Final Report
Pilot Region-Based Optimization
Program for Fund-Lead Sites
in EPA Region 3
Site Optimization Tracker:
Crossley Farm Superfund Site
Hereford and Washington Townships
Berks County, Pennsylvania
EPA Region III
-------
Solid Waste and EPA 542-R-06-006b
Emergency Response December 2006
(5102P) www.epa.gov
Pilot Region-Based Optimization Program
for Fund-Lead Sites in EPA Region 3
Site Optimization Tracker:
Crossley Farm Superfund Site
Hereford and Washington Townships
Berks County, Pennsylvania
EPA Region III
-------
Site Optimization Tracker:
Crossley Farm Superfund Site
Hereford and Washington Townships
Berks County, 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
Crossley Farm Huffs Church, Berks County, PA 3
4a. EPA RPM 5a. State Contact
Roy Schrock Asuqua Effiong
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-3210 717-705-4853
4c. EPA RPM Email Address 5c. State Contact Email Address
schrock.roy@epa.gov aeffiong@state.pa.us
5. Is the ground water remedy an interim remedy or a final remedy? Interim [XI Final I I
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
September 28, 2001 (OU #2)
2a. Date of Projected O&F
N/A - facility not yet constructed
3 . What is the primary goal of the designed P&T
system (select one)?
1 I Contaminant plume containment
I | Aquifer restoration
IXI Containment and restoration
I | Well-head treatment
lb. Dates of Other Ground Water Decision Documents (e.g., ESD. ROD Amendment)
- June 30, 1997 home treatment units (OU #1)
- June 26, 2004 (ESD for OU #2)
- 2006 expected OU #2 ROD Amendment
2b. Date for Projected Transfer to State
N/A - facility not yet constructed
4. Check those classes of contaminants that are
contaminants of concern at the site.
^1 VOCs (e.g., TCE, benzene, etc.)
D SVOCs (e.g., PAHs, PCP, etc.)
1 I metals (e.g., arsenic, chromium, etc.)
I | other
5. Has NAPL or evidence of NAPL been observed at the site? Yes 1X1 No | |
6. What is the designed total pumping rate? 100+ gpm
7. How many extraction wells
(or trenches) are there based on ~6
design?
9. How many samples are proposed to
be collected from monitoring wells or TRT4
piezometers each year? (e.g., 40 if 10
wells are sampled quarterly)
1 1 . What above-ground treatment processes are prof
IXI Air stripping
1 I Carbon adsorption (liquid phase only)
I | Filtration
|/\l Off-gas treatment
I | Ion exchange
8. How many monitoring wells are «„ .~
proposed to be regularly sampled?
10. How many process monitoring samples
(e.g.. extraction wells, influent, effluent, etc.)
are proposed to be collected and analyzed TBD
each year? (e.g., 24 if influent and effluent
are sampled monthly)
>osed (check all that apply)?
I | Metals precipitation
1 I Biological treatment
O UV/Oxidation
I | Reverse osmosis
O Other
12. What is the anticipated percentage of system downtime per year? 10% O 10-20%O >20% | |
-------
C. Site Costs
1. Projected 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
Projected Annual Costs for
System Start-up (e.g., year 1)
TBD
Projected Annual Costs for
Steady-State Operation
(e.g., after year 1)
TBD
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.
3. Estimated costs for system design
and/or construction
Notes on costs:
The site team decided on the course of action for a ROD Amendment near the end of this
project and did not have time to estimate costs for the proposed remedy. As such, reporting on
the costs is premature at this point.
-------
D. Five-Year Review
1. Date of the Most Recent Five-Year Review September 24, 2004
2. Protectiveness Statement from the Most Recent Five-Year Review
I | Protective IXI Not Protective
IXI Protective in the short-term Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
Protectiveness statement:
The remedy at OU#1 is protective of human health, and exposure pathways that could result in
unacceptable risks to human health are being controlled. To date, forty-eight residential point
of entry carbon treatment units have been installed to provide clean drinking water to homes
that have been affected by the site contamination. EPA will continue to conduct a semi-annual
monitoring program to identify if any additional residences are being affected by the
contamination. If so, point of entry carbon treatment units will be installed. New residential
construction will be tested by EPA, but if point of entry carbon treatment units are required,
the owner will be responsible for installation.
