Final Report
Pilot Region-Based Optimization
Program for Fund-Lead Sites
in EPA Region 3
Site Optimization Tracker:
Saunders Supply Company
Superfiind Site
Chuckatuck, Pennsylvania
EPA Region III
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Solid Waste and EPA 542-R-06-006I
Emergency Response December 2006
(5102P) www.epa.gov
Pilot Region-Based Optimization Program
for Fund-Lead Sites in EPA Region 3
Site Optimization Tracker:
Saunders Supply Company Superfund Site
Chuckatuck, Pennsylvania
EPA Region III
-------
Site Optimization Tracker:
Saunders Supply Company Superfund Site
Chuckatuck, Virginia
EPA Region III
December 30, 2005
-------
SECTION 1:
CURRENT SITE INFORMATION FORM
-------
Date:
12/30/05
Filled Out By: GeoTrans, Inc.
A. Site Location, Contact Information, and Site Status
1. Site name 2. Site Location (city and State) 3. EPA Region
Saunders Supply Company Chuckatuck, VA 3
4a. EPA RPM 5a. State Contact
Andy Palestini Thomas Modena
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-3233 804-698-4183
4c. EPA RPM Email Address 5c. State Contact Email Address
palestini.andy@epa.gov tmodena@deq.state.va.us
5. Is the ground water remedy an interim remedy or a final remedy? Interim! | Final IXI
6. Is the site EPA lead or State-lead with Fund money? EPA IXI State I I
B. General Site Information
1 a. Date of Original ROD for Ground Water Remedy
09/30/1991
2a. DateofO&F
06/01/1999
3. What is the primary goal of the P&T system
(select one)?
1 1 Contaminant plume containment
1 1 Aquifer restoration
IXI Containment and restoration
1 I Well-head treatment
lb. Dates of Other Ground Water Decision Documents (e.g., ESD, ROD Amendment)
ROD Amendment - 09/27/1996
2b. Date for transfer to State
06/01/2009
4. Check those classes of contaminants that are
contaminants of concern at the site.
CD VOCs (e.g., TCE, benzene, etc.)
Kl SVOCs (e.g., PAHs, PCP, etc.)
IXI metals (e.g., arsenic, chromium, etc.)
1 I other
5. Has NAPL or evidence of NAPL been observed at the site? Yes IXI No I I
6. What is the approximate total pumping rate? 1 gpm
7. How many active extraction wells .
(or trenches) are there?
9. How many samples are collected
from monitoring wells or piezometers . .
each year? (e.g., 40 if 10 wells are
sampled quarterly)
11. What above-ground treatment processes are usec
1 I Air stripping
IXI Carbon adsorption (liquid phase only)
IXI Filtration
I | Off-gas treatment
1 I Ion exchange
8. How many monitoring wells are . 1
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)?
IXI 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% IXI 10-20%| | >20% | |
-------
C. Site Costs
1. Annual O&M costs
O&M Category
Labor: project management, reporting,
technical support
Labor: system operation
Labor: ground water sampling
Utilities: electricity
Utilities: other
Consumables (GAC, chemicals, etc.)
Discharge or disposal costs
Analytical costs
Other (parts, routine maintenance, etc.)
O&M Total
Actual1 Annual
Costs for FY04
$22,900
$30,900
$34,200
$2,000
$500
$600
$0
$27,000**
$200
$118,300
Estimated2 Annual
Costs for FY05
$22,000
$30,000
$34,000
$2,000
$500
$600
$0
$27,000**
$200
$116,300
Estimated2 Annual
Costs for FY06
$22,000
$30,000
$22,000*
$2,000
$500
$600
$0
$20,000**
$200
$97,300
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
$3,800
$3,500
$43,500***
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 costs were estimated by the ROET based on the RPM projections and
discussions during the optimization follow-up meetings.
* Decrease in ground water sampling labor reflects the expectation that the site team will
reduce the ground water monitoring frequency as indicated in the optimization evaluation.
** 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 when the site is transferred to the State after LTRA. The decrease
from FY05 to FY06 reflects the above-mentioned sampling reduction.
*** The additional $40,000 in non-routine costs projected for FY06 assumes that the site team
will implement recommendations from the optimization evaluation.
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D. Five-Year Review
1. Date of the Most Recent Five-Year Review 12/29/2004
2. Protectiveness Statement from the Most Recent Five-Year Review
I | Protective I I Not Protective
M Protective in the short-term Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
1. Determine the extent of contamination east of MW-20S/21D well nest. Results will be
analyzed to determine if additional ground water recovery wells are needed to capture a larger
plume and whether additional monitoring wells are needed east of the MW-20S/21D well nest.
2. Determine whether contaminants in the Yorktown aquifer are being controlled by the
existing extraction system. Results will be analyzed to determine if additional ground water
recovery wells are needed to remediate the Yorktown aquifer plume.
3. Institutional controls restricting using the Columbia and Yorktown aquifers as a source of
ground water must be implemented for the Kelly property.
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.
