. ROD Amendment)
N/A
2b. Date for transfer to State
09/30/2011
4. Check those classes of contaminants that are
contaminants of concern at the site.
£3 VOCs (e.g., TCE, benzene, etc.)
D SVOCs (e.g., PAHs, PCP, etc.)
1 1 metals (e.g., arsenic, chromium, etc.)
IXI other 1,4-Dioxane (not official COC)
5. Has NAPL or evidence of NAPL been observed at the site? Yes I I No IXI
6. What is the approximate total pumping rate? 100 gpm
7. How many active extraction wells .
(or trenches) are there?
9. How many samples are collected
from monitoring wells or piezometers __
each year? (e.g., 40 if 10 wells are
sampled quarterly)
1 1 . What above-ground treatment processes are usec
IXI Air stripping
IXI Carbon adsorption (liquid phase only)
1 I Filtration
IXI Off-gas treatment
| 	 | Ion exchange
8. How many monitoring wells are -_
regularly sampled?
10. How many process monitoring samples
(e.g., extraction wells, influent, effluent, etc.) _ .
are collected and analyzed each year? (e.g., 24
if influent and effluent are sampled monthly)
(check all that apply)?
1 I Metals precipitation
I | Biological treatment
O UV/Oxidation
I | Reverse osmosis
O Other
12. What is the approximate percentage of system downtime per year? 10% |/\l 10 - 20% | | >20% | |

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C. Site Costs
1. Annual O&M costs
O&M Category
Labor: project management, reporting,
technical support
Labor: system operation
Labor: ground water sampling
Utilities: electricity
Utilities: other
Consumables (GAC, chemicals, etc.)
Discharge or disposal costs
Analytical costs
Other (parts, routine maintenance, etc.)
O&M Total
Actual Annual Costs
for FY03
$23,773
$69,122
$21,155
$16,156
$21,792
$35,387
$0
EPA CLP
$56,711
$244,096
Actual Annual Costs
forFY04
$29,909
$86,416
$31,845
$21,180
$14,824
$27,108
$3,803
EPA CLP
$45,894
$260,979
Projected Annual
Costs for FY05
$28,000
$80,000
$32,000
$22,000
$14,000
$25,000
$2,000
EPA CLP
$48,000
$251,000
The O&M total should be equal to the total O&M costs for the specified fiscal years, including oversight from
USAGE or another contractor. For costs that do not fit in one of the above cost categories, include them in the
"Other" category.  If it is not possible to break out the costs into the above categories, use the categories as best
as possible and provide notes in the following box.
2. Non-routine or other costs



Additional costs beyond routine O&M for the specified fiscal years should be included in the above spaces. Such
costs might be associated with additional investigations, non-routine maintenance, additional extraction wells, or
other operable units.  The total costs billed to the site for the specified fiscal years should be equal to the O&M
total plus the costs entered in item 2.
Notes on costs:

1.      All labor costs include direct, indirects, and fees for all activities and subcontractors
associated with the tasks.
2.      Electricity increased mainly due to the reduced downtime in FY04 and the FY04/FY05
costs are expected to continue but will be influenced by electricity rates.
3.      Other utilities include water, phones, propane gas, security services, mail, reproduction,
temp, utilities, etc.
4.      Consumables include carbon exchange services, equipment rental, travel expenses, etc.
5.      Other (part, routine maintenance, etc.) includes routine O&M subcontractor costs, well
maintenance services, etc.

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D. Five-Year Review
1. Date of the Most Recent Five-Year Review       N/A - Initial Syr Review - 11/08/2005
2. Protectiveness Statement from the Most Recent Five-Year Review
    I  |   Protective                              I   I  Not Protective

    |	|   Protective in the short-term                |	|  Determination of Protectiveness Deferred

3. Please summarize the primary recommendations in the space below
E. Other Information
If there is other information about the site that should be provided please indicate that information in the space
below. Please consider enforcement activity, community perception, technical problems to be addressed, and/or
areas where a third-party perspective may be valuable.
Residences near the site that have wells have been placed on public water.  Their wells have
not been abandoned so that they can continue to be monitored as part of the ground water
monitoring program. Three wells  are sampled annually. This sampling is included in the value
for item B.9 of this form.