Long-term Protectiveness
In order for the site to be protective of the environment in the long-term, the ground water
contamination needs to be controlled and remediated. The interim ROD for OU#2 requires a
pump and treat action to cleanup the "hot-spot" source areas. This ROD has not yet been
implemented. A final remedy for the site-wide ground water contamination is expected to be
developed in a subsequent ROD.
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.
By the end of the optimization pilot project, the site team had decided to modify the remedy
discussed in the OU#2 ROD from a source control P&T system that contained the plume at the
100,000 ug/L contaminant contour to a downgradient P&T system that would contain a larger
portion of the plume. The RPM will draft the ROD in 2006 and will likely consider including
the potential for source area pumping in addition to the downgradient/containment pumping.
-------
SECTION 2:
FOLLOW-UP HISTORY AND SUMMARIES
INCLUDING
NEW AND UPDATED RECOMMENDATIONS
-------
FOLLOW-UP HISTORY
Date of Original Optimization Evaluation
February 8, 2005 (Evaluation Meeting)
July 20, 2005 (Additional Meeting)
September 14, 2005 (Site Visit)
October 26, 2005 (Final Report)
Meeting Date
November 7, 2005
Report Date
Item
December 30, 2005 Follow-Up #1 (conducted as part of pilot project)
Follow-Up #2
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
* Note: Two follow-up meetings were scheduled for this site, but the first scheduled follow-up meeting was used to
discuss the draft optimization report and arrange a site visit for both the site team andROET. Therefore, the second
scheduled follow-up meeting is the first true follow-up for this site.
-------
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)
Crossley Farm Superfund Site
December 30, 2005
November 7, 2005 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Peter Schaul
Kathy Davies
Paul Leonard
Eric Johnson
Brian Nishitani
Linda Dietz
Peter Rich
Rob Greenwald
Doug Sutton
Steven Chang
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
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
215-814-3183
215-814-3315
215-814-3350
215-814-3313
215-814-2675
215-814-3195
410-990-4607
732-409-0344
732-409-0344
703-603-9017
Email
kuluj ian. norm@epa. gov
schaul.peter(@,epa.gov
davies .kathvtgjepa. gov
leonard.paul(@,epa. gov
johnson.eric(@,epa.gov
nishitani.brian(@,epa. gov
dietz.linda(@,epa.gov
prich(g)geotransinc.com
rgreenwald@geotransinc.com
dsuttontgigeotransinc.com
chang. steven(@,epa. gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Roy Schrock
Affiliation
U.S. EPA Region 3
Phone
215-814-3210
Email
schrock.rovtg.epa.gov
-------
IMPLEMENTATION STATUS OF ALL RECOMMENDATIONS UNDER CONSIDERATION BUT NOT
PREVIOUSLY IMPLEMENTED
Recommendation
Recommendation
Reason
E-2.1 Design/Install Downgradient Migration Control System
Protectiveness
Implementation
Status
In progress
Comments: The site team and ROET agreed on a suitable location for a downgradient P&T system, and die RPM
is proceeding with preparation of a ROD Amendment stating the change in location of the P&T system from the
source area to a downgradient location. The RPM and Regional counsel are also looking at the current feasibility-
study to determine if it is adequate for the ROD Amendment or if additional analysis will be needed. In addition
to specifying downgradient P&T, the ROD will be call for the following items:
• a treatment system that uses air stripping, rather than UV/oxidation, as the primary technology for
treating VOCs
• discharge of treated water to surface water
• a pump test in the source area that could be fed into the proposed downgradient treatment system
Recommendation
Recommendation
Reason
E-2.2 Vapor Intrusion Investigation
Protectiveness
Implementation
Status
In progress
Comments: The site team is working with the Regional laboratory in Fort Meade to conduct a vapor intrusion
study. The team from Fort Meade is putting together the work plan. Approximately 50 homes lie over the plume,
and the study will evaluate those homes that are located above TCE concentrations of 10 ug/L or more
(approximately 20 homes). The evaluation will likely take place in early winter. The ROET encouraged the site
team to look at subslab sampling rather than indoor air samples, and to follow sampling protocols established at
other sites.