Saunders Supply Company is approximately 400 feet from Godwins Millpond, which is used
by the city of Suffolk as one of their sources of drinking water. The city, on their own
initiative, sample several of the EPA monitoring wells monthly because of their obvious
concern that their drinking water source does not become contaminated.
-------
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
February 10, 2005 (Evaluation meeting)
July 29, 2005 (Final Report)
Meeting Date
July 13, 2005
November 7, 2005
Report Date
Item
July 29, 2005 Follow-Up #1 (conducted as part of pilot project)
December 30, 2005 Follow-Up #2 (conducted as part of pilot project)
Follow-Up #3
Follow-Up #4
Follow-Up #5
Follow-Up #6
Follow-Up #7
Follow-Up #8
"x" in box indicates the item has been completed
-------
SUMMARY OF FOLLOW-UP #2
Site or System Name
Date of This Follow-Up Summary
Date of Follow-Up Meeting or Call
(Indicate if Meeting or Call)
Saunders Supply Company Superfund Site
December 30, 2005
November 7, 2005 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Kathy Davies
Eric Johnson
Peter Schaul
Peter Rich
Rob Greenwald
Doug Sutton
Steve Chang
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
GeoTrans, Inc.
U.S. EPAOSRTI
Phone
215-814-3130
215-814-3315
215-814-3313
215-814-3183
410-990-4607
732-409-0344
732-409-0344
703-603-9017
Email
kiiliiiian.nomi@cpa.sov
davies .kathyi@epa. gov
jMllSMฃl3ฃiSsliy^2Y
schaul. peterjxiepa.gov
ElMl@SISl21Jl>iJlLSM
rgrccnwald@gcotransinc.com
diy|ton@gcotrajg_inc._com
chang.stcvcn@cpa.gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Andy Palestini
Affiliation
U.S. EPA Region 3 (RPM)
Phone
215-814-3199
Email
AndvPaJcstmi^gBiigQY
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IMPLEMENTATION STATUS OF ALL RECOMMENDATIONS UNDER CONSIDERATION BUT NOT
PREVIOUSLY IMPLEMENTED
Recommendation
Recommendation
Reason
E-2.1 Prepare a Document that Clearly States and Illustrates the Conceptual Model
Protectiveness
Implementation
Status
Planned
Comments: The site team is planning to implement this recommendation. A round of monitoring with a
modified sampling technique has been conducted in response to a recommendation provided during the
previous follow-up meeting. Favorable results from this sampling would have suggested that the contamination
was immobile and would not merit continued operation of the P&T system. However, the results were not
favorable, and the site team will now proceed with improving the site conceptual model and implementing the
recommendations from the optimization evaluation.
Recommendation
Recommendation
Reason
E-2.2 Conduct a Preliminary Capture Zone Analysis
Protectiveness
Implementation
Status
In progress
Comments: Progress toward implementing this recommendation was delayed while the site team was
collecting the samples discussed in association with Recommendations E-2.1 and Fl-1. Now that the results
suggest the continued need for P&T, the site team is proceeding with this recommendation.
Recommendation
Recommendation
Reason
E-2.3 Potentially Consider Additional Monitoring Points
Protectiveness
Implementation
Status
Will not be implemented
Comments: The site team will not be able to install the additional monitoring points suggested by the ROET
due to inaccessible terrain. The site team will need to evaluate capture through other lines of evidence.
Recommendation
Recommendation
Reason
E-3.1 Reduce Monitoring Well Sampling Frequency
Cost Reduction
Implementation
Status
In progress
Comments: Progress toward implementing this recommendation was delayed while the site team was
collecting the samples discussed in association with Recommendations E-2.1 and Fl-1. Now that the results
suggest the continued need for P&T, the site team is proceeding with this recommendation.
Recommendation
Recommendation
Reason
E-4.1 Improve Annual O&M and Monitoring Reports
Technical Improvement
Implementation
Status
In progress
Comments: Progress toward implementing this recommendation was delayed while the site team was
collecting the samples discussed in association with Recommendations E-2.1 and Fl-1. Now that the results
suggest the continued need for P&T, the site team is proceeding with this recommendation.
-------
Recommendation
Recommendation
Reason
E-5.1 Base Remedy Path Forward on Findings from Implementing the Above
Recommendations
Site Closeout
Implementation
Status
In Progress
Comments: Progress toward implementing this recommendation was delayed while the site team was
collecting the samples discussed in association with Recommendations E-2. 1 and Fl-1. Now that the results
suggest the continued need for P&T, the site team is proceeding with this recommendation.
Recommendation
Recommendation
Reason
Fl-1 Conduct Monitoring with Revised Sampling Technique
Site Closeout
Implementation
Status
Implemented
Comments: The site team conducted two rounds of monitoring with the suggested sampling technique. The
results confirmed that contamination is present above standards in the aqueous phase, confirming the need to
continue the P&T remedy. The site team is proceeding with implementation of the other recommendations.
