Final Report
Pilot Region-Based Optimization
Program for Fund-Lead Sites
in EPA Region 3
Site Optimization Tracker:
Hellertown Manufacturing
Hellertown, Pennsylvania
EPA Region III
o
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Solid Waste and EPA 542-R-06-006e
Emergency Response December 2006
(5102P) www.epa.gov
Pilot Region-Based Optimization Program
for Fund-Lead Sites in EPA Region 3
Site Optimization Tracker:
Hellertown Manufacturing
Hellertown, Pennsylvania
EPA Region III
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Site Optimization Tracker:
Heller town Manufacturing
Hellertown, Pennsylvania
EPA Region III
December 30, 2005
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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
Hellertown Manufacturing Hellertown, PA 3
4a. EPA RPM 5a. State Contact
Alexis Hanlon Margaret Boyer
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-5146 610-861-2076
4c. EPA RPM Email Address 5c. State Contact Email Address
hanlon.alexis@epa.gov boyer.margaret@dep.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
9/3/1991
2a. DateofO&F
9/26/1997
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)
2b. Date for transfer to State
9/25/2007
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? 125 gpm
7. How many active extraction wells 1
(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
IXI 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
$32,000
$11,000
$25,000
$9,200
$2,250
$10,500
0
$5,000*
$24,000
$118,950
Estimated2 Annual
Costs for FY05
$33,500
$8,000
$25,000
$9,000
$3,000
$9,000
$700
$5,000*
$20,000
$113,200
Estimated2 Annual
Costs for FY06
$33,500
$8,000
$25,000
$9,000
$3,000
$9,000
$700
$5,000*
$20,000
$113,200
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
$82,040
$50,000
$25,000**
Additional costs beyond routine O&M for the specified fiscal years should be included in the above spaces. Such
costs might be associated with additional investigations, non-routine maintenance, additional extraction wells, or
other operable units. The total costs billed to the site for the specified fiscal years should be equal to the O&M
total plus the costs entered in item 2.
Notes on costs:
1. Costs, with the exception of the analytical costs, were provided by the RPM.
2. FY05 and FY06 annual costs, with the exception of the analytical costs, were projected by
the RPM.
* Analytical costs were estimated by the ROET based on the sampling program. The
analytical costs are not incurred by the EPA site team because the samples are analyzed by the
CLP program. However, analytical costs similar to those estimated by the ROET, will likely be
incurred by the State if/when the site is transferred to the State after LTRA. The decrease from
FY05 to FY06 reflects a sampling reduction undertaken by the site team.
** The non-routine costs for FY06 are estimated by the ROET and represent potential
contractor support costs that might be associated with obtaining institutional controls for the
site or other items associated with implementing optimization evaluation recommendations.
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D. Five-Year Review
1. Date of the Most Recent Five-Year Review 4/29/2005
2. Protectiveness Statement from the Most Recent Five-Year Review
I | Protective I I Not Protective
IXI Protective in the short-term | | Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
This new Five Year Review was not provided to the ROET in enough time for consideration
during this project. The RPM reports that the Five Year Review states that the remedy is
protective in the short-term. The majority of the recommendations from the previous Five
Year Review have been implemented, but the site team is still working toward institutional
controls, which is the primary reason that the remedy is only considered protective in the short
term.
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.
This updated form reflects the following changes from the baseline information form.
- changes in the RPM's and State Contact's last names
- a correction regarding the O&F date for the system and the date of transfer to the State
- a reduction in the process sampling to quarterly sampling of the influent and effluent
- a Five Year Review was conducted in April 2005.
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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.
-------
FOLLOW-UP HISTORY
Date of Original Optimization Evaluation
June 5, 2001 (site visit)
November 14, 2001 (report)
Meeting Date
May 29, 2002
June 11, 2003
Report Date
Item
X December 16, 2004
June 10, 2002 Follow-Up A* (part of nationwide opt. effort)
June 30, 2003 Follow-Up B* (part of nationwide opt. effort)
January 24, 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
"x" in box indicates the item has been completed
* Follow-up A and B were performed as part of a nationwide optimization effort, separate from
the pilot project under which Follow-up #1 and #2 were conducted.
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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)
Hellertown Manufacturing
December 30, 2005
October 18, 2005 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Kathy Davies
NormKulujian
Peter Ludzia
Peter Rich
Rob Greenwald
Doug Sutton
Kathy Yager
Chuck Sands
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
GeoTrans, Inc.
U.S. EPA OSRTI
U.S. EPAOSRTI
Phone
215-814-3315
215-814-3130
215-814-3224
410-990-4607
732-409-0344
732-409-0344
617-918-8362
703-603-8857
Email
davies.kathy@epa.gov
kill u i ian . no rm@epa . go v
ludzia.peter@epa.gov
priclnir7igeotransinc.com
rgreemvald@geotransinc.com
dsuUon@geolransinc.com
vager.kathleen@geotransinc.com
sands.cliarles@epamail.epa.gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Alexis Hanlon
Mindy Snoparsky
Affiliation
U.S. EPA Region 3
(RPM)
U.S. EPA Region 3
(Hydrogeologist)
Phone
215-814-5146
215-814-3316
Email
Hanlon.alexisr
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IMPLEMENTATION STATUS OF ALL RECOMMENDATIONS UNDER CONSIDERATION BUT NOT
PREVIOUSLY IMPLEMENTED
Recommendation
Recommendation
Reason
E-6.1.1 Analyze Capture Zone for Ground Water Extraction Well
Effectiveness
Implementation
Status
Substantial progress
Comments: A capture zone analysis using water level measurements lias been conducted. The results suggest
that capture is adequate; however, the analysis was based on limited data. A better indicator of capture would be
from a water budget analysis and from reviewing concentration trends of downgradient performance wells
installed somewhere between the extraction well and existing downgradient wells. The site team gained access to
the Norfolk railroad property in 2005 and installed a new monitoring well approximately 100 feet downgradient
of the extraction well. The new monitoring well has been sampled, and the site team is awaiting the sampling
results. The cost for well installation and sampling was approximately $15,000.
Recommendation
Recommendation
Reason
E-6.1.3 Implement Institutional Controls
Effectiveness
Implementation
Status
In progress
Comments: The current property owner. Paikes, has been contacted regarding continued access and institutional
controls. Although initial efforts suggested that Paikes would implement the institutional controls, negotiations
between EPA and Paikes have since stopped. EPA is now working with the State to see if the State will
implement specific institutional controls through a 512 order.
Recommendation
Recommendation
Reason
E-6.4.1 Establish Cleanup Goals for the Aquifer
Site Closeout
Implementation
Status
Substantial progress
Comments: The RPM has conferred with the Regional toxicologists. After addressing recommendation 6.1.3,
the RPM will issue an ESD documenting MCLs as the cleanup levels for the site.
Recommendation
Recommendation
Reason
1F-1 Excavate Soils Near CSP-7
Effectiveness
Implementation
Status
Alternative Implemented
Comments: Investigation of the former pre-treatment area was conducted by the site team in response to
Recommendation 6.1.4. A soil gas survey indicated soil contamination as high as 240 mg/kg, and in the
December 2004 follow-up meeting, the ROET concurred with the site team that excavation was appropriate. The
site team was planning to excavate approximately 40,000 cubic feet of soil in the Summer 2005; however, prior to
the excavation, sampling indicated that the concentrations at the nearby monitoring well dropped to 12 ug/L (from
over 200 ug/L) indicating the excavation may not be necessary. The site team will continue to track the sampling
results from this area.
-------
Recommendation
Recommendation
Reason
1F-2 Install Planned Monitoring Wells Downgradient of Capture Zone
Effectiveness
Implementation
Status
Implemented
Comments: A monitoring wells was installed approximately 100 feet downgradient of the extraction, which
based on the technical assistance (see Appendix A) should be downgradient of the capture zone. For additional
information, please refer to the comments associated with recommendation 6.1.1.
Key for recommendation numbers:
• E denotes a recommendation from the original optimization evaluation
• Fl, F2, etc. denote recommendations from the first, second, etc. follow-up meeting
• The number corresponds to the number of the recommendation as stated in the optimization
evaluation or follow-up summary where the recommendation was provided
RECOMMENDATIONS PREVIOUSLY IMPLEMENTED OR THAT WILL NOT BE IMPLEMENTED
Recommendation
Recommendation
Reason
E-6.1.2 Evaluate Extraction Well Production
Effectiveness
Implementation
Status
Implemented
Comments: The well has been inspected with a downhole camera and has been rehabilitated. The flow rate has
been at approximately 130 gpm for over a year and a half. This is an increase of approximately 50% compared to
the flow rate at the time of the RSE. The site team has had to replace the pump frequently resulting in costs of
approximately $10,000 per year. The ROET provided information on more competitive costs for potential pump
replacements as part of a technical assistance item (see Appendix A). The last pump change was conducted hi
October 2004, and the next one will likely occur in Fall 2006. The site team will likely use the pump discussed in
the technical assistance item.
Recommendation
Recommendation
Reason
E-6.1.4 Evaluate Pretreatment Area
Effectiveness
Implementation
Status
Implemented
Comments: A soil gas survey indicated soil contamination as high as 240 mg/kg. The site team was planning to
excavate approximately 40,000 cubic feet of soil in the Summer 2005; however, prior to the excavation, sampling
indicated mat the concentrations at the nearby monitoring well dropped to 12 ug/L (from over 200 ug/L)
indicating the excavation may not be necessary.
Recommendation
Recommendation
Reason
E-6.2.1 Consider Modifying Treatment Processes to Liquid Phase Carbon Only
Cost Reduction
Implementation
Status
Will not be implemented
Comments: The recommendation will be considered only if replacing the air stripper or other significant
changes are required.
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Recommendation
Recommendation
Reason
E-6.2.2 Lower Building Temperature to Lower Utility Costs
Cost Reduction
Implementation
Status
Implemented
Comments: The temperature lias been lowered and the site team has identified savings of approximately
per year in lower utility costs.
