Final Report
Pilot Region-Based Optimization
Program for Fund-Lead Sites
in EPA Region 3
Site Optimization Tracker:
Croychem Superfund Site
Berks County
Boyertown, Pennsylvania
EPA Region III
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Solid Waste and EPA 542-R-06-006c
Emergency Response December 2006
(5102P) www.epa.gov
Pilot Region-Based Optimization Program
for Fund-Lead Sites in EPA Region 3
Site Optimization Tracker:
Croychem Superfund Site
Berks County
Boyertown, Pennsylvania
EPA Region III
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Site Optimization Tracker
Croychem Superfund Site
Berks County
Boyertown, 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
Cryochem Boyertown, PA 3
4a. EPA RPM 5a. State Contact
Alexis K. Hanlon Richard Morgan
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-5146 717-705-4844
4c. EPA RPM Email Address 5c. State Contact Email Address
hanlon.alexis@epa.gov rimorgan@state.pa.us
5. Is the ground water remedy an interim remedy or a final remedy? Interim | | Final 1X1
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
OU2 September 28, 1990
2a. DateofO&F
May 1998
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)
ESD 8/3/04
2b. Date for transfer to State
5/30/2008
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.)
1 I other
5. Has NAPL or evidence of NAPL been observed at the site? Yes I 1 No 1X1
6. What is the approximate total pumping rate? 45 gpm
7. How many active extraction wells q
(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
[XJ Air stripping
I | Carbon adsorption
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
Actual1 Annual
Costs for FY04
$33,000
$55,000
$135,000
$9,900
$2,500
$5,000
$6,000*
$10,000
$256,400
Actual2 Annual
Costs for FY05
$33,000
$55,000
$35,000
$11,000
$2,500
$5,000
$6,000*
$10,000
$157,500
Estimated2 Annual
Costs for FY06
$33,000
$55,000
$35,000
$11,000
$2,500
$5,000
$6,000*
$10,000
$157,500
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:
All annual O&M costs provided above are for OU2 only.
1. FY04 and FY05 costs, with the exception of the analytical costs, were provided by the RPM
based on work plan cost estimates.
2. FY06 costs are estimated by the ROET based on RPM estimates from previous years and
discussions during the optimization process.
* 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 will likely be incurred by the
State when the site is transferred to the State after LTRA. The decrease from FY05 to FY06
reflects the assumed sampling reduction.
Decrease in annual sampling costs reflects a change from quarterly sampling to annual
sampling.
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D. Five-Year Review
1. Date of the Most Recent Five-Year Review 9/30/2003
2. Protectiveness Statement from the Most Recent Five-Year Review
IXI Protective I I Not Protective
| | Protective in the short-term | | Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
- DCA cleanup level below RGC
- Gasoline plume impacts on treatment systems (OU1 and OU2)
- Collect quarterly ground water samples
- 1-4, dioxane detected in wells
- Develop performance monitoring plan
- Extraction system evaluation
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.
- No sitewide ground water sampling was conducted prior to year 2003.
- The number of impacted residential wells has been reduced as the P&T system started
operation.
- The time decay calculations have been performed.
- Since original optimization evaluation meeting in December 2004, the ground water
monitoring frequency has been reduced to annually, and the process monitoring has been
reduced from monthly to quarterly. Thus, the information in Item B.9 of this form has been
reduced to 33 (annually at 33 wells) and the information in item B. 10 on this form has reduced
by a factor of 3 (monthly to quarterly) to reflect the lower number of samples.
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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 1, 2004 (Evaluation meeting)
August 5, 2005 (Final report)
Meeting Date
July 13, 2005
October 19, 2005
Report Date
Item
August 5, 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)
Cryochem Superfund Site
December 30, 2005
October 19, 2005 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Kathy Davies
Paul Leonard
Peter Rich
Rob Greenwald
Doug Sutton
Steve Chang
Affiliation
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
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
prich(@,geotransinc.com
rgreenwald(@,geotransinc.com
dsutton(@,geotransinc.com
Chang. steven(g),epa. gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Alexis Hanlon
Mindi Snoparsky
Affiliation
U.S. EPA Region 3 (RPM)
U.S. EPA Region 3 (Hydro)
Phone
215-814-5146
215-814-3316
Email
Hanlon. alexis (@,epa. gov
Snoparsky . mindi(@,epa. gov
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IMPLEMENTATION STATUS OF ALL RECOMMENDATIONS UNDER CONSIDERATION BUT NOT
PREVIOUSLY IMPLEMENTED
Recommendation
Recommendation
Reason
E-2.1 Perform a More Detailed Capture Zone Analysis
Protectiveness
Implementation
Status
In Progress
Comments: Through a technical assistance item (described in Appendix A of this tracker), the ROET evaluated
the modeling conducted by die site contractor that would be used for evaluating the capture zone. The
evaluation concluded that die numerical modeling was flawed and needed to be recalibrated. The RPM agrees
with the analysis and is working with the site contractor to determine how best to revisit the model and the cost
of improving it.