Key for recommendation numbers:
E denotes a recommendation from the original optimization evaluation
Fl, F2, etc. denote recommendations from the first, second, etc. follow-up meeting
* The number corresponds to the number of the recommendation as stated in the optimization
evaluation or follow-up summary where the recommendation was provided
RECOMMENDATIONS PREVIOUSLY IMPLEMENTED OR THAT WILL NOT BE IMPLEMENTED
None.
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
The site team was previously considering in-situ chemical oxidation; however, after
further internal consideration among the site team and discussion with the ROET, the site
team believes that an in-situ chemical oxidation application will not provide a noticeable
benefit to the site in terms of reducing operating costs or shortening the time to cleanup.
The site team is therefore no longer considering in-situ chemical oxidation.
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)
Saunders Supply Company Superfund Site
July 29, 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
kuliij ian. norm.'fflcpa . go v
schauLpgtcr@cpa.gov
davies .kathyifi-epa. gov
prickฎ1 geotrans inc.com
rgreenwald@geotraiisinc.coin
dsutto n@geotra ns i nc . co nt
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Andy Palestini
Bernice Pasquini
Affiliation
U.S. EPA Region 3 (RPM)
U.S. EPA Region 3 (Hydro)
Phone
215-814-3199
215-814-3326
Email
Andy.Palcstini@cpa.gov
pasquini.bernice@epa. gov
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IMPLEMENTATION STATUS OF PREVIOUSLY IDENTIFIED RECOMMENDATIONS
Recommendation
Recommendation
Reason
2.1 Prepare a Document that Clearly States and Illustrates the Conceptual Model
Protectiveness
Implementation
Status
Planned
Comments: The site team is planning to implement this recommendation, but a round of monitoring conducted
with a modified sampling technique will be conducted before the document is prepared. During the followup
meeting Region 3 identified that the variable results for metals are likely due to sampling the wells with a bailer,
fixing the samples for preservation, and then filtering at the lab for analysis of dissolved concentrations. At this
site in particular, the sampling with bailers is likely yielding turbid samples, and the fixative is likely dissolving
adsorbed metals prior to the filtration and analysis. Therefore, although the intent is to measure dissolved
concentrations, the sampling and analysis procedures are likely yielding total concentrations. The dissolved
metals concentrations are likely much lower than historic sampling has suggested, and the same phenomena is
likely affecting the PCP sampling as well (as suggested in the evaluation report). The sampling technique for the
site will likely be revised to low-flow sampling with a peristaltic pump and in-line filter for both metals and PCP.
At least two rounds of sampling will be conducted with the revised sampling technique before making any
decisions regarding a modification to the remedy. If the monitoring results indicate that the plume is immobile
due to contamination being absorbed to solids rather than dissolved in ground water, P&T may not be necessary.
Recommendation
Recommendation
Reason
2.2 Conduct a Preliminary Capture Zone Analysis
Protectiveness
Implementation
Status
Delayed
Comments: The implementation of this recommendation is contingent on the results of the sampling and site
conceptual model development discussed in the follow-up of Recommendation 2.1. At least two rounds of
sampling will be conducted with the revised sampling technique before making any decisions regarding a
modification to the remedy. If the monitoring results (using a revised sampling technique) indicate that the plume
is immobile due to contamination being absorbed to solids rather than dissolved in ground water, P&T and
continued monitoring may not be necessary.
Recommendation
Recommendation
Reason
2.3 Potentially Consider Additional Monitoring Points
Protectiveness
Implementation
Status
Delayed
Comments: The implementation of this recommendation is contingent on the results of the sampling and site
conceptual model development discussed in the follow-up of Recommendation 2.1. At least two rounds of
sampling will be conducted with the revised sampling technique before making any decisions regarding a
modification to the remedy. If the monitoring results (using a revised sampling technique) indicate that the plume
is immobile due to contamination being absorbed to solids rather than dissolved in ground water, P&T and
continued monitoring may not be necessary.
Recommendation
Recommendation
Reason
3.1 Reduce Monitoring Well Sampling Frequency
Cost Reduction
Implementation
Status
Delayed
Comments: The implementation of this recommendation is contingent on the results of the sampling and site
conceptual model development discussed in the follow-up of Recommendation 2.1. At least two rounds of
sampling will be conducted with the revised sampling technique before making any decisions regarding a
modification to the remedy. If the monitoring results (using a revised sampling technique) indicate that the plume
is immobile due to contamination being absorbed to solids rather than dissolved in ground water, P&T and
continued monitoring may not be necessary.
-------
Recommendation
Recommendation
Reason
4.1 Improve Annual O&M and
Technical Improvement
Monitoring Reports
Implementation
Status
Delayed
Comments: The implementation of this recommendation is contingent on the results of the sampling and site
conceptual model development discussed in the follow-up of Recommendation 2.1. At least two rounds of
sampling will be conducted with the revised sampling technique before making any decisions regarding a
modification to the remedy. If the monitoring results (using a revised sampling technique) indicate that the plume
is immobile due to contamination being absorbed to solids rather than dissolved in ground water, P&T and
continued monitoring may not be necessary.