$2,000
Recommendation
Recommendation
Reason
E-6.3.1 Stop Performing Data Validation
Technical Improvement
Implementation
Status
Implemented
Comments: Data validation has been reduced to the M-l level, which is the lowest level. The costs of data
validation are not assigned to the site because the samples are analyzed by the CLP.
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 provid
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
A Five Year Review for the site was completed in April 2005 but was not provided to the ROET
in time for consideration in this pilot project.
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)
Hellertown Manufacturing
January 24, 2005
December 16, 2004 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Kathy Davies
NormKulujian
Peter Schaul
Peter Rich
Rob Greenwald
Doug Sutton
Jean Balent (by phone)
Chuck Sands
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
GeoTrans, Inc.
U.S. EPA OSRTI
U.S. EPAOSRTI
Phone
215-814-3315
215-814-3130
215-814-3183
410-990-4607
732-409-0344
732-409-0344
703-603-9924
703-603-8857
Email
davies.kathviffiepa.gov
kill u i ian . no rmfr? :e pa . go v
schaul .peter(#'.epa. gov
pricliiir7igeotransinc.com
rgreemvaldffi'.geotransinc.com
dsuUonffiigeoiransinc.com
balent.jeanffiepamail.epa.gov
sands.cliarlesffiepamail.epa.gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Alexis Hanlon
Jim Romig
Affiliation
EPA Region 3 (RPM)
COM Federal
Phone
215-814-5146
610-293-0450
Email
lianlon.alexisffiepa.gov
Ro mi g JMitf icdin .com
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IMPLEMENTATION STATUS OF PREVIOUSLY IDENTIFIED RECOMMENDATIONS
Recommendation
Recommendation
Reason
6.1.1 Analyze Capture Zone for Ground Water Extraction Well
Effectiveness
Implementation
Status
Substantial progress
Comments: A capture zone analysis using water level measurements has been conducted. The results suggest
that capture is adequate; however, the analysis was based on limited data. A better indicator of capture would be
from a water budget analysis and from reviewing concentration trends of downgradient performance wells
installed somewhere between the extraction well and existing downgradient wells. The site team is waiting for
access to the Norfolk railroad property to install the wells.
Recommendation
Recommendation
Reason
6.1.2 Evaluate Extraction Well Production
Effectiveness
Implementation
Status
Implemented
Comments: The well has been inspected with a downhole camera and has been rehabilitated. The flow rate has
been at approximately 130 gpm for over a year and a half. This is an increase of approximately 50% compared to
the flow rate at the time of the RSE. The site team has had to replace the pump frequently resulting in costs of
approximately $10,000 per year. The RPM has requested advice on alternatives for the current pump.
Recommendation
Recommendation
Reason
6.1.3 Implement Institutional Controls
Effectiveness
Implementation
Status
In progress
Comments: The current property owner, Paikes, has been contacted regarding continued access and institutional
controls. Paikes seems willing to cooperate. The idea is to have Paikes implement the institutional controls on
their own so that EPA does not have to have an interest in the property to implement them itself.
Recommendation
Recommendation
Reason
6.1.4 Evaluate Pretreatment Area
Effectiveness
Implementation
Status
Implemented
Comments: A soil gas survey indicated soil contamination as high as 240 mg/kg. The site team is planning to
excavate approximately 40,000 cubic feet of soil. The work will likely be conducted in Summer 2005.
Recommendation
Recommendation
Reason
6.2.1 Consider Modifying Treatment Processes to Liquid Phase Carbon Only
Cost Reduction
Implementation
Status
Will not be implemented
Comments: The recommendation will be considered only if replacing the air stripper or other significant
changes are required.
Recommendation
Recommendation
Reason
6.2.2 Lower Building Temperature to Lower Utility Costs
Cost Reduction
Implementation
Status
Implemented
Comments: The temperature lias been lowered and the site team lias identified savings of approximately $2,000
per year in lower utility costs.
-------
Recommendation
Recommendation
Reason
6.3.1 Stop Performing Data Validation
Technical Improvement
Implementation
Status
Implemented
Comments: Data validation has been reduced to the M-l level, which is the lowest level. The costs of data
validation are not assigned to the site because the samples are analyzed by the CLP.
Recommendation
Recommendation
Reason
6.4.1 Establish Cleanup Goals for the Aquifer
Site Closeout
Implementation
Status
In progress
Comments: The RPM is working with the EPA lexicologist. They are working towards a standard of 5 ug/L for
TCE but first need to demonstrate that TCE is the only contaminant of concern with a carcinogenic risk.
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
None.
NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP
1. It is recommended that the site team proceed with excavation of the contaminated soil
near CSP-7. No further sampling for metals should be necessary given that there is no
history of metals contamination at the site. The site team would be more likely to find
elevated concentrations of metals that are not associated with the site.
2. When installing the new wells downgradient of the extraction well, the wells should be
placed beyond the stagnation point of the capture zone. The calculations in Appendix A
suggest a range of likely locations for the stagnation point when pumping at 135 gpm,
assuming the aquifer is 200 feet deep, there is a hydraulic gradient of 0.03 feet per foot,
and the transmissivity ranges from approximately 4,300 to 4900 ft2 per day (high and low
estimates from site documents). The calculations suggest that the stagnation point is at
28 to 32 feet downgradient of the extraction well. The transmissivity could easily fall
outside of the above-mentioned range. To be conservative, it is suggested that the site
team place the proposed monitoring wells at least 100 feet downgradient of the extraction
well. Based on site maps and discussions during the followup meeting on 12/16/04, the
proposed locations indicated are much further downgradient and should be sufficiently
conservative to avoid installing the new monitoring wells within the capture zone.
ADDITIONAL TECHNICAL ASSISTANCE ITEMS
At the request of the RPM, information on a replacement pump is provided in Appendix A.
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Updated Cost Summary Table
Recommendation
Reason
Implementation
Status
Estimated
Capital Costs
($)
Actual Capital
Costs
($)
Estimated Change
in Annual Costs
(S/yr)
Actual Change in
Annual Costs
($/vr)
Original Optimization Evaluation Recommendations
6.1.1 Delineate plume and
evaluate capture zone
6.1.2 Evaluate extraction well
and pump
6.1.3 Implement institutional
controls
6.1.4 Initial investigation near
CSP-7and old treatment area
6.2.1
a) Switch to only
liquid-phase carbon
b) Further reduce process
monitoring
6.2.2 Reduce heating in building
(lower temperature)
6.3.1 Stop performing data
validation
6.4.1 Establish cleanup levels
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Cost Reduction
Cost Reduction
Technical
improvement
Site Closure
Substantial
progress
Implemented
In progress
Implemented
Will not be
implemented
Implemented
Implemented
Substantial
progress
$25,000
$10,000
$15,000
$25,000
$125,000
$0
$0
$0
Not quantified
$30,000 to
$45,000
Will not be
implemented
$0
$0
$0
$5,000
$0
$0
$0
($22,000)
($10,000)
($1,000)
$0
$0
Not quantified
Not quantified
Will not be
implemented
($2,000)
$0
$0
New or Updated Recommendations from Follow-up A, May 29, 2002
None. 1
1
-------
New or Updated Recommendations from Follow-up B, June 11, 2003
None. 1
1
New or Updated Recommendations from Follow-up #1, December 16, 2004
1. Move directly to soil
excavation near CSP-7
2. Install monitoring well
beyond capture zone stagnation
point
Site closure
Effectiveness
Alternative
implemented
Implemented
Not quantified
$10,000
$0
$15,000
$0
$0
$0
$0
New or Updated Recommendations from Follow-up #2, October 18, 2005
None.
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 #2
Presented January 24, 2005
Calculation of the capture zone stagnation point
The spreadsheet and chart on the following pages calculates the estimated distance between the
extraction well and the capture zone stagnation point.
-------
Capture Zone Width Calculation, One Extraction Well
Capture Zone Width Calculations provide an estimate of capture zone width for a specific pumping
rate of one or more extraction well(s). For the case of one extraction well, the equation is as follows:
yl\\ -or -
2Ti
<'; Ywdl=±g/47i
Where:
T = transmissivity (ft2/day)
Q = extraction rate (ft3/day)
i = regional (i.e., without remedy pumping) hydraulic gradient (ft/ft)
tanQ and tan"1Q are in radians, not degrees
X0 = stagnation point, the downgradient end of the capture zone by solving forx aty=0
Ymax = maximum capture half width, the half distance far upstream from the well by solving
for y at x=co
Ywen = capture half width at well, the half distance of the capture zone at the line of well by solving
for y at x=0
Assumptions applied for this method:
1. homogeneous, isotropic aquifer of infinite extent
2. confined aquifer, uniform aquifer thickness
3. fully penetrating extraction well(s)
4. uniform regional horizontal hydraulic gradient
5. steady-state flow
6. negligible vertical gradient
7. no net recharge, or net recharge is accounted for in the regional hydraulic gradient
8. no other sources of water to the extraction well (e.g., flux from rivers or from other aquifers)
Capture Zone Width Calculation Results (Low T)
Input Parameters
Transmissivity T (ft^/day)
Pumping Rate Q (gpm)
Pumping Rate Q (ft3/day)
Hydraulic Gradient i (ft/ft)
4325
135
25,900
0.03
Output Parameters
Stagnation Distance X0 (ft)
Max Capture Half Width Ymax (ft)
Capture Half Width at Well Yweii (ft)
-31.88
100.14
50.07
Capture Zone Width Calculation Results (High T)
Input Parameters
Transmissivity T (ft^/day)
Pumping Rate Q (gpm)
Pumping Rate Q (ft3/day)
Hydraulic Gradient i (ft/ft)
4871
135
25,900
0.03
Output Parameters
Stagnation Distance X0 (ft)
Max Capture Half Width Ymax (ft)
Capture Half Width at Well Ywell (ft)
-28.30
88.92
44.46
-------
Capture Zone Width Calculation Results
-1
140
Stagnation point
High and low transimissivity
High!
Low T
Extraction Well
Capture zone half width
atwell(Ywell)
High transmissivity
Capture zone half width
at well (Ywe,
Low transmissivity
Max capture zone half width
(Ymax) High transmissivity
.499.