Recommendation
Recommendation
Reason
E-2.3 Work with Town or County to Identify and/or Implement Institutional
Controls
Protectiveness
Implementation
Status
In Progress
Comments: The attorney for the town board of supervisors said that the previously mentioned approach of
creating a non-releasable map to identify areas that are affected by the ground water plume would create water
rights issues and should be avoided. The ROD calls for institutional controls if the plume cannot be cleaned up.
The RPM is considering other approaches to instituting institutional controls.
Recommendation
Recommendation
Reason
E-4.1 Produce Timely Annual Ground Water Monitoring Reports
Technical Improvement
Implementation
Status
In progress
Comments: The report for the January to May period was received in October, which is a delay of
approximately 4 to 5 months since the end of the reporting period. The ROET reemphasized that reports should
be available within six weeks or less. The RPM should ask the contractor to continue its efforts to deliver
reports in a timelier manner. In the mean time, the RPM can request that a copy of the lab data be sent directly
to the RPM.
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-2.2 Continue Monitoring for MTBE and 1,4-Dioxane
Protectiveness
Implementation
Status
Implemented
Comments: The monitoring will continue. The RPM added that 1,4-Dioxane is seen more in residential wells
than monitoring wells, suggesting the continued importance of the analysis for this parameter. During the
previous follow-up meeting, the ROET also noted that terminating the extraction at any specific extraction well,
even if it is ''clean", could cause the discharge level of 1,-4-Dioxane to increase above the discharge standard of
5.7 ug/1 (current discharge is approximately half this value). This issue should be considered when evaluating
whether extraction should be terminated at any individual well. The October sampling results were not
available for review at the time of the follow-up meeting.
Recommendation
Recommendation
Reason
E-3.1 Reduce Ground Water Sampling Frequency
Cost Reduction
Implementation
Status
Implemented
Comments: Recent rounds of sampling were conducted in Oct 2004 and May 2005. Annual sampling is to
commence beginning with the October 2005 sampling.
Recommendation
Recommendation
Reason
E-3.2 Eliminate Analysis for Metals in Extraction Wells Sampling Program
Cost Reduction
Implementation
Status
Implemented
Comments: Metals analysis was eliminated as of May 2005 (not done during the most recent sampling round).
Recommendation
Recommendation
Reason
E-3.3 Reduce the Number of Process Water Samples
Cost Reduction
Implementation
Status
Alternative Implemented
Comments: Influent and effluent are now sampled quarterly instead of monthly, effectively reducing the
number of process water samples. If 1.4-Dioxane levels change in the future, then frequency may revert to
monthly. The RPM reports that NPDES permit equivalent requirement is to report both average and
instantaneous results, and the average is based on three discrete samples. The RPM is continuing to follow-up
with the State to see if there is an alternative to the three-sample approach.
Recommendation
Recommendation
Reason
E-3.4 Reduce Data Validation
Cost Reduction
Implementation
Status
Alternative Implemented
Comments: Given that sampling frequency has been reduced (as per other recommendations), turnover to the
State is within a few years, and potential human receptors are present, data validation will remain at highest
levels. Since the sampling frequency has been reduced, the extent of data validation has effectively been
reduced, and the spirit of the recommendation lias been implemented.
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Recommendation
Recommendation
Reason
E-5.1 Continue Pumping to Meet ARARs
Site Closeout
Implementation
Status
Consideration
Acknowledged
Comments: Pumping is continuing.
Recommendation
Recommendation
Reason
E-5.2 Do Not Conduct Source Removal at this Time
Site Closeout
Implementation
Status
Consideration
Acknowledged
Comments: RPM agreed with this consideration.
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)
Cryochem Superfund Site
August 5, 2005
July 13, 2005 -Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Peter Schaul
Kathy Davies
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
215-814-3183
215-814-3315
410-990-4607
732-409-0344
732-409-0344
Email
kulujian.norm(@,epa. gov
schaul.peter@epa.gov
davies.kathy (giepa.gov
prich(@,geotransinc.com
rgreenwald(g),geotransinc.com
dsutton(@,geotransinc.com
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Alexis Alexander
Mindi Snoparsky
Affiliation
U.S. EPA Region 3 (RPM)
U.S. EPA Region 3
(Hydro)
Phone
215-814-5146
215-814-3316
Email
Alexander.alexis(g),epa. gov
Snoparsky . mindifg.epa. gov
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IMPLEMENTATION STATUS OF PREVIOUSLY IDENTIFIED RECOMMENDATIONS
Recommendation
Recommendation
Reason
2.1 Perform a More Detailed Capture Zone Analysis
Protectiveness
Implementation
Status
In Progress
Comments: Based on the recommendation to improve the capture zone analysis, and a previous request from the
evaluation team for clarification of the previous numerical modeling efforts, technical assistance from the
evaluation team was requested by the RPM. This technical assistance was initiated soon after the follow-up
meeting (a conference call was held with the site contractor to discuss the previous modeling) and is ongoing.