Recommendation
Recommendation
Reason
5.1 Base Remedy Path Forward on Findings from Implementing the Above
Recommendations
Cost Reduction
Implementation
Status
Comments: The site team is moving forward with the sampling described in the
2.1.
In Progress
follow-up to Recommendation
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
The site team has been meeting with the ERT to discuss the potential use of in-situ
chemical oxidation at MW-21D. Further discussions will be tabled until the site team
conducts at least two rounds of monitoring with a revised sampling technique (as
described in the followup to Recommendation 2.1 above).
The first round of monitoring with the revised sampling technique should occur by the
end of August 2005.
NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP
1. It is recommended that the Region proceed with the revised sampling procedure as
described in the follow-up to Recommendation 2.1 above. Other activities such as
capture zone analyses, installation of additional monitoring wells, chemical oxidation,
etc. should be postponed until the results of the new sampling have been interpreted and a
revised site conceptual model developed. Conducting this sampling should not result in
substantial additional cost given that the sampling would replace a regularly scheduled
sampling round. Minor costs, perhaps $2,000, might be required for additional equipment
that might be needed.
-------
UPDATED COST SUMMARY TABLE
Recommendation
Reason
Implementation
Status
Estimated
Capital Costs
($)
Actual Capital
Costs
($)
Estimated Change
in Annual Costs
($/yr)
Actual Change in
Annual Costs
(S/yr)
Original Optimization Evaluation Recommendations
2 . 1 Prepare a Document that
Clearly States and Illustrates the
Conceptual Model
2.2 Conduct a Preliminary
Capture Zone Analysis
2.3 Potentially Consider
Additional Monitoring Points
(based on results from 2. 1 and
2.2)
3 . 1 Reduce Reduce Monitoring
Well Sampling Frequency
4. 1 Improve Annual O&M and
Monitoring Reports
5.1 Base Remedy Path
Forward on Findings from
Implementing the Above
Recommendations
Protectiveness
Protectiveness
Protectiveness
Cost Reduction
Technical
Improvement
Site Closeout
Planned
In progress
Will not be
implemented
In progress
In progress
In progress
$15,000
$25,000
$60,000
$0
$0
Not quantified
$0
$0
$2,000
($12,000)
$0
Not quantified
New or Updated Recommendations from Follow-up #1, July 13, 2005
1. Conduct monitoring with
revised sampling technique
Site Closeout
Implemented
$2,000
Not yet quantified
Not quantified
$0
New or Updated Recommendations from Follow-up #2, November 7, 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 has not been provided by the ROET to date.
-------
APPENDIX: B
BASELINE SITE INFORMATION SHEET AND
OPTIMIZATION EVALUATION REPORT
-------
Streamlined
Optimization Evaluation Report
Saunders Supply Company Superfund Site
Chuckatuck, Virginia
EPA Region III
July 29, 2005
-------
SECTION 1:
BASELINE SITE INFORMATION FORM
-------
Date: 2/7/05
Filled Out By: Andy Palestini
A. Site Location, Contact Information, and Site Status
1. Site name 2. Site Location (city and State) 3. EPA Region
Saunders Supply Company Chuckatuck, VA 3
4a. EPA RPM 5a. State Contact
Andy Palestini Thomas Modena
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-3233 804-698-4183
4c. EPA RPM Email Address 5c. State Contact Email Address
palestini.andy@epa.gov tmodena@deq.state.va.us
5. Is the ground water remedy an interim remedy or a final remedy? Interim | | Final IXI
6. Is the site EPA lead or State-lead with Fund money? EPA IXI State I I
B. General Site Information
1 a. Date of Original ROD for Ground Water Remedy
09/30/1991
2a. DateofO&F
06/01/1999
3. What is the primary goal of the P&T system
(select one)?
1 1 Contaminant plume containment
1 1 Aquifer restoration
IXI Containment and restoration
1 I Well-head treatment
lb. Dates of Other Ground Water Decision Documents (e.g., ESD, ROD Amendment)
ROD Amendment - 09/27/1996
2b. Date for transfer to State
06/01/2009
4. Check those classes of contaminants that are
contaminants of concern at the site.
CD VOCs (e.g., TCE, benzene, etc.)
Kl SVOCs (e.g., PAHs, PCP, etc.)
IXI metals (e.g., arsenic, chromium, etc.)
1 I other
5. Has NAPL or evidence of NAPL been observed at the site? Yes IXI No I I
6. What is the approximate total pumping rate? 10 gpm
7. How many active extraction wells .
(or trenches) are there?
9. How many samples are collected
from monitoring wells or piezometers . .
each year? (e.g., 40 if 10 wells are
sampled quarterly)
11. What above-ground treatment processes are usec
1 I Air stripping
IXI Carbon adsorption (liquid phase only)
IXI Filtration
I | Off-gas treatment
1 I Ion exchange
8. How many monitoring wells are . 1
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)?