Max capture zone half width
(Ymax) Low transmissivity
-------
Technical Assistance Item #1
Presented January 24, 2005
Information regarding replacement pumps for the extraction well
A contact from Pumps-On-Line (877-863-5360), provided a quote of $2,800 (for pump and motor)
delivered to the site via common carrier. Please note that the attached quote of $4,320 is the Grundfos
list price and that the $2,800 reflects a discount offered by the vendor. Actual installation costs would
be somewhat higher, but should be under $10,000. A comparable Goulds pump (6DLC020 or 1 SOL 15 6
stage) was not available from the same vendor, but list prices quotes obtained directly from Goulds
ranged from $4,000 to $4,700.
-------
Company name: Pumps Online, Inc
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Date: 1/11/2005
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Products
1x1505150-6 Prod. No.: 13B73606
Sizing Results
Flow: 1 68 US GPM (32883650 US gal/year)
Total head: 200 ft
Power P1: 10.9kW
Power P2: 11. 8 HP
Efficiency pump: 72.0 %
Efficiency motor: 81 .0 %
Efficiency total: 58.3 %
Consumption: 39810 kWh/Year
Specific energy consumption: 1 .21 08 kWh/1 000 gal (4.63 kWh/gal/ft)
Energy costs: 2787 $/Year
Motor type: Super -6"
Phase: 3
Voltage: 460 V
Frequency: 60 Hz
Current (rated): 23.7 A
Current (actual): 23.7 A
Cos phi (actual): 0.85
Dimensional C
5 57
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11
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1/6
-------
Company name: Pumps Online, Inc
Created by:
Phone:
Fax:
Date:
David
(877) 863-5360
(630) 355-5604
1/11/2005
Position
Count
Description
Single Price
1 SOS 150-6
$4,320.00
Note! Product picture may differ from actual product
Product No.: 13B73606
Multi-stage submersible pump for raw water supply,
groundwater lowering and pressure boosting. The
pump is suitable for pumping clean, thin, non-agressive
liquids without solid particles or fibres.
The pump is made entirely of Stainless steel
DIN W.-Nr. 1.4301 DIN W.-Nr. and suitable for
horizontal as well as vertical installation.
The pump is fitted with a built-in non-return valve.
The motor is a 3-phase motor of the canned
type with sand shield, liquid-lubricated bearings
and pressure equalizing diaphragm.
Liquid:
Max liquid t at 0.08 m/sec:86 °F
Pumped liquid:Drinking water
Technical:
Rated flow:150 US GPM
Flow (Pump):168 US GPM
Rated head:226 ft
Head:200 ft
Materials:
Material, pump:Stainless steel
1.4301 DIN W.-Nr.
304 AISI
Material, impeller:Stainless steel
1.4301 DIN W.-Nr.
304 AISI
Material, motor:Stainless steel
1.4301 DIN W.-Nr.
304 AISI
Installation:
System pressure:1450 psi
Min inlet pressure:-5.3 psi
Minimum pre-charge pressure:0 psi
Size, pump outlet:3" NPT
Motor diameter:6" inch
Minimum borehole diameter:6" in
Electrical data:
Motor type:Super - 6"
2/6
-------
Company name: Pumps Online, Inc
0^. ^ Created by: David
^^yr Phone: (877)863-5360
C R U N D F O S> * 4 \ Fax: (630) 355-5604
Date: 1/11/2005
Position
Count
Description
P2 :15 HP
Mains frequency: 60 Hz
Rated voltage: 3 x 460 V
Starting method: direct-on-line
Service factor: 1,15
Rated current: 2 0.8 A
23.7 A
Starting current: 133 A
Cos phi - power factor: 0,8 5
Rated speed: 3450 rpm
Full load motor efficiency: 81, 0 %
Single Price
3/6
-------
Company name: Pumps Online, Inc
Created by:
Phone:
Fax:
Date:
David
(877) 863-5360
(630) 355-5604
1/11/2005
13B73606150S150-6
320
280
240
200
Q= 168USGPM
H = 200 ft
P2 = 11.8HP
P1 =10.9kW
Eff. pump = 72 %
Eff. pump+motor = 58.3 %
Es = 1.2109kWh/1000gal
n = 3480 rpm
160
120
20
40
60
80
100
120
140
160
180 Q(USGPM)
P2
(HP)
20
16
12
4
0
4/6
-------
Company name: Pumps Online, Inc
Created by: David
Phone: (877) 863-5360
\ Fax: (630)355-5604
Date: 1/11/2005
13B73606150S150-6
in
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3" NPT
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>
,
)
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I
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/
1:
V1
1 6"
(O
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J i J.
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Note! All units are in [mm] unless others are stated.
5/6
-------
Company name: Pumps Online, Inc
0^. ^ Created by: David
^^^ Phone: (877)863-5360
tf^i n> jj i^i rp cri^ «*g * ^\ Fax: (530)355-5604
Date: 1/11/2005
13B73606150S150-6
Input
General
Installation
Flow
Allowed flow oversize
Allowed flow undersize
Capacity selection
Operating days per year
Operation hours per day
Head
Pipe system friction losses
Include cable in calculation
Frequency
Phase
Voltage
Speed regulation
Evaluation criterion
Configuration
Pump search
Life Cycle Costs
Sizing for Pump B
Comparison with
Energy price (high)
Energy price (medium)
Energy price (low)
Calculation period
Inflation rate
Operation per day (high)
Operation per day (medium)
Operation per day (low)
Well installation, no tank
150 US GPM
50%
0%
Flow
365 d
10 h
200ft
Oft
No
60 Hz
3
460V
No
Electricity consumption
Standard pump search
No
No
0.2 $/kWh
0.12$/kWh
0.07 $/kWh
15 years
3%
Oh
Oh
10 h
Sizing result
Type 150S150-6
Quantity * Motor 1 * 1 5 HP , 460 V
Flow 168 US GPM (+12%)
H total 200 ft
Power P1 10.9 kW
Power P2 11.8 HP
Current (rated) 23.7 A
Current (actual) 23.7 A
Cos phi (actual) 0.85
Eff. pump 72.0 %
Eff. motor 81 .0 %
Eff. total 58.3 % =Eta pump * Eta motor
Flow total 32883650 US gal/year
spec.Consumpt. 1.2108 kWh/1000gal
4.63 kWh/gal/ft
Consumption 39810 kWh/Year
Price $ 4320
Energy cost $ 2787 /Year
Total costs $57717 /Years
H 150S150-6
(ft). — _
"^ — ~~^
^*X%>""^
280 ^*x\.
^""•x^
240 ^SXS_
160 N,
Q = 168 US GPM \
120 H=200ft
P2 = 11.8HP
80 P1 =10.9kW
Eff. pump = 72 %
40 Eff. pump+motor = 58.3 %
Es = 1.2109kWh/1000gal
n = 3480 rpm
0 20 40 60 80 100 120 140 Q(US GPM)
P2
(HP)
16
4
0
6/6
-------
APPENDIX B:
BASELINE SITE INFORMATION SHEET AND
OPTIMIZATION EVALUATION REPORT
Note: The attached information sheet was generated during an original nationwide screening effort in
2000 and 2001 and has a different format than the currently used information sheet included in Section 1
of this document.
-------
Hellertown Manufacturing
Bethlehem, PA (Region 3)
CERCLIS ID PAD002390748
Contact Information
RPM
Cesar Lee
1650 Arch Street
Philadelphia, PA 19103
215-814-3205 (phone)
215-814-3205 (fax)
lee.cesar@epa.gov
State Regulator
Meg Mustard
PADEP
4530 Bath Pike
Bethlehem, PA 18017
610-861-2076 (phone)
610-861-2072 (fax)
boyer.margaret@dep.state.pa.us
Contractor
Jim Romig
COM Federal Corporation
993 Old Eagle School Road, Suite 408
Wayne, PA 19087
610-293-0450 (phone)
610-293-1920 (fax)
romigjm@cdm.com
System Information and Data
Type of Fund-lead Site:
Date original ROD was signed:
Date of last modification to ROD:
Type of ROD:
Status of P&T system:
Primary goal of system:
Presence of NAPLs
Approximate annual O&M costs:
Costs related to monitoring:
Approximate pumping rate:
Result of previous evaluation of
peformance/effectiveness:
EPA-lead
9/3/91
Final
Operational
Containment & Restoration
Not present
$350,000
$150,000
SOgpm
Evaluated and found not sufficient
Number of extraction wells:
Date of construction completion:
Date of operational and functional:
Expected date of turnover to state:
Expected date of completion:
Approximate downtime per year:
Number of monitoring wells used:
Frequency of sampling:
Is plume migration controlled?
Progress of aquifer restoration:
Difficulty (due to social/political factors) of
implementing minor/major changes:
1
9/1996
3/1996
9/2006
9/2026
0 weeks
12
4 times per year
Yes
Don't know
minor/moderate
Contaminants of Concern:
Benzene
Cis-1,2-dichloroethene
TCE and Vinyl chloride
Trans 1,2-Dichloroethylene
Trichlorethylene (TCE)/Tetrachloroelthylene (PCE)
Treatment Processes:
Metals precipitation
Air stripping
Biological treatment
UV oxidation
Carbon adsorption
Filtration
Ion Exchange
Reverse Osmosis
Off-gas treatment
other/not sure
yes
yes
Comments:
Doug Sutton filled this out based on hand written notes of Cesar Lee.
-------
REMEDIATION SYSTEM EVALUATION
HELLERTOWN MANUFACTURING COMPANY SUPERFUND SITE
HELLERTOWN, PENNSYLVANIA
Report of the Remediation System Evaluation,
Site Visit Conducted at the Hellertown Manufacturing Superfund Site
JuneS, 2001
Final Report
November 14, 2001
US Army
Corps of Engineers
US Environmental
Protection Agency
-------
EXECUTIVE SUMMARY
The Hellertown Manufacturing Superfund Site, located in Hellertown, Pennsylvania 1.5 miles south of
Bethlehem, Pennsylvania, is approximately 8.6 acres and addresses trichloroethylene (TCE)
contamination of the ground water resulting from operations of a former spark-plug manufacturing
facility. The initial Remedial Investigation found that the primary sources of contamination are onsite
lagoons once used for containing process water laden with chemicals including TCE. The Record of
Decision required placement of an asphalt cap covering the former lagoon area and a pump-and-treat
system to address the ground water contamination. Construction of the asphalt cap was completed in
1994 and operation of the pump-and-treat system began in February 1996.