Results of the ongoing technical assistance will be reported in a separate document and summarized in the next
follow-up. Preliminary results from the technical assistance suggests that previous potentiometric surface maps
are highly biased by water levels at the extraction wells (as mentioned in the evaluation report), and that the
previous numerical model had flaws (particularly related to basing the model calibration largely on water levels at
extraction wells) such that the numerical model would need to be re-calibrated prior to using it for evaluating
capture.
Recommendation
Recommendation
Reason
2.2 Continue Monitoring for MTBE and 1,4-Dioxane
Protectiveness
Implementation
Status
Implemented
Comments: The monitoring will continue. Also, it was noted that terminating the extraction at any specific
extraction well, even if it is "clean", could cause the discharge level of 1,-4-Dioxane to increase above the
discharge standard of 5.7 ug/1 (current discharge is approximately half this value). This issue should be
considered when evaluating whether extraction should be terminated at any individual well.
Recommendation
Recommendation
Reason
2.3 Work with Town or County to Identify and/or Implement Institutional Controls
Protectiveness
Implementation
Status
In Progress
Comments: Discussions with Jeff Young, Zoning Officer for Earl Township (Technicon Enterprises, Inc. 610-
286-1622) and Thomas Unger, Zoning Officer for Douglass Township (Systems Design Engineering, Inc. 610-
916-8500) to create ordinances for ground water well control are underway. There are privacy issues, and a
strategy being pursued is a non-releasable map to identify areas that are affected by the ground water plume.
Recommendation
Recommendation
Reason
3.1 Reduce Ground Water Sampling Frequency
Cost Reduction
Implementation
Status
Implemented
Comments: Recent rounds of sampling were conducted in Oct 2004 and May 2005. Annual sampling is to
commence beginning with the October 2005 sampling.
Recommendation
Recommendation
Reason
3.2 Eliminate Analysis for Metals in Extraction Wells Sampling Program
Cost Reduction
Implementation
Status
Implemented
Comments: Metals analysis was eliminated as of May 2005 (not done during the most recent sampling round).
Recommendation 3.3 Reduce the Number of Process Water Samples
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Recommendation
Reason
Cost Reduction
Implementation
Status
Alternative Implemented
Comments: Influent and effluent are now sampled quarterly instead of monthly, effectively reducing the number
of process water samples. If 1,4-Dioxane levels change in the future, then frequency may revert to monthly. The
RPM reports that NPDES permit equivalent requirement is to report both average and instantaneous results, and
the average is based on three discrete samples. The RPM will follow up with the state to see if there is an
alternative to the three-sample approach.
Recommendation
Recommendation
Reason
3.4 Reduce Data Validation
Cost Reduction
Implementation
Status
Alternative Implemented
Comments: Given that sampling frequency has been reduced (as per other recommendations), turnover to the
State is within a few years, and potential human receptors are present, data validation will remain at highest
levels. Since the sampling frequency has been reduced, the extent of data validation has effectively been
reduced, and the spirit of the recommendation has been implemented.
Recommendation
Recommendation
Reason
4.1 Produce Timely Annual Ground Water Monitoring Reports
Technical Improvement
Implementation
Status
Under consideration
Comments: The RPM indicates that data from the May 2005 sampling event were received mid- June reflecting
that data management is occurring in a timely manner. The idea of moving forward with an annual report will be
revisited during the next optimization evaluation follow-up meeting.
Recommendation
Recommendation
Reason
5.1 Continue Pumping to Meet ARARs
Site Closeout
Comments: Pumping is being continued.
Implementation
Status
Consideration Acknowledged
Recommendation
Recommendation
Reason
5.2 Do Not Conduct Source Removal at this Time
Site Closeout
Comments: RPM agreed with this consideration.
Implementation
Status
Consideration Acknowledged
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OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
• It was noted that terminating the extraction at any specific extraction well, even if it is
"clean", could cause the discharge level of 1,-4-Dioxane to increase above the discharge
standard of 5.7 ug/1 (current discharge is approximately half this value). This issue
should be considered when evaluating whether extraction should be terminated at any
individual well.
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 Perform a More Detailed
Capture Zone Analysis
2.2 Continue Monitoring for
MTBE and 1,4-Dioxane
2.3 Work with Town or
County to Identify and/or
Implement Institutional Controls
3 . 1 Reduce Ground Water
Sampling Frequency
3.2 Eliminate Analysis for
Metals in Extraction Well
Sampling Program
3.3 Reduce the Number of
Process Water Samples
3.4 Reduce Data Validation
4.1 Produce Timely Annual
Ground Water Monitoring
Reports
5 . 1 Continue Pumping to Meet
ARARs
5.2 Do Not Conduct Source
Removal at this Time
Protectiveness
Protectiveness
Protectiveness
Cost Reduction
Cost Reduction
Cost Reduction
Cost Reduction
Technical
Improvement
Site Closeout
Site Closeout
In progress
Implemented
In progress
Implemented
Implemented
Alternative
Implemented
Alternative
Implemented
In progress
Consideration
Acknowledged
Consideration
Acknowledged
$10,000
$0
$15,000
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Included in 4.1
$0
$0
($100,000)
Not quantified
Not quantified
Not quantified
$22,000
$0
$0
$0
Not yet quantified
Not quantified
(analyzed by CLP)
Not quantified
(analyzed by CLP)
$0
$0
$0
New or Updated Recommendations from Follow-up #1, July 13, 2005
None.