IXI 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% IXI 10-20%| | >20% | |
-------
C. Site Costs
1. Annual O&M costs
O&M Category
Actual Annual Costs
for FY03
Actual Annual Costs
forFY04
Projected Annual
Costs for FY05
Labor: project management, reporting,
technical support
$37,600
$22,900
$22,000
Labor: system operation
$49,200
$30,900
$30,000
Labor: ground water sampling
$35,600
$34,200
$34,000
Utilities: electricity
$2,000
$2,000
$2,000
Utilities: other
$500
$500
$500
Consumables (GAC, chemicals, etc.)
$600
$600
$600
Discharge or disposal costs
$0
$0
$0
Analytical costs
$0
$0
$0
Other (parts, routine maintenance, etc.)
$200
$200
$200
O&M Total
$125,700
$91,300
$89,300
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
$1,200
$3,800
$3,500
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:
-------
D. Five-Year Review
1. Date of the Most Recent Five-Year Review 12/29/2004
2. Protectiveness Statement from the Most Recent Five-Year Review
I | Protective I I Not Protective
M Protective in the short-term Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
1. Determine the extent of contamination east of MW-20S/21D well nest. Results will be
analyzed to determine if additional ground water recovery wells are needed to capture a larger
plume and whether additional monitoring wells are needed east of the MW-20S/21D well nest.
2. Determine whether contaminants in the Yorktown aquifer are being controlled by the
existing extraction system. Results will be analyzed to determine if additional ground water
recovery wells are needed to remediate the Yorktown aquifer plume.
3. Institutional controls restricting using the Columbia and Yorktown aquifers as a source of
ground water must be implemented for the Kelly property.
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.
Saunders Supply Company is approximately 400 feet from Godwins Millpond, which is used
by the city of Suffolk as one of their sources of drinking water. The city, on their own
initiative, sample several of the EPA monitoring wells monthly because of their obvious
concern that their drinking water source does not become contaminated.
-------
SECTION 2:
STREAMLINED OPTIMIZATION EVALUATION
FINDINGS AND RECOMMENDATION
-------
Date of Evaluation Meeting:
Saunders Supply Company Superfund Site
February 10, 2005 Date of Final Report:
July 29, 2005
ROET MEMBERS CONDUCTING THE STREAMLINED OPTIMIZATION EVALUATION:
Name
Peter Ludzia
Norm Kulujian
Kathy Davies
Peter Schaul
Peter Rich
Doug Sutton
Chuck Sands
Jean Balent (by phone)
Affiliation
U.S. EPA Region 3 (Section
Chief)
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3 (Branch
Chief)
GeoTrans, Inc.
GeoTrans, Inc.
U.S. EPAOSRTI
U.S. EPAOSRTI
Phone
215-814-3190
215-814-3130
215-814-3315
215-814-3183
410-990-4607
732-409-0344
703-603-8857
202-564-1709
Email
liid/.ia.pcl.cr@epa.aov
Kuluiian.norm@^Qa.gov
Davics.kat.hY@cpa.gov
scliaul .pctcr@.cpa . go v
pjTcJi@gcoJransinc.coni
dsutton@Keotransinc.com
Sands.charles@epa. gov
Bajcntj_can@CEa._goy
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Andy Palestini
Bernice Pasquini
Tom Modena
Dan Gilroy
Affiliation
U.S. EPA Region 3 (RPM)
U.S. EPA Region 3 (Hydro)
Virginia Dept. of
Environmental Quality
COM
Phone
215-814-3199
215-814-3326
804-698-4183
703-968-0900
Email
Palestini.andv@epa. gov
pasauini.bcmicc@cpa.sov
tmodena@deq.state.va.us
GilroyD@cdm.com
1.0 SIGNIFICANT FINDINGS BEYOND THOSE REPORTED ON SITE INFORMATION FORM
The evaluation team observed an RPM who appears to be an effective site manager. 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.
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Findings beyond those reported on the site information form include the following:
The Saunders Supply facility began on-site chemical treatment of lumber in 1946
with pentachlorophenol (PCP) solution. Treatment with chromated copper arsenate
was introduced to the facility in 1974. By 1984, the PCP process was completely
converted to the CCA process. The site was proposed to the National Priorities List
in 1987, and a remedial investigation took place from September 1988 and May 1991.
The operation on lumber treatment stopped in 1991. The Record of Decision (ROD),
signed in 1991, included treatment of the soils in the source areas and monitoring of
ground water. A ROD Amendment in 1996 included P&T. The P&T system was
installed in early 1998 and started operation on April 20, 1998.
The primary ground water contaminants are PCP, arsenic, and chromium. The
following table summarizes cleanup levels, the highest 2004 average concentration of
each contaminant detected in a site monitoring well, and the monitoring well where
that highest average was detected.
Contaminant of Concern
PCP
Arsenic*
Chromium*
Cleanup Level
(ug/L)
1
10
100
Max. Dissolved
Concentration in 10/04
(ug/L)
280
1,810
200
Location of
Sample
MW-21D
MW-7S
MW-9S
* Reported concentrations are for dissolved metals
The upper water-bearing unit at the site is the Columbia Aquifer, which extends from
near the surface to approximately 20 feet below ground surface (bgs). Boring logs
from the Deep Groundwater Investigation Memorandum indicate a very tight
formation that yields very little or no water in some intervals.