Ground water TCE concentrations as sampled during November 2000 are an order of magnitude
lower than they were during the Remedial investigation nearly 10 years earlier. In November 2000
TCE concentrations downgradient of the lagoons were as high as 190 ug/L. TCE concentrations
upgradient of the lagoons as high as 140 ug/L were also detected in November 2000 suggesting a
potentially uncharacterized source on site.
In general, the RSE team found a well-operated system. Recommendations to improve system
effectiveness include the following:
• An additional monitoring well downgradient of the site should be installed and sampled to help
delineate the plume. Water level measurements from this well would also help in generating
a more accurate potentiometric surface downgradient of the extraction well thereby-
elucidating the extent of the capture zone.
• The ground water extraction system consists of a single well that is currently operating at 110
gpm rather than the designed rate of 160 gpm. A steady decrease from 160 gpm has been
noticed since February 2000. Given that this well is solely responsible for containing the
plume and extracting contaminated ground water, the well and pump should be evaluated and
possibly replaced.
• Institutional controls and deed restrictions are required by the Record of Decision and were
mentioned in the five-year review. However, these controls have not yet been implemented.
Institutional controls and deed restrictions should be implemented.
• TCE concentrations of 140 ug/L upgradient of the lagoons suggest the possibility of another
source area (likely associated with the old equipment washing area or with the old
ground water treatment system, which is still in place). An initial investigation using a
GeoProbe to collect soil gas and water samples should be conducted to better delineate this
contamination.
These recommendations might require approximately $75,000 in capital costs and might increase
annual costs by approximately $5,000 per year.
-------
Recommendations to reduce life-cycle costs include the following:
• Ground water is extracted at approximately 150 gallons per minute with an approximate
concentration of 40 ug/L. This translates to a approximately 30 pounds of TCE extracted and
treated per year. Current annual costs for the system total approximately $130,000 per year
(excluding analytical costs). With a capital investment of approximately than $125,000 this
cost could likely be reduced to approximately $110,000 per year if extracted water is treated
only with liquid phase carbon. Furthermore, with this recommendation the treatment system
process monitoring could be reduced, potentially saving an additional $10,000 per year. Thus,
with a potential savings of $30,000 per year, the site managers should consider replacing the
current treatment system with liquid phase carbon treatment. However, a pilot test should be
conducted prior to implementation to ensure carbon usage is as projected.
• Regardless of revamping the treatment system, the building heat should be reduced. The
building is kept at 60 to 65 degrees Fahrenheit but only needs to be as high as 35 or 40
degrees Fahrenheit to protect against freezing. This would save approximately $1,000 per
year in costs for natural gas.
Finally, cleanup limits for the site have yet to be determined. The Record of Decision mentioned that
if background levels are lower than the maximum contaminant levels, then background contaminant
levels or the detection limit would be the cleanup level. Such cleanup levels would be stricter than
those set at the large majority of Superfund sites. The RSE team recommends that the cleanup levels
be established so that an exit strategy can be developed.
A summary of recommendations, including estimated costs and/or savings associated with those
recommendations, is presented in Section 7.0 of the report.
-------
PREFACE
This report was prepared as part of a project conducted by the United States Environmental
Protection Agency (USEPA) Technology Innovation Office (TIO) and Office of Emergency and
Remedial Response (OERR). The objective of this project is to conduct Remediation System
Evaluations (RSEs) of pump-and-treat systems at Superfund sites that are "Fund-lead" (i.e., financed
by USEPA). RSEs are to be conducted for up to two systems in each EPA Region with the
exception of Regions 4 and 5, which already had similar evaluations in a pilot project.
The following organizations are implementing this project.
Organization
Key Contact
Contact Information
USEPA Technology Innovation
Office
(USEPA TIO)
Kathy Yager
11 Technology Drive (ECA/OEME)
North Chelmsford, MA 01863
617-918-8362
yager.kathleen@epa.gov
USEPA Office of Emergency and
Remedial Response
(OERR)
Paul Nadeau
1200 Pennsylvania Avenue. NW
Washington, DC 20460
Mail Code 5201G
phone: 703-603-8794
fax: 703-603-9112
nadeau.paul@epa.gov
GeoTrans, Inc.
(Contractor to USEPA TIO)
Rob Greenwald
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
(732) 409-0344
Fax: (732) 409-3020
rgreenwald@geotransinc. com
Army Corp of Engineers:
Hazardous, Toxic, and Radioactive
Waste Center of Expertise
(USACE HTRW CX)
Dave Becker
12565 W. Center Road
Omaha, NE 68144-3 869
(402) 697-2655
Fax: (402) 691-2673
dave.j.becker@nwd02.usace.army.mil
111
-------
The project team is grateful for the help provided by the following EPA Project Liaisons.
Region 1 Darryl Luce and Larry Brill
Region 2 Diana Curt
Region 3 Kathy Davies
Region 4 Kay Wischkaemper
Region 5 Dion Novak
Region 6 Vincent Malott
Region 7 Mary Peterson
Region 8 Armando Saenz and Richard Muza
Region 9 Herb Levine
Region 10 Bernie Zavala
They were vital in selecting the Fund-lead P&T systems to be evaluated and facilitating
communication between the project team and the Remedial Project Managers (RPM's).
IV
-------
TABLE OF CONTENTS
EXECUTIVE i
PREFACE in
TABLE OF CONTENTS v
1.0 INTRODUCTION 1
1.1 PURPOSE 1
1.2 TEAM COMPOSITION 2
1.3 DOCUMENTS REVIEWED 2
1.4 PERSONS CONTACTED 3
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS 3
1.5.1 LOCATION 3
1.5.2 POTENTIAL SOURCES 3
1.5.3 HYDROGEOLOGIC SETTING 4
1.5.4 DESCRIPTION OF GIOUND WATER PLUME 4
2.0 SYSTEM DESCRIPTION 6
2.1 SYSTEM OVERVIEW 6
2.2 EXTRACTION SYSTEM 6
2.3 TREATMENT SYSTEM 6
2.4 MONITORING SYSTEM 7
3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE CRITERIA 8
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA 8
3.2 TREATMENT PLANT OPERATION GOALS 9
3.3 ACTION LEVELS 9
4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT 10
4.1 FINDINGS 10
4.2 SUBSURFACE PERFORMANCE AND RESPONSE 10
4.2.1 WATER LEVELS 10
4.2.2 CAPTURE ZONES 10
4.2.3 CONTAMINANT LEVELS 11
4.3 COMPONENT PERFORMANCE 12
4.3.1 EXTRACTION WELL AND PIPING 12
4.3.2 EQUALIZATION TANK 12
4.3.3 PACKED TOWER 12
4.3.4 AIR COMPRESSORS/BLOWERS 12
4.3.5 CARTRIDGE FILTERS 12
4.3.6 EXTRACTION .AND PROCESS PUMPS 12
4.3.7 VAPOR PHASE GRANULAR ACTIVATED CARBON 13
4.3.8 BUILDING AND UTILITIES 13
4.3.9 CONTROLS 13
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF MONTHLY COSTS 14
4.4.1 UTILITIES 14
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS 14
4.4.3 LABOR 14
4.4.4 CHEMICAL ANALYSIS 14
-------
4.5 RECURRING PROBLEMS OR ISSUES 15
4.6 REGULATORY COMPLIANCE 15
4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL CONTAMINANT/REAGENT
RELEASES 15
4.8 SAFETY RECORD 15
5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT 16
5.1 GROUND WATER 16
5.2 SURFACE WATER 16
5.3 AIR 16
5.4 SOILS 16
5.5 WETLANDS AND SEDIMENTS 16
6.0 RECOMMENDATIONS 17
6.1 RECOMMENDED STUDIES TO ENSURE EFFECTIVENESS 17
6.1.1 ANALYZE CAPTURE ZONE FOR GROUND WATER EXTRACTION WELL 17
6.1.2 EVALUATE EXTRACTION WELL PRODUCTION 17
6.1.3 IMPLEMENT INSTITUTIONAL CONTROLS 17
6.1.4 EVALUATE OLD PRETREATMENT .AREA 18
6.2 RECOMMENDED CHANGES TO REDUCE COSTS 18
6.2.1 CONSIDER MODIFYING TREATMENT PROCESSES TO LIQUID-PHASE CARBON ONLY 18
6.2.2 LOWER BUILDING TEMPERATURE TO LOWER UTILITY COSTS 19
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT 20
6.3.1 STOP PERFORMING DATA VALIDATION 20
6.4 MODIFICATIONS INTENDED TO GAIN SITE CLOSE-OUT 20
6.4.1 ESTABLISH CLEANUP GOALS FOR THE AQUIFER 20
6.5 UNUSED EQUIPMENT 20
7.0 SUMMARY 21
List of Tables
Table 3-1. Maximum Contaminant Level for each Contaminant of Concern
Table 3-2. Pennsylvania DEP Discharge Criteria for the Hellertown Site
Table 4-1. TCE Concentrations
Table 7-1. Cost Summary Table
List of Figures
Figure 1-1 Site layout showing the locations of the monitoring wells and the extraction well
Figure 1-2 Cross section of the geology underlying the Hellertown Manufacturing Superfund Site
VI
-------
1.0 INTRODUCTION
1.1 PURPOSE
In the OSWER Directive No. 9200.0-33, Transmitted of Final FYOO - FYOJ Superfund Reforms
Strategy, dated July 7,2000, the Office of Solid Waste and Emergency Response outlined a
commitment to optimize Fund-lead pump-and-treat systems. To fulfill this commitment, the US
Environmental Protection Agency (USEPA) Technology Innovation Office (TIO) and Office of
Emergency and Remedial Response (OERR), through a nationwide project is assisting the ten EPA
Regions in evaluating their Fund-lead operating pump-and-treat systems. This nationwide project is a
continuation of a demonstration project in which the Fund-lead pump-and-treat systems in Regions 4
and 5 were screened and two sites from each of the two Regions were evaluated. It is also part of a
larger effort by TIO to provide USEPA Regions with various means for optimization, including
screening tools for identifying sites likely to benefit from optimization and computer modeling
optimization tools for pump and treat systems.