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Recommendation
Reason
Implementation
Status
Estimated
Capital Costs
($)
Actual Capital
Costs
($)
Estimated Change
in Annual Costs
(S/yr)
Actual Change in
Annual Costs
($/yr)
New or Updated Recommendations from Follow-up #2, October 19, 2005
None.
Costs in parentheses imply cost reductions.
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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
Presented September 29, 2005
Comments on a capture zone evaluation and numerical modeling efforts
The attached memorandum documents feedback on the site team's efforts in evaluating capture
and developing a site-wide numerical ground water flow model. Specifically, this technical
assistance was provided by the optimization contractor for consideration by the site team and the
restoftheROET.
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MEMORANDUM
To: Alexis Hanlon, RPM, EPA Region III
From: Rob Greenwald and Yan Zhang, GeoTrans, Inc.
Date: September 29, 2005
Subject: Cryochem, Technical Assistance
Ground Water Modeling and Capture Zone Analysis
GeoTrans was asked to provide technical assistance regarding capture zone evaluations at
the Cryochem site, and in particular, to provide feedback regarding the use of numerical
ground water modeling in that regard. The request for technical assistance was in part
due to the following items presented in the RSE-Lite report:
"A ground water flow model was calibrated for this site, and some information about the
modeling was provided to the evaluation team after the optimization evaluation meeting.
However, it appears that particle tracking results to evaluate actual capture, or to compare
actual capture to the extent of capture interpreted on the May 6, 2003 potentiometric surface
map, have not been presented in reports. "
"A more detailed capture zone analysis is recommended to confirm that the extraction system
is providing the intended containment. This is important given the potential receptors
located downgradient of the extraction system. This analysis should include specifying a
target capture zone on a map, and using as many lines of evidence as possible
(potentiometric surface maps, concentration trends, particle tracking in conjunction with
ground water modeling, etc.) to interpret the capture zone. Care must be taken to make sure
the extent of capture is not over-estimated by relying on measured water levels at pumping
wells when evaluating potentiometric surfaces. Also, it is recommended that a particle
tracking analysis be performed with the already developed numerical flow model to evaluate
predicted capture. The simulated capture should be compared to interpreted capture based
on potentiometric surface evaluations, and any differences in those interpretations should be
reconciled. "
The previously conducted ground water modeling was documented in a slide-style
presentation dated March 2004. At the request of the RPM, a conference call was held on
July 19, 2005 so that GeoTrans could ask questions regarding the ground water modeling.
Participants included Alexis Hanlon (EPA RPM), GeoTrans, and EPA's contractor Tetra
Tech NUS, Inc. Subsequent to that call, Tetra Tech NUS provided additional
information (7 pages of text plus a spreadsheet with water levels from 5/92, 8/92, 5/03,
10/04, and 5/05).
Based on the information provided to GeoTrans to date, we offer the following comments
for consideration of EPA Region III:
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• Tetra Tech NUS has indicated that the ground water modeling was not really
performed to assess capture zones from the on-site wells, but rather was
developed to assess the impact of off-site recovery wells at Mike's Fancy Service
Station on the Cryochem system. Nevertheless, GeoTrans suggests that the use of
a properly calibrated numerical ground water model in conjunction with particle
tracking is a potentially valuable line of evidence regarding the capture zone of
the on-site wells.
• Use of ground water modeling as a line of evidence for capture is particularly
important given the difficulty in developing potentiometric surface maps for
evaluation of capture at this site. These difficulties in developing potentiometric
surface maps are due to the fact that there are relatively few water level
measurements other than the extraction wells, and water levels in the extraction
wells are not representative of aquifer water levels (due to well losses and well
inefficiencies). GeoTrans notes that the previously constructed potentiometric
surface maps may be biased towards overestimating the interpreted zone of
capture due the reliance on water levels at the extraction wells.
• GeoTrans noted on the conference call of July 19 that there are issues with the
method reportedly used for calibrating the existing ground water flow model. The
most significant issue is the heavy reliance on water level targets at the extraction
wells for calibrating the model, which in turn resulted in the assignment of zones
of very low hydraulic conductivity in the vicinity of the pumping wells (on-site
and at Mike's Fancy) relative to the adjacent aquifer material. For instance, the
region containing the on-site extraction wells was assigned a hydraulic
conductivity value of 0.005 ft/day, versus 20 ft/day in the adjacent material. This
is not an appropriate approach to model calibration for two main reasons:
o the measurements of water levels at the pumping wells are influenced by
well losses and well inefficiencies, and therefore are not representative of
aquifer conditions immediately adjacent to the well
o the ground water model predicts water level at the center of a grid cell,
representing an average water level for the entire cell, which may be quite
a bit higher than the measured water level in the aquifer at the extraction
well (even if well losses and well inefficiencies were absent)
• The information provided by Tetra Tech NUS after the conference call does not
alter GeoTrans' opinion that the existing ground water model is not appropriately
calibrated. However, the information provided by Tetra Tech NUS after the
conference call includes discussion of previous pump tests in 1995, where
individual extraction wells were pumped one at a time and drawdown responses
were measured at adjacent wells that were not pumping.