1,4-Dioxane has been found in ground water at approximately 250 ug/L and in the influent at 8
to 10 ug/L.  No official discharge or cleanup standards have been applied to the  site  for this
contaminant.

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            SECTION 2:

STREAMLINED OPTIMIZATION EVALUATION
   FINDINGS AND RECOMMENDATIONS

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   Date of Evaluation Meeting:
  AIW Frank/Mid-County Mustang



December 15, 2004      Date of Final Report:       July 29, 2005
ROET MEMBERS CONDUCTING THE STREAMLINED OPTIMIZATION EVALUATION:
Name
Kathy Davies
Norm Kulujian
Peter Schaul
Peter Rich
Doug Sutton
Jean Balent (by phone)
Steve Chang (by phone)
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
U.S. EPAOSRTI
U.S. EPAOSRTI
Phone
215-814-3315
215-814-3130
215-814-3183
410-990-4607
732-409-0344
202-564-1709

Email
Davies.kathy(g),epa.gov
Kurujian.norm(g)epa.gov
schaul.peter(@,epa.gov
prich(@,geotransinc.com
dsutton(g)geotransinc.com
Balent.j ean@epa. gov
Chang. steve(@,epamail. epa. gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Charlie Root
Bruce Rundell
Vincent Ou
Kevin Kilmartin
Barbara Bloomfield
Tim Cherry
David Ewald
Ragesh Patel
Affiliation
U.S. EPA Region 3 (RPM)
U.S. EPA Region 3 (Hydro)
TetraTechNUS
TetraTechNUS
PADEP
PADEP
PADEP
PADEP
Phone
215-814-3193
215-814-3317
610-491-9688
610-491-9688
484-250-5788
484-250-5728
484-250-5725
484-250-5719
Email
Root.charlie(g),epa.gov
Rundell.bruce(@,epa.gov
ouv(@,ttnus.com
kilmartink(g),ttnus .com
BBloomfield(g),state.pa.us
TCherrv(@,state.pa.us
DEwaldtg.state .pa.us
RPatel(g),state.pa.us

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1.0    SIGNIFICANT FINDINGS BEYOND THOSE REPORTED ON SITE INFORMATION FORM

       The evaluation team observed an RPM who appears to be an effective manager of a complex
       site, making decisions based on a comprehensive understanding of the site that considers the
       hydrogeology, engineering, costs, and relationships with other entities.  The RPM appears to
       effectively utilize Regional technical resources (e.g., hydrogeologists), and Regional
       Management appears to be well informed regarding site progress. The observations and
       recommendations herein are not intended to imply a deficiency in the work of either the
       designers or operators, but are offered as constructive suggestions in the best interest of the EPA
       and the public.  Recommendations made herein obviously have the benefit of site
       characterization data and the operational data unavailable to the original designers.

       Findings beyond those reported on the site information form include the following:

       •   Downgradient residential wells (denoted by HW on report tables and figures) have all been
          disconnected and the residences placed on public water.  The wells are still accessible for
          sampling as monitoring wells. Three of them are sampled on an annual basis for VOCs.

       •   There are no concerns about new supply wells being installed in the body of the plume. The
          Chester County Health Department keeps track of wells and is aware of the plume.  EPA has
          annual or biannual meetings to keep the health department updated.

       •   Given that there are no downgradient receptors, the cleanup philosophy is to control and
          remediate the  source area while applying natural attenuation to the downgradient portion of
          the plume, which extends approximately 1,500 feet beyond the extraction wells. The
          maximum TCE concentration in this downgradient portion is approximately  100 ug/L (MW-
          112B), but most of the concentrations in this area are approximately 10 ug/L.

       •   Sampling indicates that 1,4-Dioxane is present in the source area at approximately 250 ug/L
          and in the treatment system influent at approximately 8 to 10 ug/L. No reduction in 1,4-
          Dioxane is expected through the treatment train, and the site team does not have a
          documented discharge limit for it.  For reference, the most stringent Pennsylvania Medium
          Specific Concentration (MSC) for 1,4-Dioxane is 5.6 ug/L.