This nationwide project identifies all Fund-lead pump-and-treat systems in EPA Regions 1 through 3
and 6 through 10, collects and reports baseline cost and performance data, and evaluates up to two
sites per Region. The site evaluations are conducted by EPA-TIO contractors, GeoTrans, Inc. and
the United States Army Corps of Engineers (USAGE), using a process called a Remediation System
Evaluation (RSE), which was developed by USAGE. The RSE process is meant to evaluate
performance and effectiveness (as required under the NCP, i.e., and "five-year" review), identify
cost savings through changes in operation and technology, assure clear and realistic remediation goals
and an exit strategy, and verify adequate maintenance of Government owned equipment.
The Hellertown Manufacturing Company Site was chosen based on initial screening of the pump-and-
treat systems managed by USEPA Region 3 as well as discussions with the EPA Remedial Project
Manager for the site and the Superfund Reform Initiative Project Liaison for that Region. This report
provides a brief background on the site and current operations, a summary' of the observations made
during a site visit, and recommendations for changes and additional studies. The cost impacts of the
recommendations are also discussed.
A report on the overall results from the RSEs conducted for this system and other Fund-lead P&T
systems throughout the nation will also be prepared and will identify lessons learned and typical costs
savings.
-------
1.2
TEAM COMPOSITION
The team conducting the RSE consisted of the following individuals:
Frank Bales, Chemical Engineer, USAGE, Kansas City District
Rob Greenwald, Hydrogeologist, GeoTrans, Inc.
Lindsey Lien, Environmental Engineer, USAGE HTRW CX
Doug Sutton, Water Resources Engineer, GeoTrans, Inc.
1.3
DOCUMENTS REVIEWED
Author
EPA Region III
Environmental Strategies
Corp.
Ecology and Environment,
Inc
Ecology and Environment,
Inc
CH2MHill
Roy F. Weston, Inc
EPA Region III
EPA Region III
COM
CDM
COM
Date
September 30, 1991
June 17, 1991
August 1994
June 1994
June 7, 1996
October 1998
January 27, 1999
August 1999
November 1999
April 2000 through
February 2001
March 23, 2001
Title/Description
Record of Decision
Draft Remedial Investigation Report
Hydrogeological Conditions Evaluation
Design Basis Report for Remedial Design
Activities
Construction Report
Design Review Results and
Recommendations
Scope of Work
Five Year Review
Draft Operation and Maintenance Plan
Monthly Discharge Monitoring Reports
Annual Operations and Maintenance
Report
-------
1.4 PERSONS CONTACTED
The following individuals were present for the site visit:
Frank Bales (USAGE) 816-983-3591 francis.e.bales@usace.army.mil
Kathy Davies (USEPAReg. 3) 215-814-3315 davies.kathy@epa.gov
Rob Greenwald (GeoTrans) 732-409-0344 rgreenwald@geotransinc.com
Cesar Lee (USEPA Reg. 3) 215-814-3205 lee.cesar@epa.gov
Lindsey Lien (USAGE) 402-697-2580 lindsey.k.lien@usace.army.mil
Paul Nadeau (USEPA OERR) 703-603-8794 nadeau.paul@epa.gov
Bernice Pasquini (USEPA Reg. 3) 215-814-3326 pasquini.bemice@epa.gov
Jim Romig (COM Federal) 610-293-0450 romigjm@cdm.com
Mindi Snoparsky (USEPA Reg. 3) 215-814-3316 snoparsky.mindi@epa.gov
Doug Sutton (GeoTrans) 732-409-0344 dsutton@geotransinc.com
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS
1.5.1 LOCATION
The Hellertown Manufacturing Superfund Site is approximately 8.6 acres and is located on Main
Street (Route 412) in Hellertown. Borough. Northampton County. Pennsylvania. The remedy at the
site addresses contamination from the manufacturing of spark plugs which began at that location in
1918 and was discontinued in 1982. The surrounding area is a combined residential and commercial
area approximately 1.5 miles south of Bethlehem, Pennsylvania. The site is bordered on the north by
Interstate 78, on the east by Main Street, on the south by private residences, and on the west by a
Conrail railyard. Saucon Creek is located on the far west side of the railroad property approximately
600 feet from the western boundary of the site. The site layout is depicted in Figure 1-1.
The warehouse onsite was purchased by Paikes Enterprises, Inc. in 1988 and used as a warehouse.
The current property owner is Federal Mogul.
1.5.2 POTENTIAL SOURCES
During operations at the spark-plug plant from 1930 to 1976, five unlined discharge lagoons were
maintained to treat aqueous discharges. Discharges consisted of various chemicals including sodium
and potassium nitrates and nitrites, alkaline wastes, cyanide, zinc, hexavalent chromium, and
trichloroethylene. In 1965 a wastewater treatment plant was added to the facility. In 1971 this plant
was upgraded by installing sludge drying beds, and in 1976, the lagoons were backfilled. A Remedial
Investigation was conducted from 1988 to 1991 to investigate the extent of contamination site. The
investigation did find soil and ground water contamination associated with the lagoons, especially
lagoon #4, but did not find significant contamination associated with underground storage tanks or an
equipment wash area also located at the site. The Remedial investigation was followed by a Record
of Decision on September 30, 1991 specifying an asphalt cap, institutional controls, and a pump-and-
treat system. The asphalt cap covering the former lagoon area was completed in 1994. Elements of
the wastewater treatment system and the sludge drying beds were left in place.
-------
It is believed that contaminants including TCE infiltrated through the unlined lagoons into the aquifer.
The lagoons were dredged and backfilled, and soil samples indicated volatile organic compounds
(VOCs) at levels less than 1 mg/kg, with the highest concentrations found near lagoon 4 in the
northwest comer of the site. The monitoring wells show that VOCs have been transported offsite in
ground water toward Saucon Creek at levels that exceed MCLs. In contrast to the findings of the
Remedial Investigation, it appears that the elements of the old wastewater treatment system or
equipment wash area may have been a potential source of TCE. because an overburden well
approximately 100 feet downgradient of those features (CSP-7) had a TCE concentration of 140
ug/L in November 2000. That well is located upgradient of the lagoons, which have historically been
interpreted as the primary source of ground water impacts.
1.5.3 HYDROGEOLOGIC SETTING
Figure 1-2, taken from the Hydrogeological Conditions Evaluation, depicts the geologic units observed
at the site. This figure depicts a northwest-southeast cross section of the stratigraphic units and the
monitoring and extraction well locations. The site elevation ranges from approximately 320 feet
above mean sea level (MSL) in the east to approximately 280 feet MSL in the west. Beneath the
asphalt cap installed in 1994, the stratigraphy includes 10 feet of overburden and 30 feet of saprolite
and phyllitic schist overlaying fractured dolostone identified with the Tomstown formation. A
sandstone layer 10 feet thick exists within the dolostone formation at a depth ranging from 80 to 100
feet below ground surface (bgs).
Two permanent zones of saturation are of concern at the site: an intermediate zone, existing 15 to 95
feet bgs occurring primarily in the weathered saprolite; and a deep zone, existing approximately 95 to
greater than 215 feet bgs occurring in the dolostone which is fractured and exhibits characteristics of
solution weathering and channelized flow. The saprolite acts as a semiconfining layer above the
deeper fractured and weathered zone. In both zones, water flows to the west-northwest toward
Saucon Creek although the Hydrogeological Conditions Evaluation suggests the presence of
significant vertical gradients responsible for transporting TCE to deeper elevations 295 feet bgs as
detected in CSP-24. Flow in the deep zone may continue beyond Saucon Creek before rising and
returning to discharge into the creek.
1.5.4 DESCRIPTION OF GROUND WATER PLUME
The plume consists primarily of TCE and cis-1,2 dicholorethylene, a degradation product of TCE.
The highest TCE concentration as measured during the November 2000 sampling event is 190 ug/L
and was measured in a sampled taken from monitoring well CSP-14, a shallow monitoring well
located immediately downgradient of the northwest corner of the site (specifically downgradient of
lagoon #4). Other shallow wells in the same area measured during the same sampling event have
concentrations of 150 ug/L, 80 ug/L, and 33 ug/L. A deep monitoring well located adjacent to these
wells but over 100 feet deeper had a concentration of 43 ug/L. A single monitoring well screening the
overburden, CSP-7, which is located 100 feet downgradient of the old wastewater treatment plant
(upgradient of the lagoons), had a concentration of 140 ug/L in November 2000. Another monitoring
well screening the shallow bedrock, CSP-10, also located upgradient of the lagoons, had a TCE
concentration of 27 ug/L and a DCE concentration of 42. The impacts at CSP-7 and CSP-10 suggest
that at least a portion of the plume formed upgradient of the waste lagoons.
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TCE contamination in ground water has migrated beyond the site boundary. Unfortunately, there are
no monitoring wells between the wells near immediate site boundary and the wells near Saucon
Creek. Therefore, it is difficult to characterize the plume in that region, which is immediately
downgradient of the remediation well. Low concentrations in ground water have historically been
found in the overburden along the eastern bank of Saucon Creek. For instance, CSP-16 has had
TCE as high as 6.3 ug/1 in 1999, although all other readings since 1996 have been below 5 ug/1 at that
well. CSP-18, a shallow ground water well near Saucon Creek, had TCE of approximately 50 ug/L in
1990 and 1993, but all samples there have been "non-detect" since 1996. It should also be noted that
there are no wells near Saucon Creek immediately downgradient of well CSP-14, where highest
ground water concentrations are observed. TCE has also been infrequently detected at very low
concentrations (2 ug/1 or less) in the deep ground water zone, more than 1,000 feet to the west of
Saucon Creek (i.e., on the other side). It is not clear that those impacts are related to this site.