GeoTrans believes that a much improved calibration of the ground water model
could be achieved by trying to match the drawdown responses from those 1995
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pump tests. The drawdowns in the active pumping wells for a specific simulation
should not be used as calibration targets, but the drawdowns in the other MW's
and EW's (i.e., those not being pumped) could be used. The calibration would be
achieved by simulating individual pumping at wells, one at a time, and varying
hydraulic conductivity zonation and other parameters (e.g., recharge) such that a
large portion of the observed drawdowns to individual pumping rates match
reasonably well. Hydraulic conductivity zonation and values could be adjusted
during this calibration process to best mimic the degrees of interconnection of the
various wells observed from those 1995 pump test data. Additional calibration
simulations could be performed using observed pumping rates and observed water
level measurements (at non-pumping wells) for one or more recent pumping
periods (such as May 5, 2005).
This is a complicated calibration approach because it involves multiple calibration
simulations that will ultimately result in a single calibrated model that matches as
many of the targets in the individual calibration simulations as reasonably as
possible. This will require a somewhat iterative approach. For instance,
hydraulic conductivity may first be assigned to best match one of the individual
pump tests, but may later be refined to better match one of the other individual
pump tests. Somewhat qualitative decisions will need to be made to select the
best parameter values so that as many targets are matched as reasonably as
possible.
Because this calibration approach is complicated due to the iterations that will be
required, GeoTrans would estimate that a substantial effort would be required for
the revised calibration and subsequent capture zone delineation (with particle
tracking), perhaps in the $15K to $25K range. However, GeoTrans believes that
this would be the most appropriate approach.
In summary, this calibration approach would be iterative and would include both
of the following types of calibration simulations:
o Multiple simulations, where one well is pumped and drawdown observed
at nearby wells during the pump tests are compared to simulated
drawdowns
o One or more simulations with pumping at multiple extraction wells, based
on measured values for pumping rate, with observed water levels at non-
pumping wells compared to simulated water levels
GeoTrans also notes (as does Tetra Tech NUS) that there is something odd about
the water level data from May 6, 2003, because the lowest water level is reported
at EW-3, which was reportedly not pumping. It seems likely that this extraction
well was pumping a short time before water levels were measured, and that the
well had not fully recovered. The assumption that the well was not pumping may
not be valid. Therefore, it may be prudent to rely more on the pumping rates and
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measured water levels from other time periods for calibrating absolute water
levels (such as the May 5, 2005 pumping rates and water levels).
• During the conference call of July 19, GeoTrans indicated that it would be
beneficial to have a few additional piezometers between extraction wells that
would provide more aquifer water levels for developing potentiometric surfaces
and for calibrating the model. It should be noted that the use of the 1995 pump
test data, where wells were pumped one a time, may preclude the need for such
piezometers for re-calibrating the ground water model. However, additional
piezometers would certainly improve the accuracy of potentiometric surface
maps. The cost of drilling those piezometers may be substantial due to the
significant depth, and should be weighed against the value of those additional data
points.
• During the conference call of July 19, Tetra Tech NUS indicated that there was a
proposal in for geophysics. At the time, GeoTrans thought this would be at new
borings, which might provide a reason for installing the additional piezometers
discussed above. Based on information subsequently provided to GeoTrans, the
geophysics would be performed on existing wells. Performing the geophysics
work is somewhat tangential to the modeling work, and GeoTrans defers to the
judgment of Region III as to whether or not the geophysics should be performed
to resolve other issues unrelated to the modeling effort.
• In summary, there is value in using ground water modeling to better assess the
capture zone at this site. GeoTrans believes the existing ground water model
should be re-calibrated using an approach outlined above. Capture zones for
different pumping scenarios can then be assessed with particle tracking, once the
model has been re-calibrated. The extent of capture determined with particle
tracking should be compared to a Target Capture Zone, which should be defined
and represented on a map. This line of evidence regarding capture (i.e., modeling
with particle tracking) can be used in conjunction with other lines of evidence,
such as potentiometric surface maps and observed concentration trends, to
provide a comprehensive capture zone evaluation.
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APPENDIX: B
BASELINE SITE INFORMATION SHEET AND
OPTIMIZATION EVALUATION REPORT
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Streamlined
Optimization Evaluation Report
Croychem Superfund Site
Berks County
Boyertown, Pennsylvania
EPA Region III
August 5, 2005
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SECTION 1:
BASELINE SITE INFORMATION FORM
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Date:
2/14/05
Filled Out Bv: GeoTrans
A. Site Location, Contact Information, and Site Status
1. Site name 2. Site Location (city and State) 3. EPA Region
Cryochem Boyertown, PA 3
4a. EPA RPM 5a. State Contact
Alexis K. Alexander Richard Morgan
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-5146 717-705-4844
4c. EPA RPM Email Address 5c. State Contact Email Address
alexander.alexis@epa.gov rimorgan@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
OU2 September 28, 1990
2a. DateofO&F
May 1998
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)
ESD 8/3/04
2b. Date for transfer to State
5/30/2008
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.)