Prior to this investigation, the Columbia Aquifer was thought to be underlain by a
semi-confining layer of 2 to 7 feet of clay above the 100-foot thick sands of the
Yorktown aquifer. The Deep Groundwater Investigation Memorandum, which
summarizes data collected at the end of 2004, indicates that below the semi-confining
layer the Yorktown aquifer consisted of silt/clay mixtures to a depth of 76 feet bgs.
This material was tightly compacted and typically dry. Ground water could be
recovered only in select locations at depths below 30 feet bgs.
Site wells are identified as shallow and deep. Shallow wells are screened in the upper
2 to 20 feet of the subsurface and "deep" wells are screened at an interval about 2 feet
below the bottom of the nearby shallow well for 10 feet. No site wells are screened
below 30 feet bgs. The recovery wells are screened 13 to 21 feet deep.
Ground water sampling results indicate that the most elevated PCP contamination is
in MW-21D and MW-8D. MW-21D is located approximately 200 feet downgradient
of the Saunders property and is screened from approximately 20 to 30 feet bgs. MW-
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8D is located immediately downgradient of the Saunders property and is screened
from approximately 14 feet to 24 feet bgs. Therefore, the highest PCP concentrations
have been detected deeper than any of the site recovery wells. In comparison, the
shallow monitoring wells and the extraction wells typically have PCP concentrations
less than 10 ug/L.
The recent Deep Groundwater Investigation Memorandum summarizes a direct-push
investigation, in which site lithology was logged and four ground water samples were
collected. One of the samples (DPT5-42) was collected near MW-21D at a depth of
42 feet (approximately 12 feet deeper than MW-21D), and PCP was not detected.
Two samples (DPT2-42 and DPT2-42P) were collected at upgradient of MW-21D
approximately 50 feet downgradient of MW-8D, both at a depth of 42 feet bgs. PCP
was detected at 2.3 and 3.7 ug/L, respectively, which is at least an order of magnitude
lower than the concentrations in MW-8D and MW-21D.
The highest arsenic and chromium concentrations are located in shallow wells MW-
7S and MW-9S, respectively, which are both shallow wells located immediately
downgradient of the Saunders property. Deep wells in these locations have
substantially lower concentrations, indicating that arsenic and chromium
contamination decreases with depth. Wells MW-7S and MW-9S are screened from 2
feet to 12 feet bgs and 1 foot to 11 feet bgs, respectively.
Godwin's Millpond, located approximately 500 feet north of the site, is a municipal
water supply source for the city of Suffolk.
The P&T system consists of following components:
o 4 extraction wells oriented parallel to the primary direction of ground water
flow (which is to northwest)
o A reaction tank with chemical feed
o The chemical precipitation step used to minimize iron fouling of the
remaining treatment train components
o A settling tank
o A sand filter
o Granular activated carbon (GAC) vessels contained in 55-gallon drums
o An effluent tank
o The treated water is discharged to a surface water body that is not connected
to Godwin's Millpond
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The design extraction rate for the system is 10 gpm, but the actual extraction rate over
the life of the system is relatively consistent at approximately 1 gpm.
The average flow per month reported in these Table 4-2 of the Annual Operation and
Maintenance (O&M) and Monitoring Report 2004 appears to be incorrect for RW-2,
RW-3 and RW-4 since October 2003. The total flow measurements appear to be
accurate, but the calculated average flow does not correspond with the total flow
measurements. The calculated average flow appears to overestimate the actual
average flow rate by a factor of 5 to 7.
The system is checked weekly. The treatment system operates effectively and
consistently meets discharge limits.
The P&T objective is containment of the plume (primarily to protect Godwin's
Millpond) and cleanup of ground water to the above-mentioned standards. Initially,
the site team targeted a 5-foot drawdown as an indication of hydraulic containment.
Currently, capture is determined based on concentration trends and inward flow based
on potentiometric maps. However, water level measurements from operating
extraction wells are being used in the development of the potentiometric maps, which
generally results in overestimates of the degree of capture. In addition, there does not
appear to be enough monitoring wells to be conclusive about the interpreted ground
water flow indicated in the potentiometric surface maps. Therefore, the evaluation of
capture is likely not reliable.
Insufficient information is also available to conduct an analytical ground water flow
analysis that compares the amount of contaminated water flowing through the site
with the amount of water extracted by the extraction network. The following
parameters are typically needed for this preliminary analysis, and as is indicated in
the list below, some of this information is not available.
o Background hydraulic gradient (not available)
o Hydraulic conductivity estimate (not available)
o Aquifer thickness (likely between 5 and 10 feet for the Columbia Aquifer)
o Plume width (the plume is not fully delineated)
o Pumping rate (approximately 1 gpm)
Analyzing concentration trends in downgradient performance monitoring wells and
sentinel wells can generally be used to evaluate capture. However, downgradient
monitoring points are fairly limited. MW-19D is relatively far downgradient and may
not yet be influenced, and it adjacent to Godwin's Millpond, which means that if
MW-19D becomes impacted then the remedy has likely already failed in meeting its
objective. Furthermore, it is unclear if MW-19D is installed at the appropriate depth
to monitor the performance of the extraction network.