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2.0 SYSTEM DESCRIPTION
2.1 SYSTEM OVERVIEW
The remedy for the Hellertown Manufacturing Site specified in the ROD includes the following items:
• placement of an impermeable cover over the entire former lagoon area;
• surface water runoff controls;
• ground water extraction from one well located on-site, above-ground treatment (air stripping
and cartridge filtration), and discharge to Saucon Creek;
• long term ground water monitoring; and
• deed restrictions.
The site was covered with asphalt in December 1994, and construction completion of the
ground water extraction well and treatment plant occurred in January 1996 with full time operation
beginning in February 1996. The plant was down for a period of 17 months while a new well was
installed to replace the original extraction well.
2.2 EXTRACTION SYSTEM
The extraction system consists of one well, EW-1. Originally installed in 1993 in the location of
former lagoon 4, EW-1 originally had a screened interval from 115.5 to 215.5 feet bgs (163 to 63 feet
MSL). Although the well was designed to pump 160 gallons per minute (gpm), it only yielded 90 gpm.
The well was replaced by a new well in 1998-1999, EW-1R, in the same approximate location with a
screened interval ranging from 84 to 219 feet bgs (199 to 63 feet MSL). The new well and pump are
designed to extract 160 gallons per minute (gpm), and although the well was operated at
approximately 160 gpm for a while, in was observed in February 2000 to be cavitating at 160 gpm,
and flow rate has been periodically decreased in 10 gpm increments since then to the current rate of
approximately 110 gpm.
2.3 TREATMENT SYSTEM
According to the construction report(CH2MF£ILL, 1996) the ground water treatment system was
designed with a treatment capacity of 100 gpm, an influent concentration of 970 ug/L (or parts per
billion by mass), and an effluent concentration of 1 ug/L. However, it was stated many times during
the RSE site visit that the wells were designed to extract at 160 gpm, and the system is certainly sized
to handle at least that flow rate. The system consists of the following elements:
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equalization tank,
cartridge filters.
air stripping tower,
vapor phase granular activated carbon (GAC),
and discharge piping to Saucon Creek.
The entire system is contained in a building heated by two boilers (which are also used to heat the
influent into the vapor phase GAC), and the interior piping for the water is insulated. The system
allows remote operation. An operator/maintenance engineer visits the site twice each month, and an
auto dialer calls the plant engineer when the system shuts down. The plant cannot be restarted
remotelv.
2.4 MONITORING SYSTEM
The monitoring system consists of 30 ground water monitoring wells, a portion of which are sampled
on a quarterly basis. The November 2000 sampling event involved VOC analysis from four
overburden wells, 19 shallow wells, and four deep wells. In addition, semi-annually the surface water
and sediments from Saucon Creek are measured and the ground water elevations from all 30
monitoring wells and the extraction well are measured.
Plant influent and effluent are measured twice per month and air influent and effluent for the air
stripper is sampled once every two months with a photo-ionization detector.
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3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE
CRITERIA
3.1
CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA
The goal as specified in the ROD is to restore the aquifer to either the maximum contaminant levels
(MCLs), which are listed in Table 3-1, or applicable State background concentrations, whichever is
more stringent. These State background levels were to be determined by sampling subsequent to the
ROD and before treatment began. If the contaminants of concern were not detected in background
samples, the detection limits are to be used as the cleanup levels. The 5-year review authored in 1999
states that EPA has not yet determined background concentrations, and that "upon determining the
background concentrations...EPA, in accordance with the ROD, will determine the remediation goal
for this site". These cleanup goals have not yet been formally stated in the site documents reviewed
by the RSE team. Along with the MCLs, the detection limits for contaminants are provided in Table
3-1. The discharge criteria to Saucon Creek listed in Table 3-2.
Table 3-1: Maximum Contaminant Level for each Contaminant of Concern
Contaminant
Benzene
Tetrachloroethylene
Trichloroethylene
Vinyl chloride
trans-1,2 Dichloroethylene
cis-1,2 Dichloroethylene
MCL
(ug/L)
5
5
5
2
100
70
Detection
Limit
(ug/L)
0.20
0.03
0.12
0.18
0.10
0.12
Analytical Method
601/602
601/602
601/602
601/602
601/602
524.2
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Table 3-2: Pennsylvania DEP Discharge Criteria for the Hellertown Site
Effluent Parameter
Benzene
Total BTEX*
Tetraehloroethylene
Trichloroethylene
Vinyl chloride
trans 1,2DCE
cisl,2DCE
Average
Monthly Cone.
(ug/L)
1
100
1
1
1
1
1
*all concentrations in microgram per liter (ug/
Average
Daily Cone.
(ug/L)
2
200
2
2
2
2
2
Instantaneous
Maximum
Concentration
(ug/L)
2.5
250
2.5
2.5
2.5
2.5
2.5
Measurement
Frequency
2/month
2/month
2/month
2/month
2/month
2/month
2/month
Sample
Type
Grab
Grab
Grab
Grab
Grab
Grab
Grab
)
3.2
TREATMENT PLANT OPERATION GOALS
The operational goal of the plant is to maintain effluent TCE concentrations below 1 ug/L, which
agrees with the design specifications of the plant and complies with the discharge permit for that
contaminant.
3.3
ACTION LEVELS
The action levels regarding plant discharge are noted above. The five-year review states that
cleanup goals have not been established for this site.
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4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT
4.1 FINDINGS
The RSE team noted that the system is well maintained and not operated at an unusual cost. The
observations and recommendations given below 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. These recommendations obviously have the benefit of the operational data
unavailable to the original designers.
4.2 SUBSURFACE PERFORMANCE AND RESPONSE
4.2.1 WATER LEVELS
The water levels in the monitoring wells are regularly monitored. Water levels have been plotted by
CDM (e.g., CDM, 2000 Annual O&M Report) on line graphs to compare pre-pumping and post-
pumping water levels, to assess whether drawdown occurs due to pumping. The overburden wells
show little if any drawdown due to pumping. Many shallow bedrock wells show some drawdown due
to pumping, and those wells are typically near the extraction well (e.g., wells CSP-5A, CSP-5B, CSP-
6, CSP-12, CSP-13, CSP-14), while some are further away from the extraction well (CSP-11, CSP-
15, CSP-18). Shallow bedrock wells distant from the extraction well typically show little or no
drawdown associated with extraction, as expected. The three deep bedrock wells closest to the
extraction well also show drawdown due to pumping (CSP-5c, CSP-24, CSP-25). Deep bedrock
wells distant from the extraction well typically show little or no drawdown associated with extraction,
as expected.
Analysis of water level data from October 1997 when pumping was not occurring reveals information
about vertical hydraulic gradients in the absence of pumping. Water levels from CSP-5A, CSP-5B,
and CSP-5C, which are located adjacent to each other and are vertically spaced 10 feet apart,
demonstrate an upward gradient in the absence of pumping. Likewise, CSP-6 and CSP-25, which are
also adjacent but separated vertically by 100 feet also suggest an upward gradient in the absence of
pumping.
4.2.2 CAPTURE ZONES
Although the water level analysis suggests that drawdown does occur due to pumping, that
observation does not define the capture zone of the extraction well. Capture zones are based on
hydraulic gradients, which are impacted not only by drawdown due to pumping, but also by
background hydraulic gradients. A capture zone was interpreted from water level data collected
during the pumping test at the original extraction well (Ecology and Environment, 1994) that suggested
the capture zone would encompass the majority of the area associated with the former lagoons and
possibly the contamination associated with CSP-7. This former capture zone analysis did suggest that
10
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contamination in the area of wells CSP-10 and CSP-11 likely would not be captured. A more recent
interpretation of potentiometric surface was not evident in documents reviewed by the RSE team.
The November 2000 water levels provide sufficient information from the shallow bedrock wells to
suggest that ground water in the shallow bedrock near wells CSP-12, CSP-13, CSP-14, and CSP-5A
is captured by the extraction well. Data is too sparse to estimate ground water directions and capture
in the overburden and the deep bedrock or in the shallow bedrock further from the extraction well.
Because no monitoring wells or water-level measurements exist for over 400 feet to the west
(downgradient) the extent of contamination and capture is unknown downgradient of CSP-12, CSP-
13, CSP-14, and CSP-5A.
4.2.3
CONTAMINANT LEVELS
Ground water concentrations appear to be declining slightly at some wells, although TCE concentration
at many wells are still significantly higher than the MCL of 5 ug/1. It is significant to note that current
influent levels to the plant (30-40 ug/1) are significantly lower than the design influent concentration of
nearly 1,000 ug/1.
Table 4-1 presents TCE concentrations versus time at selected wells.
Table 4-1 TCE Concentrations
Date
1990
1993
D^r- 1QQQ
Mo-ir onnn
EW-1R
not
not
/I 1 =; ra-irrA
CSP-14
420
220
1QQ
1QO
ion
CSP-25
not
an aKr^^rl
310
0/1
AH
,17
CSP-6
310
350
OOA
nn
sn
CSP-13
700
150
IS/1
170
oon
i-n
CSP-12
390
110
1/1Q
onn
/!«;
77
CSP-7
180
240
i/ii
on
QQ
i/in
Note that TCE impacts are observed in all three zones (overburden, shallow bedrock,and deep
bedrock).
As stated in Section 1.5.4, there are no monitoring wells between the wells near the immediate site
boundary and the wells near Saucon Creek. Therefore, it is difficult to characterize the plume in that
region, which is immediately downgradient of the remediation well. It should also be noted that there
are no wells near Saucon Creek immediately downgradient of well CSP-14, where highest
ground water concentrations are observed. Concentrations at well CSP-18, a shallow bedrock well
near Saucon Creek, had TCE at approximately 50 ug/1 in 1990 and 1993, but has been "non-detecf
since 1996.