1 I other
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? 45 gpm
7. How many active extraction wells q
(or trenches) are there?
9. How many samples are collected
from monitoring wells or piezometers t _.
each year? (e.g., 40 if 10 wells are
sampled quarterly)
1 1 . What above-ground treatment processes are usec
[XJ Air stripping
I | Carbon adsorption
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
32,000
56,000
135,000
9,900
2,500
5,000
10,000
250,400
Actual Annual Costs
forFY04
33,000
55,000
135,000
9,900
2,500
5,000
10,000
250,400
Projected Annual
Costs for FY05
33,000
55,000
135,000
11,000
2,500
5,000
10,000
251,500
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:
- Costs are from work plan cost estimates.
- The annual O&M costs provided above are for OU2 only.
- The system operation labor costs include cost associated with monthly reporting.
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D. Five-Year Review
1. Date of the Most Recent Five-Year Review 9/30/2003
2. Protectiveness Statement from the Most Recent Five-Year Review
IXI Protective I I Not Protective
| | Protective in the short-term | | Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
- DCA cleanup level below RGC
- Gasoline plume impacts on treatment systems (OU1 and OU2)
- Collect quarterly ground water samples
- 1-4, dioxane detected in wells
- Develop preformance monitoring plan
- Extraction system evaluation
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.
- No sitewide ground water sampling was conducted prior to year 2003.
- The number of impacted residential wells has been reduced as the P&T system started
operation.
- The time decay calculations have been performed.
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SECTION 2:
STREAMLINED OPTIMIZATION EVALUATION
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Date of Evaluation Meeting:
Cryochem Superfund Site
December 1, 2004 Date of Final Report: Augusts, 2005
ROET MEMBERS CONDUCTING THE STREAMLINED OPTIMIZATION EVALUATION:
Name
Peter Schaul
Norm Kulujian
Kathy Davies
Rob Greenwald
Peter Rich
Kathy Yager (by phone)
Jean Balent (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
215-814-3183
215-814-3130
215-814-3315
732-409-0344
410-990-4607
617-918-8362
202-564-1709
Email
schaul.peter(@,epa.gov
Kurujian.norm(g),epa.gov
Davies.kathy(g),epa.gov
rgreenwald(@,geotransinc.com
prich(@,geotransinc.com
Yager.kathy(g),epa.gov
Balent.j ean@epa. gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Ashee Rudolph
Mary Mang
Steve Demars
Richard Morgan
Mindi Snoparsky
Alexis Alexander
Tony Dappalone
Affiliation
VISTA
TetraTechNUS
PADEP
PADEP
U.S. EPA Region 3
(Hydro)
U.S. EPA Region 3 (RPM)
U.S. EPA Region 3 (Sec.
Chief)
Phone
215-814-3187
610-491-9688
717-705-4832
717-705-4844
215-814-3316
215-814-5146
215-814-3188
Email
Rudolph. asheet@,epa. gov
MangMtg.TTNUS.com
SDemars(@,state.pa.us
RImorgan@state.pa. us
Snoparskv.mindi(@,epa.gov
Alexander, alexisfg.epa. gov
dappalone.anthony(g),epa. gov
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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:
• The OU1 remedy (water treatment at impacted homes) continues to operate with 12 home
treatment systems. Eight of the original 20 systems have been removed based on ground water
monitoring results. OU2 pertains to the ground water remedy for the site.
• MTBE believed to be from a separate downgradient source (Mike's Fancy Service Station) is
present in site ground water and could impact the pumping strategy in the future if MTBE
concentrations increase. The current MTBE influent concentration is reported to be
approximately 2 to 3 ug/L and the effluent concentration is less than 1.0 ug/L so MTBE is not
impacting treatment at this time. A discharge standard is not provided but it is likely to be 10 to
20 ug/L (or higher) if added.
• Mike's Fancy Service Station has a P&T system, with a total design capacity of 35 gpm. EPA
reportedly has completed a hydrologic review to assess the impact of their system on the
Cryochem system and the neighboring residences. The cones of influence for that system are
very tight, and based on observed water levels, no impacts on the Cryochem system have been
noted.
• 1,4-Dioxane is present at the site and could impact future treatment. Current influent and
effluent levels are approximate 3 ug/L, and the highest concentration in ground water is 15 ug/L
detected at EW-8. The RPM indicates that a state standard of 5.7 ug/1 was adapted as the
discharge standard for 1,4-Dioxane in an ESD dated August 3, 2004.
• The extraction wells are deep bedrock wells with the depth about 250 feet to 350 feet below
ground surface. The source of the impacts has never been well defined, and the plume is spread
out within the deep bedrock. Thus any in-situ source removal would likely be very difficult and
costly.