The P&T system has removed about 0.1 pounds of PCP per year. The recent
apparent error in the average flow calculation has also led to errors regarding PCP
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removal in Table 4-2, especially with RW-2. Concentrations at the extraction wells
fluctuate over time but actual mass removal remains very low.
2.0 RECOMMENDATIONS TO IMPROVE SYSTEM PROTECTIVENESS
2.1 PREPARE A DOCUMENT THAT CLEARLY STATES AND ILLUSTRATES THE
CONCEPTUAL MODEL
Although the recent Deep Groundwater Investigation Memorandum and the Annual
O&M and Monitoring Report 2004 present important site data, a site conceptual
model is not clearly laid out. An effort should be made to update the conceptual
model. Geologic cross-sections should be prepared to clearly portray well
construction information and litho logy encountered during soil borings.
Furthermore, horizontal and vertical ground water flow patterns should be interpreted
and ground water flow velocities estimated. Finally, the fate and transport of the site-
related contamination (PCP, arsenic, and chromium) should also be interpreted,
particularly with respect to migration toward Godwin's Millpond.
This conceptual model should also attempt to explain the observation of apparently
isolated high PCP concentrations at MW-21D and the fluctuating concentrations at
the recovery wells, MW-7S, MW-1 IS, and other monitoring wells. The influence of
precipitation variation over time on concentrations should be considered as should the
influence of turbidity in the PCP results. The PCP contamination may be present in a
dissolved contaminant plume, but it may also be primarily absorbed to solids,
relatively immobile, and only apparent at elevated concentrations in turbid samples.
This effort of developing a site conceptual model will help provide evidence as to
whether the P&T system provides any significant benefit or alternative (more
targeted) approaches should be considered. It is estimated that this effort, which
does not involve any field-work or data collection, might cost $15,000.
In addition to routine ground water sampling for PCP, the site team may consider
taking filtered samples for PCP. Dissolved PCP would be present in the filtered
samples, and absorbed PCP associated with high turbidity would likely be removed
through filtration. This should add very little cost to the next routine sampling event
given that the laboratory analysis is not charged to the site.
2.2 CONDUCT A PRELIMINARY CAPTURE ZONE ANALYSIS
The site team should evaluate the plume capture offered by the P&T system by
conducting an analytical ground water flow analysis. To do this, the site team first
needs a background hydraulic gradient and an estimated hydraulic conductivity for
the Columbia Aquifer. The site team should install three or four piezometers near
(e.g., within 10 feet of) RW-2 and/or RW-4 that can be used during a pump test. The
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site team should then shut down the P&T system and measure the water levels in the
newly installed piezometers as the aquifer recovers. This recovery test should allow
the site team to estimate the hydraulic conductivity, and, after the aquifer recovers,
the site team can determine the background hydraulic gradient. When the site team
restarts the P&T system, the water levels in the piezometers can again be monitored.
This pump test would provide additional data for estimating the hydraulic
conductivity.
The background hydraulic gradient and the hydraulic conductivity estimate should
allow the site team to conduct a ground water flow analysis to preliminarily
determine the areal extent of the capture offered by the extraction system. This effort,
including a work plan and analysis of the data could likely be accomplished for under
$25,000.
2.3 POTENTIALLY CONSIDER ADDITIONAL MONITORING POINTS
The above preliminary capture zone analysis provides one line of evidence to
evaluate capture. An additional line of evidence for evaluating capture would be
likely appropriate, especially if the above-mentioned capture preliminary zone
analysis is inconclusive and the site conceptual model suggests continued
contaminant migration toward surface water.
Ground water flows toward the creek located to west of the extraction net work, and
there are no monitoring wells between the extraction network and the creek.
Installing monitoring wells in this area and monitoring concentration trends would
provide additional information for evaluating capture. A potential scope of work
would be to install monitoring well clusters in the following locations:
100 feet to the west of RW-3
50 feet northwest of RW-4 (perhaps 20 feet west of DPT-7)
150 to 200 feet north of RW-4
The well clusters might include a shallow well screened in a similar zone to that
influenced by the extraction network, and a deeper well that is screened in a similar
zone to that of MW-21D.
It is recognized that the access may be difficult or impracticable. It is also recognized
that a number of borings have recently been installed without intercepting ground
water. As a result, this recommendation to install additional monitoring wells is
intended to be contingent on results (or lack of results) from the recommendations in
Sections 2.1 and 2.2, and it is understood that a subset of the proposed wells may be
more appropriate. It is unlikely that more than the proposed six wells would be
necessary.
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These wells, if installed, could be used as downgradient performance wells to help
evaluate plume capture, or, in the absence of pumping, the degree of contaminant
migration. The cost for this effort (if conducted) might be $60,000, including a work
plan, oversight, and reporting. Adding these wells to the monitoring program
(assuming annual monitoring as discussed in Section 3.0) would cost an additional
$2,000 per year.