       •   No formal capture zone analysis has been conducted. The karst geology makes it difficult to
          reliably determine ground water flow velocities and capture zones based on hydraulic
          gradients. The site team will rely on sampling results from dowgradient performance wells to
          evaluate capture. Concentrations that decrease to background would suggest complete
          capture. Concentrations that remain steady or increase would suggest incomplete capture.
          The P&T system has only operated for approximately 3 years; therefore, there are not enough
          data at this point to analyze capture.

       •   The total extraction rate is approximately 100 gpm from four bedrock extraction wells (EW-
          3, EW-4, EW-5, and EW-6) completed between 180 and 300 feet below ground  surface.
          Approximately 95  gpm is extracted from EW-6. EW-3 extracts about 5 gpm.
          Approximately 2 gpm is extracted from EW-4 and EW-5 combined. EW-4 is the extraction
          well with the highest TCE concentration. It was hydrofraced in 2003 to improve flow.

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       •   Between January 2004 and October 2004 (10 months) TCE influent concentrations ranged
          from 12 ug/L to 42 ug/L with an average concentration of approximately 29 ug/L. PCE and
          1,1,1-TCA influent concentrations were well below their respective MCLs (there is no
          discharge standard for either constituent). Given a flow rate of 100 gpm, this translates to
          TCE mass removal of approximately 12 to 13 pounds per year. The influent concentrations
          have decreased by 80% since start up in November 2000.

       •   The treatment system is designed for a capacity of 200 gpm and is operating at
          approximately half capacity. It consists of the following items:

          o   400-gallon equalization tank
          o   two parallel 25-micron bag filters
          o   one QED 24.4 tray aerator (which has two subunits arranged in parallel) with a 10 HP
              blower
          o   15-HP tray-aerator effluent pump
          o   eight parallel 10-micron bag filters
          o   two 5,000-pound liquid phase GAC units in series
          o   12-kW tray-aerator off-gas heater
          o   two 3,000-pound vapor phase GAC units in series
          o   discharge to either a pond for spray irrigation (not used) or to surface water

       •   The air strippers were designed for relatively low efficiency (approximately 90%) and
          efficiency is further hampered by calcium fouling.  The trays are being cleaned quarterly at
          which time the calcium deposits must be drilled and chipped  away in a process that requires
          2 days. Bag filters require replacement weekly and liquid phase GAC replacement is on an
          every 3 to 4 month frequency due to fouling/channelizing of the GAC (not contaminant
          loading).

       •   The site has effectively negotiated a reasonable arsenic discharge limit.  The original limit
          was lower than background concentrations.  With the help of the State the NPDES permit
          was modified accordingly.

       •   The contractor provides all site data in electronic format to EPA and PADEP. These data
          include all laboratory and field data in a Microsoft Access™  database designed by the
          Region, and all site maps are provided in CAD format.  These data are incorporated into an
          Intranet-based GIS system and used to track remedial progress.
2.0    RECOMMENDATIONS TO IMPROVE SYSTEM PROTECTIVENESS

   2.1    VERIFY APPROPRIATE DISCHARGE AND CLEANUP STANDARDS FOR 1,4-DioxANE

          Given that 1,4-Dioxane is present at concentrations up to 250 ug/L in ground water and is
          likely being discharged in the treatment plant effluent at approximately 8 to 10 ug/L, EPA
          and PADEP should work together to verify the appropriate discharge and cleanup standards
          for 1,4-Dioxane. PADEP has developed Medium Specific Concentrations (MSCs) for 1,4-

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          Dioxane that are specific to used and unused aquifers in residential and non-residential areas.
          The most stringent MSC for 1,4-Dioxane is 5.6 ug/L but another less stringent standard of 24
          ug/L might also apply.  Implementing this recommendation should not require immediate
          costs being directly assigned to the site, but may impact site closeout (discussed in Section
          5.1).
3.0    RECOMMENDATIONS TO REDUCE SYSTEM COST

   3.1    STREAMLINE VOC REMOVAL PROCESSES

          With designed efficiency of only 90% removal, the effluent from the tray-aerators has
          historically required polishing with liquid phase GAC to meet TCE discharge standards,
          especially given the potential for fouling due to calcium. However, influent concentrations
          are sufficiently low that TCE treatment could likely be accomplished with either the tray-
          aerators or the GAC (i.e., likely does not require both).  It is recommended that the site team
          further evaluate the following two options and implement the most promising one. The
          options are ordered below by greatest potential O&M savings without sacrificing
          effectiveness.