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4.3 COMPONENT PERFORMANCE
During the first two years of operation the plant had difficulties in meeting extraction flowrate and
discharge standards. These items were addressed by Weston in 1998 by replacing the extraction well.
upgrading some system components (pumps, distributor plate in air stripping tower) and redoing control
logic for the plant.
4.3.1 EXTRACTION WELL AND PIPING
Since being replaced in 1998, the extraction well has performed well. However, the flow rate has been
declining since February 2000, from 160 gpm to the current rate of approximately 110 gpm. The pump
is "hard-piped" with steel which requires heavy machinery to remove the pump. Therefore, it has not been
pulled to check it with respect to deterioration. The pump from the original well was available for
inspection, and showed evidence of significant corrosion (pits, holes, slits, rust).
4.3.2 EQUALIZATION TANK
The 3,000-gallon equalization tank provides capacity for only fifteen minutes of storage. The flow rate
out of the tank is controlled by the pump that forces water to the top of the air stripper. The plant runs
continuously, not in batch mode.
4.3.3 PACKED TOWER
The packed tower is 35 feet high with a packed bed depth of 24 feet. The water is distributed evenly
across the packing with a distribution plate. The packing is jaeger plastic two inch Tri-packs. No
corrosion or scaling problems have been identified.
4.3.4 BLOWER
One blower is utilized to provide forced air to the stripping tower. This unit is 7.5 hp and provides process
air at approximately 1,000 cfm.
4.3.5 CARTRIDGE FILTERS
Two parallel cartridge filters remove solids prior to entering the air stripping tower. The relatively clean
and soft water at the site does not foul these filters. The operators have changed these filters only once
since they took over operation in 1999 and noted that they showed little sign of being fouled.
4.3.6 EXTRACTION AND PROCESS PUMPS
The pumps include a well pump (15 hp) and a process pump (7.5 hp) inside the building. Both pumps have
been upgraded since 1998 renovations were performed. The process pump has not shown excessive
wear. The pumping rate of the well pump, however, has declined from 160 gpm at installation to 110 gpm
at the time of the RSE— a decrease of 10 gpm in the pumping rate occurs every 5 to 6 months. This is
due to oscillations in the pumping rate and shaking in the piping that the operator addresses by throttling
back a valve to decrease the extraction rate by 10 gpm.
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4.3.7 VAPOR PHASE GRANULAR ACTIVATED CARBON
Two vapor GAC units are on site. The process air from the air stripper is heated to lower the relative
humidity and therefore increase carbon capacity. The units each contain approximately 2.000 pounds
of activated carbon. Because influent concentrations to the plant are lower than originally designed,
carbon changeout should be very infrequent. A simple calculation is provided below:
Calculate of pounds of TCE per year in extracted ground water and assume
100% removal by air stripper.
150 gallons 40 ug 3.785 liters IP'9 kg 2.2 Ibs 1440 minutes 365 days 26 Ibs
v y ^^^^^^^^^^^^^^~ y y ^^^^^^^^^ y ^^^^^^^^^^^^^^^^^^~ y — ^^^^^^^^~
minute liter gallon ug kg day year year
Calculate pounds of vapor phase carbon per year:
5 Ibs of carbon 26 Ibs of contaminant 130 Ibs of carbon
x =
Ib of contaminant year year
Due to the low organic loading to the plant the lead unit should not require new carbon for 10 to 15
years.
4.3.8 BUILDING AND UTILITIES
The building encases the entire process including the air stripping tower. The temperature in the
winter is maintained at 60 to 65 degrees Fahrenheit. The heat for the building and for the preheater
(for vapors prior to GAC unit) are provided by two separate boilers. The operators are going to begin
a long term maintenance contract for upkeep and tuning of these units.
4.3.9 CONTROLS
The extraction well and plant are shut down for alarms including but not limited to low levels in the
extraction well, leaking in the piping, high water levels in the air stripper reservoir, low air through the
air stripper, or a high level in the building sump. The controls also allow for partial shutdown. The
extraction well is shutdown when a high level is detected in the equalization tank and the feed pump is
shutdown when a low level is detected in the equalization tank. The blower for the air stripper shuts
down if either of these signals last for longer than 30 minutes. Each alarm triggers an autodialer that
contacts the project engineer.
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
MONTHLY COSTS
The total annual cost of operations is estimated at $132,500 excluding analytical costs. The annual cost
breakdown included labor (including project management) at $93,000, travel costs of $6,500, direct
costs (utilities and materials for sampling) of $33,000. Laboratory analyses and data validation are
13
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performed under the Contract Laboratory Program (CLP), and costs are not directly assigned to the
site and therefore not included in the annual cost estimate provided above.
It should be noted that the during the information survey conducted prior to the RSE, the estimated
costs for this site were $350,000 per year. That number is also referred to in the 5-year review.
Reportedly the estimate of $350,000 per year has been used for the purpose of insuring that adequate
budget is available as a contingency because of maintenance issues in past years that have required
significant expenditure.
4.4.1 UTILITIES
Of the $33,000 spent on direct costs, approximately $15.000 is spent on electricity for running the
pumps and $5,000 is spent on natural gas for heating the building and the air entering the vapor GAC.
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS
The remainder of the direct costs are primarily spent on materials needed for the process monitoring
and quarterly sampling events. There are no disposal costs that occur on a regular basis. A reserve of
filter cartridges is available onsite, and because these filters infrequently require replace, additional
filters will not need to be purchased for a number of years.
4.4.3 LABOR
Labor, including project management, accounts for 70% of the system costs. The system is
maintained on a regular schedule by a subcontracted operator who is present at the site once every
two months. In addition, process influent and effluent are sampled twice per month by the O&M
contractor. An operations and maintenance inspection along with sampling of the plant influent and
effluent are conducted by the project manager twice per month, and aquifer sampling and water level
measurements are conducted quarterly.
4.4.4 CHEMICAL ANALYSIS
The chemical analyses (for VOC's) performed are in accordance with the surface water discharge
requirements from the State. It should be noted that this data is being validated which is not a standard
procedure for long term monitoring at pump and treat sites. As stated earlier, analyses are performed
under the CLP program, and those costs are not directly assigned to the site.
4.5 RECURRING PROBLEMS OR ISSUES
The most notable recurring problem is the decreasing flow from the extraction well. No notable
process problems have occurred. Unscheduled shutdowns have all been weather related. The boilers
have required excessive maintenance; therefore, the site is going to enter a boiler maintenance
contract to relieve this problem.
14
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4.6 REGULATORY COMPLIANCE
Compliance with discharge standards was a problem early during operation of the plant. Upon
completion of upgrading the extraction well pump, process controls, process pump and distribution
system in the tower, the treated ground water has met all discharge criteria.
4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL
CONTAMINANT/REAGENT RELEASES
The system has been shut down on several occasions. These shutdowns have almost exclusively been
caused by power outages rather than any process problems.
4.8 SAFETY RECORD
No safety issues were apparent and no safety problems or accidents were reported to have
occurred in the past. There is a broken fence that was reported in the ROD, and the fence was still
found to be broken during the RSE visit.
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5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
HEALTH AND THE ENVIRONMENT
5.1 GROUND WATER
Several monitor wells and piezometers are located on site. Some wells have shown marked decline in
site contaminants while others have shown little to no decrease in concentrations. It is not clear that
the source of contamination near CSP-7 of CSP-10 (upgradient of the lagoons) has been
characterized. The capture zone of the extraction well has not been documented since extraction
began, and while there are monitoring wells near Saucon Creek, there are no monitoring wells
immediately downgradient of the most contaminated well (CSP-14) all the way to Saucon Creek.
5.2 SURFACE WATER
Surface water in the creek is sampled upstream and downstream of the outfall twice per year. No
significant impacts have been observed. TCE was detected at a very small concentration (estimated
at 1 ppb) in one surface water sample in July 2000.
5.3 AIR
Air emissions from the GAC units are sampled two times per month using a PID. The loading to the
carbon units is minimal, and not likely to be any problem.
5.4 SOILS
Soils exposure was remedied by the asphalt cover that now covers the former lagoons and serves as a
parking lot.
5.5 WETLANDS AND SEDIMENTS
The sediments in the creek are sampled at several points up and downstream of the outfall twice per
year. Reportedly, minor detections of VOC?s in sediments of Saucon Creek have been detected both
upgradient and downgradient of the treatment plant outfall.
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6.0 RECOMMENDATIONS
6.1 RECOMMENDED STUDIES TO ENSURE EFFECTIVENESS
6.1.1 ANALYZE CAPTURE ZONE FOR GROUND WATER EXTRACTION WELL
As stated in the five year review, the capture zone (EW-1R) needs to be further evaluated to
determine if EW-1R is containing the entire plume as designed. This should include development of
potentiometric surface maps with water levels indicated and interpreted capture zone superimposed.
A one-time effort of $5,000 is appropriate, plus an additional $3,000 per year thereafter for continued
capture zone evaluation on the basis of potentiometric surface maps.
Ideally, one or more monitoring wells in the shallow bedrock should be added between CSP-14 and
Saucon Creek, to allow increased resolution for water level evaluation as well as water quality
evaluation. The ability to add one or more wells in that area may be hampered by access issues, as
well as limitations due to steep slopes immediately west of CSP-14. To add one well should cost
approximately $20,000 in capital costs, and additional sampling and analysis of that well will be less
than $2,000 per year.
6.1.2 EVALUATE EXTRACTION WELL PRODUCTION
The decrease in flow from the extraction well is a concern because it could adversely impact the
ability to maintain hydraulic control. Therefore, the pump should be removed and the pump and well
should be evaluated (although removing the pump is a difficult operation, it will need to be done). It is
suspected that this pump and screen are failing as did the previous extraction well. It may be
necessary to also evaluate the screen with a downhole camera while the pump is removed. Chemical
analysis of the water will help identify the potential agents for fouling or corrosion. Sampling should be
conducted from the extraction well for iron, manganese, sulfur minerals and complexes, pH,
conductivity, sand/silt content, carbon dioxide, carbonate, bicarbonate, and major ions including calcium
and magnesium. The cost for analyzing all of these constituents in a single sample should be
approximately $200 per sample. Cost for these combined evaluations should be less than $10,000.