Recommendation
Recommendation
Reason
E-4.1 Consideration of Aggressive Source Remediation Technologies
Site Closeout
Implementation
Status
Under Consideration
Comments: The ROET has suggested that the site consider alternative technologies as a routine course of action
once the plume is contained. The team has indicated they intend to keep source area remediation as a component
of the remedy, and they plan to do further testing of alternatives (see further discussion under "New or Updated
Recommendations from This Follow-Up").
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
None.
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
None other than those highlighted above.
NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP
1. Reconsider parameters of source area pump test
The site team is planning a source area pump test to determine the concentrations that
might be present under pumping conditions. The RPM noted the test might include
pumping from six extraction wells at a total of 40 gpm for six months. Prior to
conducting the test, vaults for each of the already completed extraction wells would be
constructed with necessary controls. This is a large scale pump test, and the costs may
outweigh the benefits since designing and conducting the pump test would be similar in
designing and installing a source area P&T system.
The ROET suggests that, for long-term source area extraction, contaminated water from
the source area be fed to the proposed downgradient treatment system after it is built.
The amount of source area water can be adjusted based a number of parameters,
including the treatment system capacity, the treatment system design concentration, the
flow rate and influent concentrations from the downgradient extraction system, and the
flow rate and concentrations from the source area extraction system. Under this scenario,
pumping from the source area would likely be lower than 40 gpm and could be adjusted
accordingly. The ROET therefore suggests a two-week pump test in the source area, at a
lower flow rate, to get an improved understanding of the flow rate and concentrations
that would be blended with the water from the downgradient extraction system. This
type of short-term, low-rate test could potentially be performed in advance of designing
and constructing the downgradient system. Based on this information and information
from pump tests in the location of the downgradient extraction system, the site team
could design the downgradient extraction system accordingly. A reasonable result of the
source area pump test may be that the site team "over-designs" the treatment system for
the downgradient extraction system by selecting the "next biggest" air stripper to
accommodate some additional flow from the source area. This approach with a reduced-
scope pump test should be significantly lower in cost than that planned by the site team
and should provide the site team with useful information for designing the downgradient
treatment system. The potential cost savings associated with this reduced-scope
approach are difficult to estimate but might be $225,000 or more (assuming a cost of
$75,000 for a two-week pump test and perhaps $300,000 to $500,000 for the six month
pump test).
-------
2. Use subslab sampling for the vapor intrusion evaluation
It is recommended that the site team initiate the vapor intrusion evaluation by conducting
subslab sampling at the target residences rather than conducing indoor air sampling. A
number of residential activities could lead to false positive results from indoor air
sampling. By beginning with subslab sampling, the site team can first establish a link
between the ground water contamination and vapor contamination at the target residence.
While subslab sampling is being conducted, the homes should be evaluated for potential
preferential flow paths that may facilitate vapor intrusion. If subslab sampling results in
elevated vapor concentrations at some residences, the site team could then return to those
residences to conduct indoor air sampling, using appropriate protocols and sampling for
specific contaminants of concern. These considerations will likely have little effect on
the overall cost of the vapor intrusion evaluation.
-------
Updated Cost Summary Table
Recommendation
Reason
Implementation
Status
Estimated
Capital Costs
($)
Actual Capital
Costs
($)
Estimated Change
in Annual Costs
($/yr)
Actual Change in
Annual Costs
(S/yr)
Original Optimization Evaluation Recommendations
2.1 Design/Install
Downgradient Migration
Control System
2.2 Vapor Intrusion
Investigation
4. 1 Consideration of ISCO,
Source Area Pumping or
Alternative Technology
Protectiveness
Protectiveness
Site Closeout
In progress
In progress
Under
Consideration
Not quantified
$30,000
Not quantified
Not quantified
$0
Not quantified
New or Updated Recommendations from Follow-up #1, November 7, 2005
1 . Reconsider parameters of
source area pump test
2. Use subslab sampling for the
vapor intrusion evaluation
Cost Reduction
Cost Reduction
($225,000)
$0
$0
$0
Costs in parentheses imply cost reductions.
-------
APPENDIX: A
ARCHIVE OF TECHNICAL ASSISTANCE PROVIDED BY THE ROET
Note: Technical assistance items are provided in reverse chronological order.
-------
Technical Assistance Item #1
Prepared December 30, 2005
The ROET visited the site with the site team on September 14, 2005 and revised the draft
optimization evaluation report accordingly. The findings from the site visit were included in the
revised optimization evaluation report submitted on October 26, 2005. Therefore, this technical
assistance item is only included to document the site visit in the site's technical assistance
archive.