          •   Clean the tray aerators on a more frequent basis (perhaps biweekly or monthly) using a
              power washer and bypass the liquid phase GAC units. Overall, this approach should be
              less time consuming than the current approach and should not result in an increase in
              O&M labor costs. By keeping the tray aerator clean, the tray aerator efficiency will
              likely be sufficient for the site team to bypass or to eliminate polishing with liquid phase
              GAC. The site team could also consider sampling the effluent at the discharge point
              rather than directly from the effluent tank. With frequent cleaning of the tray aerator, the
              liquid phase GAC may no longer be needed to polish the air stripper effluent, and the
              liquid phase GAC replacement costs, which might be as high $15,000 to $20,000 per
              year, could be eliminated.

          •   Turn off the blower to the tray aerator and allow process water from the equalization tank
              to flow through the tray aerator without being aerated. Even in the absence of the
              aeration, the GAC will be sufficient for contaminant removal and will still likely need to
              be replaced due to fouling and channeling rather than contaminant loading. The bag
              filters should provide adequate protection of the GAC, especially in the  absence of
              aeration and the associated reduction in calcium precipitation. GAC replacement could
              likely continue at a frequency of once every three to four months.  This would likely
              reduce the electrical usage by approximately 85,000 kWh per year or more ($6,000 per
              year assuming an electrical rate of $0.07 per kWh).  This modification would also
              eliminate tray aerator cleaning, which is a two-day event every quarter (a savings of labor
              of approximately $6,000 per year).  Site visits by the RACs contractor as a result of
              alarms might also be decreased, resulting  in potential savings. Costs associated with
              replacing the vapor phase GAC would also be eliminated.

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4.0    RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT

   4.1    ADD INFLUENT CONCENTRATION TREND GRAPHS TO THE MONITORING REPORTS

          The monitoring reports in their current form are well done. They could be slightly improved
          by adding a trend graph for the influent concentration. The influent concentration has
          decreased substantially since operation began, it would be helpful to visualize the trend.
          Implementing this recommendation should not require any additional cost.

   4.2    MODIFY DISCUSSION OF I,!,I-TRICHLOROETHANE IN THE REPORTS

          The reports discuss in depth the plume and concentration trends for 1,1,1-Trichloroethane
          (1,1,1-TCA).  Although 1,1,1-TCA is a contaminant of concern for the site, all sampling
          results indicate that it is below the cleanup goal of 200 ug/L.  On the other hand, 1,1-
          Dichloroethene (1,1-DCE) is above standards but discussion is limited to a single bullet item
          under "Other VOCs".  It appears reasonable to greatly simplify the discussion of 1,1,1, TCA
          concentrations, including that discussion under "Other VOCs", removing 1,1,1-TCA plume
          maps from the report, and emphasizing the concentrations are below the cleanup standard.
          The discussion of 1,1-DCE appears appropriate. The extent of 1,1-DCE contamination is far
          less than the TCE contamination,  and it is clear that the TCE plume is the primary driver for
          remediation efforts and changes in TCE  concentrations are the primary indicators of remedial
          progress.


5.0    RECOMMENDATIONS To SPEED SITE CLOSEOUT

   5.1    CONSIDER IN-SITU CHEMICAL OXIDATION (FENTON' s REAGENT) PILOT TEST IN THE
          SOURCE AREA

          The evaluation team agrees with the site team that the source area at the site is relatively
          small and may be amenable to more aggressive source removal using in-situ chemical
          oxidation.  Successful source removal could result in the discontinuation of pump and treat if
          the remaining portion of the plume is allowed to naturally attenuate as per current practice.
          Most of the annual O&M costs would be eliminated, but some ground water monitoring (and
          the associated costs) would likely remain for several years. The presence of 1,4-Dioxane in
          the source area and treatment plant influent further justifies the use of aggressive source
          removal because the treatment plant may not be able to meet a 1,4-Dioxane discharge level
          without significant and expensive modifications.  It is therefore recommended that the source
          area be treated using Fenton's reagent. Unlike permanganate, Fenton's reagent is a strong
          enough oxidant to oxidize both TCE and 1,4-Dioxane. Fenton's reagent should be applied to
          the source area (in the area near EW-4 and OB-II) and perhaps a few locations between EW-
          4 and EW-5. During the pilot test, pumping from EW-4 and EW-5 should be discontinued.

