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
-------
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
-------
Site Optimization Tracker:
AIW Frank/Mid-County Mustang Site
Exton, Pennsylvania
EPA Region III
December 30, 2005
-------
SECTION 1:
CURRENT SITE INFORMATION FORM
-------
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% | |
-------
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.
-------
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.
-------
SECTION 2:
FOLLOW-UP HISTORY AND SUMMARIES
Note: Follow-up summaries are provided in reverse chronological order and include updated
and/or new recommendations.
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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 $90,000 for
this effort).
-------
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
None.
NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP
None.
-------
UPDATED COST SUMMARY TABLE
Recommendation
Reason
Implementation
Status
Estimated
Capital Costs
($)
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.
-------
APPENDIX: A
ARCHIVE OF TECHNICAL ASSISTANCE PROVIDED BY THE ROET
Note: Technical assistance items are provided in reverse chronological order.
-------
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.
-------
APPENDIX: B
BASELINE SITE INFORMATION SHEET AND
OPTIMIZATION EVALUATION REPORT
-------
Streamlined
Optimization Evaluation Report
AIW Frank/Mid-County Mustang Site
Exton, Pennsylvania
EPA Region III
July 29, 2005
-------
SECTION 1:
BASELINE SITE INFORMATION FORM
-------
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% | |
-------
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.
-------
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.
-------
SECTION 2:
STREAMLINED OPTIMIZATION EVALUATION
FINDINGS AND RECOMMENDATIONS
-------
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
-------
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.
-------
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-
-------
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.
-------
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.
-------
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 $300,000, including
oversight by the site contractor and two rounds of follow-up sampling from eight locations
six months apart. This assumes up to 5 injection points are installed at 100 feet to 200 feet
below ground surface and that two applications are made.
PRIORITIZATION AND SEQUENCING OF RECOMMENDATIONS
Recommendation 2.1 (1,4-Dioxane standards) is an issue facing EPA and PADEP and is not necessarily
site-specific. Therefore, EPA and PADEP can continue to work on this recommendation without using
site resources or interfering with implementation of the other recommendations.
Recommendation 3.1 (streamline VOC removal processes) should be implemented immediately. The
site team can choose which approach to attempt first: modifying the approach for tray aerator cleaning
or relying on GAC. The site team's choice would likely depend on the schedule for the next GAC
replacement and other site related factors.
-------
Recommendations 4.1 and 4.2 (regarding monitoring reports) should be implemented prior to the next
ground water monitoring report.
Work on the criteria and work plan for Recommendation 5.1 (in-situ chemical oxidation) should begin
in the first quarter of 2005, with the hope of conducting the pilot test at some point during calendar year
2005 (perhaps between October and December).
OTHER ACTION ITEMS
No other action items are provided.
-------
Cost Summary Table
Recommendation
2.1 Verify Appropriate Discharge
and Cleanup Standards for 1,4-
Dioxane
3 . 1 Streamline VOC Removal
Processes
4. 1 Add Influent Concentration
Trend Graphs to the Monitoring
Reports
4.2 Modify Discussion Of 1,1,1-
Trichloroethane in the Reports
5 . 1 Consider In-Situ Chemical
Oxidation (Fenton's Reagent) Pilot
Test in the Source Area
Reason
Effectiveness
Cost Reduction
Technical
Improvement
Technical
Improvement
Site Closeout
Estimated
Additional
Capital Costs
($)
$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.
------- |