-------
APPENDIX: B
BASELINE SITE INFORMATION SHEET AND
OPTIMIZATION EVALUATION REPORT
-------
Streamlined
Optimization Evaluation Report
Crossley Farm Superfund Site
Hereford and Washington Townships
Berks County, Pennsylvania
EPA Region III
October 26, 2005
-------
SECTION 1:
BASELINE SITE INFORMATION FORM
-------
Date:
10/26/05
Filled Out Bv: GeoTrans
A. Site Location, Contact Information, and Site Status
1. Site name 2. Site Location (city and State) 3. EPA Region
Crossley Farm Huffs Church, Berks County, PA 3
4a. EPA RPM 5a. State Contact
Roy Schrock Asuqua Effiong
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-3210 717-705-4853
4c. EPA RPM Email Address 5c. State Contact Email Address
schrock.roy@epa.gov aeffiong@state.pa.us
5. Is the ground water remedy an interim remedy or a final remedy? Interim [XI Final I I
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
September 28, 2001 (OU #2)
2a. Date of Projected O&F
N/A - facility not yet constructed
3 . What is the primary goal of the designed P&T
system (select one)?
I | 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)
June 30, 1997 home treatment units (OU #1)
June 26, 2004 (ESD for OU #2)
2b. Date for Projected Transfer to State
N/A - facility not yet constructed
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.)
I | metals (e.g., arsenic, chromium, etc.)
1 I other
5. Has NAPL or evidence of NAPL been observed at the site? Yes IXI No | |
, „.. . , , . , , „ 40 gpm, design # for 100
6. What is the designed total pumping rate / ,
ppm plume
7. How many extraction wells
(or trenches) are there based on 6
design?
9. How many samples are proposed to
be collected from monitoring wells or r^^y^
piezometers each year? (e.g., 40 if 10
wells are sampled quarterly)
1 1 . What above-ground treatment processes are prop
1 I Air stripping
1 1 Carbon adsorption (liquid phase only)
1 I Filtration
1 1 Off-gas treatment
1 I Ion exchange
8. How many monitoring wells are - „ . „
proposed to be regularly sampled?
10. How many process monitoring samples
(e.g.. extraction wells, influent, effluent, etc.)
are proposed to be collected and analyzed TBD
each year? (e.g., 24 if influent and effluent
are sampled monthly)
>osed (check all that apply)?
1 I Metals precipitation
1 1 Biological treatment
£3 UV/Oxidation
| | Reverse osmosis
IXI Other oxidation process
12. What is the anticipated percentage of system downtime per year? 10% O 10-20%O >20% I I
-------
C. Site Costs
1. Projected 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
Projected Annual Costs for
System Start-up (e.g., year 1)
TBD
Projected Annual Costs for
Steady-State Operation
(e.g., after year 1)
TBD
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.
3. Estimated costs for system design
and/or construction
Notes on costs:
The actual nature of the system to be constructed is not yet finalized. As such, reporting on the
costs is considered premature. However, it is noted here that the ROD treatment process
included air stripping, vapor treatment with GAC, and reinjection of treated water, and the July
2004 ESD changed the primary treatment method to advanced oxidation (PhotoCat). Based on
the ROD and ESD, the capital cost was expected to be on the order of $3.5 million, and the
present worth of the remedy was expected to be on the order of $8.65 million (ROD) or $6.50
million (ESD)
-------
D. Five-Year Review
1. Date of the Most Recent Five-Year Review September 24, 2004
2. Protectiveness Statement from the Most Recent Five-Year Review
I | Protective IXI Not Protective
IXI Protective in the short-term Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
Protectiveness statement:
The remedy at OU#1 is protective of human health, and exposure pathways that could result in
unacceptable risks to human health are being controlled. To date, forty-eight residential point
of entry carbon treatment units have been installed to provide clean drinking water to homes
that have been affected by the site contamination. EPA will continue to conduct a semi-annual
monitoring program to identify if any additional residences are being affected by the
contamination. If so, point of entry carbon treatment units will be installed. New residential
construction will be tested by EPA, but if point of entry carbon treatment units are required,
the owner will be responsible for installation.