          Prior to conducting the  pilot, the site team should determine criteria for evaluating the
          success of the pilot. The following should be considered when developing these criteria.

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          •  Is the concentration of contaminants in the source area greater than or less than the
             concentrations at MW-112B? The concentrations at MW-112B were sufficiently low to
             monitor (at least temporarily) rather than address by pump and treat.  It is reasonable to
             assume similar or lower concentrations in the source area would also not require
             continued pump and treat.

          •  Do concentrations downgradient of the Fenton's Reagent application decrease or remain
             the same over time? If they decrease, it is evidence that source removal has been
             sufficiently effective and may lead to discontinuing pump and treat.

          •  Have 1,4-Dioxane concentrations in the source area substantially decreased (by more
             than an order of magnitude)?

          •  Are 1,4-Dioxane concentrations downgradient of the Fenton's reagent application
             decreasing over time? When (or if) the pump and treat system is restarted, does the 1,4-
             Dioxane concentration decrease to at or near the Pennsylvania MSC of 5.6 ug/L, perhaps
             eliminating the need for enhancing the treatment system to address 1,4-Dioxane?

          Based on the success of the pilot study, additional applications (either as additional pilot tests
          or full-scale  applications) could be made if cost-effective.  The evaluation team notes that the
          cost of modifying the treatment system to treat 1,4-Dioxane and operating the modified
          system would be substantial and that the site team is encouraged to attempt other in-situ
          efforts if this initial application of Fenton's Reagent is not successful. As an approximate
          estimate, the evaluation team estimates that the costs of modifying the treatment system
          could require as much as $500,000 in capital expenses, and operating the system could
          increase by approximately $150,000 per year to a total annual O&M cost of $400,000 per
          year.

          The cost for  developing these criteria, writing a work plan, conducting the pilot test, and
          documenting the results should cost on the order of $250,000 to $300,000, including
          oversight by the site contractor and two rounds of follow-up  sampling from eight locations
          six months apart. This assumes up to 5 injection points are installed at 100 feet to 200 feet
          below ground surface and that two applications are  made.
PRIORITIZATION AND SEQUENCING OF RECOMMENDATIONS

Recommendation 2.1 (1,4-Dioxane standards) is an issue facing EPA and PADEP and is not necessarily
site-specific.  Therefore, EPA and PADEP can continue to work on this recommendation without using
site resources or interfering with implementation of the other recommendations.

Recommendation 3.1 (streamline VOC removal processes) should be implemented immediately. The
site team can choose which approach to attempt first: modifying the approach for tray aerator cleaning
or relying on GAC. The site team's choice would likely depend on the schedule for the next GAC
replacement and other site related factors.

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Recommendations 4.1 and 4.2 (regarding monitoring reports) should be implemented prior to the next
ground water monitoring report.

Work on the criteria and work plan for Recommendation 5.1 (in-situ chemical oxidation) should begin
in the first quarter of 2005, with the hope of conducting the pilot test at some point during calendar year
2005 (perhaps between October and December).

OTHER ACTION ITEMS

No other action items are provided.

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                                        Cost Summary Table
Recommendation
2.1 Verify Appropriate Discharge
and Cleanup Standards for 1,4-
Dioxane
3 . 1 Streamline VOC Removal
Processes
4. 1 Add Influent Concentration
Trend Graphs to the Monitoring
Reports
4.2 Modify Discussion Of 1,1,1-
Trichloroethane in the Reports
5 . 1 Consider In-Situ Chemical
Oxidation (Fenton's Reagent) Pilot
Test in the Source Area
Reason
Effectiveness
Cost Reduction
Technical
Improvement
Technical
Improvement
Site Closeout
Estimated
Additional
Capital Costs
($)
$0
$0
$0
$0
$250,000
to
$300,000
Estimated Change in Annual
Costs
($/yr)
$0
($12,000 to $20,000)
$0
$0
Unquantifiable decrease in
lifecycle costs
Costs in parentheses imply cost reductions.

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