3.0 RECOMMENDATIONS TO REDUCE SYSTEM COST
3.1 REDUCE MONITORING WELL SAMPLING FREQUENCY
Ground water sampling is the highest cost O&M item at the site. Eleven monitoring
wells (6 deep and 5 shallow) and four recovery wells are sampled and analyzed
quarterly for semi-volatile organics and 17 dissolved metals. It was reported that
three additional monitoring wells will be added to the monitoring network. Based on
the lack of trends apparent in quarterly data, the slow ground water flow velocity at
the site and the extended time to be required to meet remedial goals, the optimization
team recommends a reduction in the sampling frequency of monitoring wells. The
site team could reduce sampling of some monitoring wells (MW-9S, MW-10D, MW-
1 IS, MW-12D, MW-22S, MW-23D, MW-19D) to semi-annual and the remaining
monitoring wells (MW-7S, MW-8D, MW-20S, MW-21D) to annual. After a few
years of monitoring with this schedule, the monitoring frequency might be reduced to
annual for all site monitoring wells. The reduction in sampling frequency to a
combination semi-annual and annual sampling should save about $12,000 in
sampling labor and equipment per year. Recovery well sampling could be maintained
at a quarterly frequency.
Additional savings in analytical costs cannot be quantified since the site does not pay
for these directly under the EPA lab program. Most of the metals could be removed
from the analyte list for further laboratory savings since only arsenic and chromium
are considered in site reports.
4.0 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT
4.1 IMPROVE ANNUAL O&M AND MONITORING REPORTS
These reports should include a more clear statement of the site conceptual model
(developed as part of Recommendation 2.1), and should correct the calculations made
in Table 4.2. This effort should not require additional funds.
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5.0 RECOMMENDATIONS To SPEED SITE CLOSEOUT
5.1 BASE REMEDY PATH FORWARD ON FINDINGS FROM IMPLEMENTING THE ABOVE
RECOMMENDATIONS
The existing P&T system may be providing some benefit with hydraulic containment
but it is removing minimal contaminant mass. Based on PCP concentration trends,
the system operation will likely have to continue for decades (if it is technically
practicable in any time frame) to reach the PCP cleanup goal, particularly since the
current extraction areas do not directly address the areas with the highest ground
water contamination.
The site team and Region will need to consider the developed conceptual model and
the capture zone evaluation to determine next steps for the remedy. Based on the
suggested recommendations, the Region may find that the remedy provides adequate
and necessary capture in a cost-effective manner. On the other hand, the Region may
find that the contaminant mobility is very limited, that the P&T system is unnecessary
for capture, and that the P&T system is not a cost-effective means for removing
contaminant mass. These two different findings might result in two different paths
forward. Under one scenario, the Region would continue operation of the P&T
system (perhaps with enhanced extraction) and focus on reducing annual costs.
Under another scenario, the Region might discontinue P&T operation and focus on
targeted remediation.
If targeted remediation is considered in the absence of an operating P&T system, the
Region might consider focused excavation (e.g., shallow PCP and arsenic
contamination at MW-7S), in-situ chemical oxidation (Fenton's reagent), or zero-
valent iron injection. If the P&T system will continue to operate, the site team could
consider adding extraction points near MW-21D and MW-8D. Areas to be targeted
might include MW-7S, MW-8D, MW-21D, RW-1, RW-2, and RW-3. Further
evaluation of these technologies/options is not likely necessary until the conceptual
model has been developed and the Region is seriously considering piloting targeted
remediation.
PRIORITIZATION AND SEQUENCING OF RECOMMENDATIONS
Recommendations 2.1 and 2.2 should be implemented first, followed by Recommendation 3.1.
Recommendation 2.3 can be implemented if the site team sees a clear benefit to the additional
data based on their understanding of the site conceptual model and plume capture.
Recommendation 4.1 should be implemented with the next annual report. Recommendation 5.1
is simply a recommendation to reconsider the path forward at the site after implementing the
other recommendations and conducting the suggested evaluations.
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Cost Summary Table
Recommendation
2. 1 Prepare A Document That
Clearly States And Illustrates The
Conceptual Model
2.2 Conduct a Preliminary
Capture Zone Analysis
2.3 Potentially Consider
Additional Monitoring Points
(based on results from 2. 1 and 2.2)
3 . 1 Reduce Monitoring Well
Sampling Frequency
4. 1 Improve Annual Reports
5.1 Base Remedy Path Forward
on Findings from Implementing
the above Recommendations
Reason
Effectiveness
Effectiveness
Effectiveness
Cost
Technical
Improvement
Site Closeout
Estimated Additional
Capital Costs
($)
$15,000
$25,000
$60,000
$0
$0
Not Quantified
Estimated Change in
Annual Costs
($/yr)
$0
$0
$2,000
($12,000)
$0
Not quantified
Costs in parentheses imply cost reductions.
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