• It was thought that the source of the ground water impacts was near well RI-2D, but soil
sampling in that vicinity showed little impacts. Factors that may have led to plume spreading
and complicating source identification include one or more of the following: a storm water
collection system that may have served as a conduit; pumping at private wells that could have
caused transience in the flow direction; complicated flow patterns due to fractures in the
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bedrock; and plant production wells near MW-1 and MW-2 that might have complicated flow
patterns.
• 1,1-DCE is the only COC remaining above MCLs, and the maximum concentration during the
March 2003 sampling event at an extraction well was 57 ug/L. The highest observed
concentration at a monitoring well was 150 ug/1 at MW-3. Only three of the nine extraction
wells (EW-4, EW-8, and EW-9) had 1,1-DCE concentrations above MCLs.
• It is considered likely that there is some continuing source of 1,1,1-TCA in the unsaturated zone
that breaks down to 1,1-DCE when it enters the ground water. The continuing source may be
located beneath a building.
• There is a tradeoff associated with pumping more water at the extraction wells. On one hand,
increasing extraction may increase the size of the capture zone. However, it may also cause too
much drawdown at residences, negatively impacting the yields of those wells.
• A ground water flow model was calibrated for this site, and some information about the
modeling was provided to the evaluation team after the optimization evaluation meeting.
However, it appears that particle tracking results to evaluate actual capture, or to compare actual
capture to the extent of capture interpreted on the May 6, 2003 potentiometric surface map, have
not been presented in reports.
• No institutional controls have been implemented to date.
2.0 RECOMMENDATIONS TO IMPROVE SYSTEM PROTECTIVENESS
2.1 PERFORM A MORE DETAILED CAPTURE ZONE ANALYSIS
The P&T system design flow rate was 65 gpm, however, the system has operated at
approximately 35 to 45 gpm based on sustained yield at the extraction wells, and has been
sustained at approximately 45 gpm recently. An additional P&T system was recently
installed downgradient for the MTBE plume, and some analysis (with a ground water flow
model) has reportedly been performed to conclude that the off-site system does not impact
the on-site system. Site-wide potentiometric data have been collected quarterly in 2003 and
2004, and a preliminary capture zone analysis was presented in the Technical Review Report
(June 2003). A more detailed capture zone analysis is recommended to confirm that the
extraction system is providing the intended containment. This is important given the
potential receptors located downgradient of the extraction system. This analysis should
include specifying a target capture zone on a map, and using as many lines of evidence as
possible (potentiometric surface maps, concentration trends, particle tracking in conjunction
with ground water modeling, etc.) to interpret the capture zone. Care must be taken to make
sure the extent of capture is not over-estimated by relying on measured water levels at
pumping wells when evaluating potentiometric surfaces. Also, it is recommended that a
particle tracking analysis be performed with the already developed numerical flow model to
evaluate predicted capture. The simulated capture should be compared to interpreted capture
based on potentiometric surface evaluations, and any differences in those interpretations
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should be reconciled. A detailed capture zone analysis effort will indicate the degree of
capture effectiveness (relative to the Target Capture Zone) and suggest if additional/revised
pumping be required. Estimated cost of this capture zone analysis is approximately $10,000.
Updating it annually is incorporated in the cost of Recommendation 4.1.
2.2 CONTINUE MONITORING FOR MTBE AND 1,4-DioxANE
It is recommended that monitoring the influent for MTBE and 1,4-Dioxane be continued. If
either compound becomes present at concentrations that are greater than (potential) discharge
standards, a modification to the pumping strategy and/or ground water treatment strategy will
likely be required, and a source remediation strategy may become more important. No
change in current costs is anticipated.
2.3 WORK WITH TOWN OR COUNTY TO IDENTIFY AND/OR IMPLEMENT INSTITUTIONAL
CONTROLS
EPA and PADEP should meet with the town and/or county to identify if there are measures
in place to prevent exposure to contaminants, and to determine what (if anything) needs to be
done to make sure no new wells can be drilled in areas potentially impacted by the site. EPA
efforts for coordinating and/or participating in these activities might cost $15,000 assuming
contractor support for meetings and other support tasks are required.
3.0 RECOMMENDATIONS TO REDUCE SYSTEM COST
3.1 REDUCE GROUND WATER SAMPLING FREQUENCY
Current plans are to sample 43 wells quarterly through September 2006. Quarterly sampling
began in March/April 2003, and it was acknowledged during the evaluation meeting that this
sampling has improved the understanding of the site and was a very worthwhile effort.
However, the evaluation team feels that continuing quarterly sampling for two additional
years is not likely to be worth the cost. Moreover, any seasonal impacts will have already
been observed with 2003/2004 sampling data. A reasonable alternative program would be
annual sampling of the 43 wells. Since the OU1 program is already in place with treatment
of impacted supply wells and long-term data, the evaluation team could not identify any well
where it recommends more frequent sampling than annually. The associated cost savings
from reducing sampling frequency is about $100,000 per year (the current labor costs for
quarterly sampling are reported to be $135,000 per year).