Long-term Protectiveness
In order for the site to be protective of the environment in the long-term, the ground water
contamination needs to be controlled and remediated. The interim ROD for OU#2 requires a
pump and treat action to cleanup the "hot-spot" source areas. This ROD has not yet been
implemented. A final remedy for the site-wide ground water contamination is expected to be
developed in a subsequent ROD.
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.
Based on the ROD for OU #2 which documents the regional ground water contamination at the
Site, EPA initiated an OU #3 Remedial Design, which is a pilot test evaluation of in-situ
chemical oxidation in the "hot spot" area. Based on the OSE report recommendations, a new
remedy concept with pumping further downgradient than was previously planned in the
ROD/BSD for OU #2 may be considered. That revised remedy concept would likely require
an additional BSD if it were to be implemented.
-------
SECTION 2:
STREAMLINED OPTIMIZATION EVALUATION
FINDINGS AND RECOMMENDATIONS
-------
Site Name: Crossley Farm Superfund Site
Date of Report: October 26, 2005
ROET MEMBERS CONDUCTING THE STREAMLINED OPTIMIZATION EVALUATION:
Name
Norm Kulujian
Kathy Davies
Peter Rich
Rob Greenwald
Steve Chang
Jean Balent (by phone)
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
U.S. EPAOSRTI
U.S.EPAOSRTI
Phone
215-814-3130
215-814-3190
410-990-4607
732-409-0344
202-564-1709
Email
kuluj ian. norm@epa. gov
davies .kathy(@,epa. gov
prichfg.geotransinc.com
rgreenwald@geotransinc.com
chang.steve(@,epamail.epa.gov
balent.j ean@epa. gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Roy Schrock
Bernice Pasquini
Bruce Rundell
Affiliation
U.S. EPA Region 3 (RPM)
U.S. EPA Region 3 (Hydro)
U.S. EPA Region 3 (Hydro)
Phone
215-814-3210
215-814-3326
215-814-3317
Email
Schrock. roy(@,epa. gov
pasquini.bernicetg.epa.gov
Rundell.bruce(@,epa.gov
The original meeting associated with the optimization evaluation for this site was conducted on
February 8, 2005 at the Region III building in Philadelphia. Discussions pertaining to an
original draft optimization evaluation report were conducted on July 20, 2005 at the Region III
building in Philadelphia. During those discussions, it was decided that a revised optimization
evaluation report would be prepared after a site visit was conducted. This site visit was
conducted on September 14, 2005. The individuals listed above were all present for the site
visit, with the exception of Jean Balent and Steve Chang. There were also additional participants
and observers at the site visit from EPA Region III, site contractors, and GeoTrans.
-------
1.0 SIGNIFICANT FINDINGS BEYOND THOSE REPORTED ON SITE INFORMATION FORM
The site is located on a hilltop with steep slopes to the west and the south. There were
several contaminant source areas at the site from disposal in the 1960s and 1970s.
These source areas include the borrow pit, the EPIC (Environmental Photograph
Information Center) Pit area, and potentially a former quarry. In 1998 approximately
1,200 drums and 15,000 tons of contaminated soil were removed from the EPIC pit
area. Contaminated soil is not thought to be a significant continuing source of ground
water contamination because bedrock is close to the surface and dumping at the source
areas likely allowed quick migration of the solvents into the bedrock
In 1983, odors in residential well water were observed and investigation was started.
At that time 8 private wells were found to be impacted, with six at TCE levels above
200 ug/1 and a maximum of 8,500 ug/1. By 1987, 15 POET systems were installed at
nearby residences.
. The ground water contamination reaches deep bedrock (up to 400 feet below ground
surface). The contaminant plume is extensive, approximately 2 miles long.
Contaminant levels over 1 mg/1 TCE emanate from multiple source areas and combine
to form the long plume. At the time of the RI (1999), contaminant levels above 10 mg/1
were present over an area about 1,000 feet long and 500 feet wide.
. EPA currently operates about 48 POETS in the area. There are no current plans to
extend a potable water line into the area. EPA samples about 120 private wells and
springs on a semiannual frequency.