The RSE team has not estimated cost for a replacement pump and/or replacement well.
6.1.3 IMPLEMENT INSTITUTIONAL CONTROLS
As required by the ROD and noted in the five year review, institutional controls are to be implemented
to prohibit the use of site ground water for a drinking water or a domestic well. Currently, this has not
be performed. Estimated cost for this activity is $15,000.
6.1.4 EVALUATE OLD PRETREATMENT AREA
Contamination in CSP-7 and possibly in CSP-10 needs to be further evaluated. The original Remedial
Investigation analyzed soil contamination near the CSP-7 and these samples showed low
concentrations of total VOCs around 50 ug/kg. That investigation, however, did not thoroughly
17
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evaluate ground water contamination. Current measurements of VOCs in the soil gas and ground water
will help to more thoroughly evaluate and delineate contamination in this area. The soil gas evaluations
would also be useful for evaluating whether or not soil gas concentrations are elevated across the
southern site boundary, in the vicinity of the frame dwelling. Because ground water is present above
the bedrock, a GeoProbe could be used to obtain soil gas and ground water grab samples in
approximately 15 locations primarily around the former equipment washing area and waste water
treatment facility. This evaluation, including hiring out a GeoProbe for two or three days and
conducting the analytical work could be accomplished for approximately $15,000. Additional
investigation would be based on results of those studies.
Given the location of present monitoring wells, it will be very difficult to determine if CSP-7 and the
surrounding plume in that vicinity are captured by the current extraction well. The importance of that
uncertainty will be more meaningfully evaluated after the extent of contamination in the vicinity of
CSP-7 and the old water treatment area is better understood, as per the recommendation described
above.
6.2 RECOMMENDED CHANGES TO REDUCE COSTS
6.2.1 CONSIDER MODIFYING TREATMENT PROCESSES TO LIQUID-PHASE CARBON ONLY
As discussed in Section 4.3.7, based on a pumping rate of 150 gpm and influent concentration of 40
ug/1, there is less than 30 Ibs of TCE removed each year from the ground water. The design influent
concentration was much higher (nearly 1,000 ug/1). It could be argued that the water extracted from
EW-1R could simply be discharged directly to the creek through the existing outfall. By the time that
water discharged to the creek, most of the TCE would have volatilized, and certainly after discharge to
the surface water the rest would volatilize. However, EPA and the Pennsylvania Department of
Environmental Protection generally prefer remedies that reduce mass rather than transfer mass into
the atmosphere. Therefore, a more palatable option would be to replace the current filter/air
stripper/vapor carbon system with a filter/liquid-phase carbon system. Given that the filters do not
appear to be removing significant amounts of solids, clogging of the filters or carbon should not be
significant a problem.
Using a conservative estimate of 300 Ibs of liquid phase carbon to one pound of contaminant the
remedy would require 9,000 Ibs of carbon per year. At $2/lb, this would equate to $ 18,000 per year of
carbon. Two GAC units each containing 10,000 Ibs of carbon and aligned in series would provide over
15 minutes of contact time in each vessel, and the lead vessel would have enough carbon treat the
water for a year. Water could be sampled after the primary unit to help determine when it needs
replacement and after the secondary' unit to determine if the effluent concentration is below the
discharge criteria. Due to chemical loading and potential fouling, the lead unit may require
replacement once a year. During this replacement, the secondary unit would become the primary unit,
and the replacement vessel would become the secondary unit.
The air stripper and the current vapor phase carbon units could be removed and the new liquid phase
carbon units could be plumbed into the current system after the cartridge filters. To avoid the costs of
heating the entire treatment plant, a small insulated room with a small electric heater could be
constructed within the current treatment building to house the cartridge filters and the new carbon
18
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units. The heater would keep the small room at 50 degrees Fahrenheit during the winter thereby
discontinuing the need for the boilers that are currently used.
Under this scenario less labor and power would be required. Although the electric heater would
require additional electricity; overall, the electricity would be reduced because the 7.5 hp blower to the
air stripper could be removed. The boilers and the natural gas would be eliminated. The visits by the
subcontracted operator once every two months could be eliminated and project management
associated with the subcontract and general maintenance issues could be reduced. In addition,
because of the simplicity of the system, someone locally could be hired to conduct site visits twice per
month and sampling of the process water.
It is estimated that these changes might require up to $125,000 to implement, but net savings in labor,
travel, and utilities costs could be $22,000 per year or more. Also, the proposed maintenance contract
for the boilers could be eliminated thus removing an expected additional cost.
With two 10,000-lb carbon units in series treating approximately 30 Ibs of contaminants per year
(requiring a conservative estimate of 9,000 Ibs of carbon per year), it is reasonable to reduce the
frequency of site visits and process monitoring. Because the second carbon unit serves as a natural
backup to the first, a site visit that includes sampling of the process water once every month would
likely be sufficient. If over time it is found that the carbon vessels are replaced less frequently than
once per year, site visits and sampling of the process water could be reduced to once every two
months. If site visits and sampling of the process water is reduced to once per month, and these visits
are made by a local contractor, an additional savings of approximately $10,000 per year could be
expected.
A comparison of the capital costs and the annual cost savings associated with this recommendation
suggests that life cycle savings would be realized after approximately 6 years of operation. Therefore,
to realize substantial costs savings, this recommendation should only be implemented if system
operation is expected to continue for 10 or more years.
Prior to implementation, a pilot test with 55 gallon drums of carbon could be conducted with a fraction
of the current extracted water (i.e., 11 gpm) to verify that actual carbon usage is similar to that
estimated in this recommendation.
6.2.2 LOWER BUILDING TEMPERATURE TO LOWER UTILITY COSTS
Under current operations, the building temperature is maintained at 60 to 65 degrees during the winter
months even though the building is only manned a few days per month. If the current treatment
process is continued, the air stripping towers can operate at subfreezing temperatures. Therefore, it is
recommended that building temperature be maintained around 35 to 40 degrees Fahrenheit. This might
reduce heating costs by $1,000 year.
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6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT
6.3.1 STOP PERFORMING DATA VALIDATION
The need to validate the monitoring data should be revisited as this step is typically only required for
site investigation and not for operation. This reduction in scope will save a nominal amount of money
(apparently these costs are not directly assigned to the site) and will allow quicker use of the collected
data.
6.4 MODIFICATIONS INTENDED TO GAIN SITE CLOSE-OUT
6.4.1 ESTABLISH CLEANUP GOALS FOR THE AQUIFER
The ROD states that cleanup goals will be the more stringent of the Federal MCLs or the background
concentration established by the State. These cleanup goals have not been formally established.
These goals should be established so that the closure criteria are clear and an appropriate exit strategy
can be developed.
6.5 UNUSED EQUIPMENT
No unused equipment was noticed at this site. If recommendations in Section 6.2.1 are implemented,
there may be some unused government equipment (filters, blower, pump, etc.).
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7.0 SUMMARY
In general, the RSE team found a smoothly running treatment system and a well-operated and
maintained site. The observations and recommendations mentioned 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. These recommendations have the obvious benefit of the
operational data unavailable to the original designers.
Several recommendations are made to assure system effectiveness, reduce future operations and
maintenance costs, improve technical operation, and gain site close out. The recommendations to
improve effectiveness include investigations to help delineate the plume, and to evaluate the capture
zone of the current extraction well. The recommendations for cost reduction include a potentially
simplified system consisting only of liquid-phase carbon. Finally, clarification of cleanup goals is
recommended, since specific cleanup goals have not yet been established.
Recommendations, and estimated cost increases/decreases associated with those recommendations,
are presented in Table 7-1.
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Table 7-1. Cost Summary Table
Recommendation
6.1.1 Delineate plume and
evaluate capture zone
6. 1 .2 Evaluate extraction
well and pump
6.1.3 Implement
institutional controls
6. 1 .4 Initial investigation
near CSP -7 and old
treatment area
6.2.1
a) Switch to only
liquid-phase carbon
b) Further reduce process
monitoring
6.2.2 Reduce heating in
building (lower
temperature)
6.3.1 Stop performing data
validation
6.4. 1 Establish cleanup
levels
Reason
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Cost
Reduction
Cost
Reduction
Technical
improvement
Site Close
Estimated Change in
Capital
Costs
$25,000
$10,000
$15,000
$25,000
$125,000
$0
$0
$0
Annual
Costs
$5,000
$0
$0
$0
($22,000)
($10,000)
($1,000)
$0
$0
Lifecycle
Costs*
$175,000
$10,000
$15,000
$25,000
($535,000)
($300,000)
($30,000)
$0
$0
Lifecycle
Costs**
$105,600
$10,000
$15,000
$25,000
($230,000)
($161,100)
($16,100)
$0
$0
Costs in parentheses imply cost reductions.
* assumes 30 years of operation with a discount rate of 0% (i.e., no discounting)
** assumes 30 years of operation with a discount rate of 5% and no discounting in the first year
22
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FIGURES
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FIGURE 1-1. SITE LAYOUT SHOWING THE LOCATIONS OF THE MONITORING WELLS AND THE EXTRACTION WELL.
"—— .-—i-^- —--^--^-- r,,,""nr,Mr-u "r,r UFI I FPiOWN / \
R.R. CSP14f
YAPP ','R
frtKL1 CSP13jfcH
• ''*
(Note: This figure is adapted from Figure 2-1 from the Hellertown Manufacturing Company Site Hydrogeological Conditions Evaluation, Ecology and
Environment, August 1994.)
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FIGURE 1-2. CROSS SECTION OF THE GEOLOGY UNDERLYING THE HELLERTOWN MANUFACTURING SUPERFUND SITE.
A'
OVERBURDEN -
POTENTIOMETRIC WATER LEVEL
FOR THE DEEP AQUIFER ZONE
(Note: This figure is taken from Figure 4-1 from the Hellertown Manufacturing Company Site Hydrogeological Conditions Evaluation, Ecology and
Environment, August 1994.)
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