3.2 ELIMINATE ANALYSIS FOR METALS IN EXTRACTION WELL SAMPLING PROGRAM
Metals are not COCs at the site and the treatment system operates effectively without
significant metals fouling. Analyzing for metals at all the extraction wells provides no useful
data. A sample from the treatment system influent could be analyzed annually for metals to
provide sufficient data for long-term consistent operations. There is no direct saving
associated with this recommendation (due to the use of the contract lab), but the current
practice causes unnecessary effort with respect to sampling, analysis at the lab, and reporting.
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3.3 REDUCE THE NUMBER OF PROCESS WATER SAMPLES
Currently, the treatment system influent and effluent are sampled 3 times per month with
sampling occurring at half-hour increments on the same day. For a ground water system
with relatively consistent influent, this procedure provides little or no advantage to sampling
one time per month. It is recommended that a variance be requested from whatever
requirement is the basis for such sampling. The cost savings for the site are negligible given
that analysis is performed by contract lab, but the current practice causes unnecessary effort
with respect to sampling, analysis at the lab, and reporting.
3.4 REDUCE DATA VALIDATION
Based on the Sampling and Analysis Plan (June 2003) analytical data is currently validated
to the highest level. Given that key regulatory decisions are not being made based on these
data, and that the data are in many ways self validating due to the long-term nature of the
system operation and ongoing monitoring, the evaluation team recommends going to the M-l
level of data validation. In addition to potential cost savings, this change will likely allow
the data to be reported and used more quickly. Based on information provided by the RPM
after the evaluation meeting, data validation costs appear to have been approximately
$40,000 over a nearly 3.5 year period, or approximately $12,000 per year. However, future
validation costs will be lower if recommendations 3.1 to 3.3 are also implemented. Thus, the
potential savings from implementing this recommendation are not quantified at this time.
4.0 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT
4.1 PRODUCE TIMELY ANNUAL GROUND WATER MONITORING REPORTS
Quarterly ground water monitoring commenced in March 2003 and continued through 2004.
However, the most recent ground water monitoring summary report provided to the
evaluation team was a draft report describing the March 2003 event. The evaluation team
recommends that an annual report be produced (which would be especially appropriate if the
sampling frequency is changed to annual). That report should generally be produced within
approximately 8 weeks of the ground water sampling event (or within one month of
receiving results from the EPA lab, if that takes longer than a typical lab). It should include
annual updates to the detailed capture zone evaluation suggested in Recommendation 2.1.
This annual report should generally cost on the order of $25,000. Since the site information
form reported expected costs of approximately $33,000 per year for project management and
reporting, and project management might be expected to cost approximately $30,000 per
year, the evaluation team believes that a well done ground water monitoring report, prepared
annually, might add $22,000 per year to the current estimated costs.
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5.0 RECOMMENDATIONS To SPEED SITE CLOSEOUT
5.1 CONTINUE PUMPING TO MEET ARARs
Decay calculations reportedly indicate the timeframe for attenuation/remediation of
downgradient residential wells and site wells to MCLs is about 7.5 years and 18 years,
respectively. These results seem reasonable given the site conditions. As long as there is
ground water pumping at homes downgradient of the P&T wells, it is recommended that
P&T operations also continue.
5.2 Do NOT CONDUCT SOURCE REMOVAL AT THIS TIME
At present, the evaluation team does not recommend attempting to remove the contaminant
source because of the expected difficulty and expense. The source has not been clearly
identified, many factors have led to previous plume spreading (which further complicates
identifying source locations), and some of the source material may be located under
buildings. Therefore, the evaluation team believes that success in identifying the source area,
removing the source, and substantially reducing the operating lifetime of the P&T system
with source removal is unlikely. Furthermore, continued P&T system operation for
containment would likely be required for a similar amount of time, whether or not source
material is removed.
PRIORITIZATION AND SEQUENCING OF RECOMMENDATIONS
All recommendations can be implemented within several months, and none are dependent on the
implementation of other recommendations.
OTHER ACTION ITEMS
None
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Cost Summary Table
Recommendation
2. 1 Perform More Detailed
Capture Zone Analysis
2.2 Continue Monitoring for
MTBE and 1,4-Dioxane
2.3 Work with Town or
County to Identify and/or
Implement Institutional Controls
3 . 1 Reduce Ground Water
Sampling Frequency
3.2 Eliminate Analysis for
Metals in Ground Water
Sampling Program
3 . 3 Reduce the Number of
Process Water Samples
3 .4 Reduce Data Validation
4.1 Produce Timely Annual
Ground Water Monitoring
Reports
5 . 1 Continue Pumping to Meet
ARARs
5.2 Do Not Conduct Source
Removal at This Time
Reason
Effectiveness
Effectiveness
Effectiveness
Cost Reduction
Cost Reduction
Cost Reduction
Cost Reduction
Technical Improvement
Site Closeout
Site Closeout
Estimated Additional
Capital Costs
($)
$10,000
$0
$15,000
$0
$0
$0
$0
$0
$0
$0
Estimated Change in
Annual Costs
($/yr)
Included in 4. 1
$0
$0
($100,000)
Not quantified
Not quantified
Not quantified
$22,000
$0
$0
Costs in parentheses imply cost reductions.
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