The site remedial plan described in the ROD, and subsequent plans including the Basis
of Design report, described a source area P&T system extracting water within the
delineated area of 100,000 ug/1 TCE. The ROD treatment process included air
stripping, vapor treatment with GAC, and reinjection of treated water. The July 2004
ESD changed the primary treatment method to advanced oxidation (PhotoCat). Based
on the ROD and ESD, the capital cost was expected to be on the order of $3.5 million,
and the present worth of the remedy was expected to be on the order of $8.65 million
(ROD) or $6.50 million (ESD).
The P&T system proposed in the ROD/ESD for OU2 has been on hold, and in-situ
chemical oxidation (ISCO) with potassium permanganate has been tested on a small
scale. The results of the ISCO test have proven difficult to interpret.
. The primary objective stated in the OU2 ROD was to contain contamination in the
fractured bedrock aquifer at the site and reduce contamination in the aquifer and
surface water springs to MCLs or below. The ROD states that discharge standards for
the P&T system and the cleanup standards for the site are both MCLs (5 ug/1 for TCE).
Since the ROD, additional residential wells have been impacted, but these wells are still
within the confines of the RI delineated contaminant plume (i.e., there is no indication
the extent of the plume has expanded).
-------
2.0 RECOMMENDATIONS TO IMPROVE SYSTEM PROTECTIVENESS
2.1 DESIGN/INSTALL A MIGRATION CONTROL SYSTEM AND A TREATMENT PLANT
DOWNGRADIENT OF THE INTERIM SYSTEM PREVIOUSLY PLANNED FOR OU #2
The optimization team believes that the active treatment of the 100,000 ug/1 TCE
plume near the borrow pit area, which is the planned interim remedy as per the
ROD/BSD for OU2, should not be the initial focus of an interim or final remedy.
Instead, the optimization team initially recommended that the initial focus should be
on designing and installing ground water extraction wells and a ground water treatment
plant (air stripping with discharge to surface water) further downgradient. This was
discussed with the site team during a meeting on July 20, 2005, and after further
discussions with the site team during the site visit on September 14, 2005, there
appeared to be agreement that this approach had merit.
Based on discussions during the site visit, there appeared to be consensus that
extraction wells could be located along Airport Road (between the West Branch of
Perkiomen Creek and Dale Road), and along Dale Road between Airport Road and
Dairy Lane (perhaps extending just east of Dairy Lane). This is illustrated on Figure
1. This is downgradient of the borrow pit area (the extraction location associated with
the ROD/BSD for OU2), but more upgradient that than the extraction area originally
suggested by the optimization team. A treatment plant could be built in the vicinity
of the intersection of Airport Road and Dale Road, with discharge of treated water to
the West Branch of Perkiomen Creek.
Benefits associated with this general recommendation include the following:
• The strategy in the ROD/BSD for OU2 only contains the 100,000 ug/1 contour
for TCE as an interim remedy. That would still allow for extremely high
concentrations of TCE to remain outside of the contained area until a final
remedy was established, which decreases the potential for restoration of
ground water, springs, and surface water downgradient of the extraction
system. However, the approach suggested herein would place initial focus on
containing a much larger area. Based on Figures 4 and 5 of the OU2 ROD,
TCE concentrations near the recommended extraction locations were closer to
1,000 ug/1 rather than 100,000 ug/1. Therefore, pumping in the locations
recommended herein would leave much lower contaminant concentrations
(and much lower contaminant mass) outside of the contained area. This
increases the protectiveness of the initial action, and increases the likelihood
for restoration of ground water, springs, and surface water downgradient of
the extraction system.
The high TCE concentrations anticipated from extraction in the borrow pit
area apparently caused considerable concern during the design process,
resulting in an ESD for the treatment process (change from air stripping to UV
oxidation). A system located further downgradient will have lower influent
-------
concentrations, such that air stripping can definitely be utilized. This will cost
less money to design, implement, and operate.
• A treatment system located near the borrow pit area, as envisioned in the
ROD/BSD for OU2, did not allow an option for discharging the treated water
to surface water. Therefore, injection or infiltration of treated water would be
required, and this significantly increases the likelihood of operational
difficulties due to fouling and/or inability to infiltrate an appropriate rate of
treated water. It also requires land to be utilized for recharge, and creates
potential for NAPL to be mobilized by the infiltrated water. A system located
further downgradient, as recommended herein, will have the potential for
treated water to be discharged to surface water (i.e., to the West Branch of
Perkiomen Creek).
The Region III hydrogeologists indicated during the site visit that the geology
in the vicinity of the extraction locations recommended herein is likely more
favorable for achieving high extraction rates, relative to the borrow pit area.
(Note that a detailed review of the very complex geology at this site to
determine if this assertion is likely correct is beyond the scope of this
optimization evaluation).
• While ISCO may prove potentially viable for mass removal in focused areas,
the optimization team believes ISCO cannot provide the plume containment
indicated as the primary ROD objective. Furthermore, the effectiveness of
ISCO may be limited if there are large DNAPL pools, which is likely the case.
The optimization team believes the extraction and treatment approach
suggested herein is preferable to an ISCO-only approach. Once containment
of the downgradient plume is demonstrated, source area in-situ alternatives
could be further considered.
If this recommendation is implemented, an BSD or a ROD amendment will be
required. The specific number of wells, locations of wells, and well rates would
require detailed hydrogeologic analysis that is beyond the scope of this evaluation.
This may require drilling of test wells, aquifer testing, and perhaps modeling. Due to
the complicated geology at this site, these efforts will require the site-specific
geology expertise of site contractors and EPA hydrogeologists. Because there are
many site-specific factors associated with the complex geology and site access, costs
for these design efforts have not been quantified.
2.2 VAPOR INTRUSION
Springs SW-10, SW-11, SW-13, and SW-15 are reported to have TCE concentrations
around 200 ug/1 in the OU2 ROD. This indicates that shallow ground water has
similar or higher concentrations. The impacted shallow ground water is near
residences. The optimization team did not find consideration of a vapor intrusion
pathway in the documents reviewed. The site team should consider vapor sampling
for VOCs in residences located above impacted shallow ground water. Assuming
-------
that sampling of 10 residences is required, we estimate a cost of $30,000 including a
brief work plan and report.
3.0 RECOMMENDATIONS TO REDUCE COST
None, this is not an operating system.
4.0 RECOMMENDATIONS TO SPEED SITE CLOSEOUT
4.1 CONSIDERATION OF AGGRESSIVE SOURCE REMEDIATION TECHNOLOGIES
Once hydraulic containment is established for the downgradient plume, source
removal options should once again be considered. However, the optimization team
cautions against expenditure on any source removal technology without a clear
understanding of how the technology will hasten progress to site closure and without
guarantees of performance from vendors. If the application of a technology will
remove mass but not speed up site cleanup (because significant mass still remains as
a continuing source of dissolved ground water impacts), then implementing that
technology is of questionable value. Pilot testing should only be performed on
aggressive source remediation technologies after an evaluation has been performed to
determine that scale-up to full-scale implementation is feasible from a cost
perspective.
PRIORITIZATION AND SEQUENCING OF RECOMMENDATIONS
As discussed above, the downgradient migration control system design and construction should
take precedence over continued evaluation of source removal options. Vapor intrusion
investigations, if applicable based on residence locations, should be a high priority.
OTHER ACTION ITEMS
None
-------
Cost Summary Table
Recommendation
2.1 Design/Install a Migration
Control System and a Treatment
Plant Downgradient of the
Interim System Previously
Planned for OU #2
2.2 Vapor Intrusion
Investigation
4 . 1 Consideration of
Aggressive Source Remediation
Technologies
Reason
Protectiveness
Protectiveness
Site Closeout
Priority
(High/Other)
High
High
Estimated
Additional
Capital Costs
($)
Not quantified*
$30,000
(unknown)
Estimated
Change in
Annual Costs
($/yr)
Not quantified*
$0
Costs in parentheses imply cost reductions.
*Given that an operating system does not exist yet, and the recommended extraction and treatment system is only
conceptual at this point, potential changes in capital and annual costs have not been quantified.
-------
FIGURES
-------
Conceptual
Location
Recommended for
Extraction Wells
NOTE:
TCE CONCENTRATIONS REPORTED
IN
LEGEND
A - MONITORS WELL LOCATION
G - RESIDENTIAL WELL LOCATION
1500
SCALE IN FEET
3000
TCE CONCENTRATIONS
IN
DEEP GROUNDWATER
CROSSLEY FARM
HEREFORD TOWNSHIP. BERKS COUNTY, PA
OU2 ROD
FIGURE 5
Figure 1: Conceptual Location Recommended for Extraction Wells
------- |