REMEDIATION SYSTEM EVALUATION


      OTT/STORY/CORDOVA SUPERFUND SITE

DALTON TOWNSHIP, MUSKEGON COUNTY, MICHIGAN
       Report of the Remediation System Evaluation,

 Site Visit Conducted at the Ott/Story/Cordova Superfund Site

               September 27-28, 2001
        Final Report Submitted to Region 5

                 March 12, 2002
                            \
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                                        NOTICE
Work described herein was performed by GeoTrans, Inc. (GeoTrans) and the United States Army Corps
of Engineers (USAGE) for the U.S. Environmental Protection Agency (U.S. EPA). Work conducted by
GeoTrans, including preparation of this report, was performed under Dynamac Contract No. 68-C-99-
256, Subcontract No. 91517.  Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.

This document (EPA 542-R-02-008s) may be downloaded from EPA's Technology Innovation Office
website at www.epa.gov/tio or www.cluin.org/rse.

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                               EXECUTIVE SUMMARY
The Ott/Story/Cordova Superfund Site occupies approximately 20 acres in Dalton Township, Muskegon
County, Michigan. The remedies at the site address contamination stemming from a specialty organic
chemical production facility operated under a series of owners from  1957 until 1985. The area
surrounding the site is predominantly rural with a residential area downgradient to the southeast of the
site along River Road. Little Bear Creek is also located downgradient of the site and has been impacted
by site-related contamination.  The site has been divided into three  operable units:

       OU1 requires containment of site groundwater with extraction wells and prevention of further
       contamination of Little Bear Creek.

       OU2 requires restoration of the aquifer through treating extracted groundwater.

       OU3 requires excavation and disposal of plant area soils (originally, OU3 required low
       temperature thermal desorption of excavated soils, but this aspect of the remedy was changed to
       disposal in a 1998 ROD  Amendment).

A single pump and treat system,  with two extraction well networks, serves as the remedy for both OU1
and OU2. The OU1 extraction well network of 7 wells is located upgradient of Little Bear Creek and its
unnamed tributary and captures site contaminants preventing them from discharging to these surface
water bodies. The OU2 extraction well network consists of 3 wells (a fourth well is being installed) and
extracts contaminated groundwater from the source area in an attempt to restore the aquifer.

The treatment plant regularly meets the discharge criteria and the pump and treat system has successfully
reduced discharge of contaminated groundwater to nearby surface water.  As a result, the RSE team does
not provide specific recommendations with regard to effectiveness.

Recommendations to reduce life-cycle costs include the following:

       The current diffused air  stripper (DAS) units could be replaced with more efficient units such as
       tray aerators or packed towers.  Implementing this recommendation may cost $750,000; however,
       annual cost savings of approximately $192,000 would result from a reduction in utilities,
       chemical additions, and potentially powdered activated carbon.

       The site managers should compare the concentrations of ammonia, acetone, and other influent
       contaminants that require biological treatment against NPDES permit discharge limits. If the
       influent concentrations of these parameters meet the discharge requirements, then the PACT
       systems can be bypassed. The remaining contaminants would be removed by the  more efficient
       air stripping units as well as the GAC units that are currently used as  a polishing step.
       Implementing this recommendation would likely cost $400,000 for bypass piping, valving,
       associated controls, and  additional GAC usage; however, annual cost savings of approximately
       $696,000 would result from a reduction in utilities, labor, and materials.

       The treatment plant could likely be operated effectively with a significant reduction in process
       monitoring. The associated reduction in onsite analyses would likely allow the laboratory staff
       to be reduced by one or two technicians. Reducing the laboratory staff could result in savings of

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       approximately $50,000 per year if two people are required to operate the lab or $100,000 per
       year if only one person is required to operate the lab.

•      The current groundwater monitoring program consists of more than 250 samples collected each
       year and analyzed for both VOCs and SVOCs. The groundwater monitoring program could be
       reduced in scale without sacrificing effectiveness. A savings of approximately $55,000 per year
       may potentially be realized due to a decrease in the analysis costs alone.

•      Current site plans include construction of an additional building for storage. Another storage
       alternative may exist. A large amount of onsite equipment, including two large filter presses and
       four 400 horsepower blowers, may be transported offsite making space for any storage
       requirements.

•      Although providing an "inherently governmental" presence, oversight provided by USAGE could
       likely be reduced now that the system is operating as expected.  The RSE team recommends
       evaluating the potential to reduce USAGE oversight and onsite presence to determine if the cost
       of $24,500 per month can be reduced.

•      At the time of the RSE visit two trailers were onsite to provide office space to USAGE and other
       contractors. Sufficient space should be available in other onsite buildings. As of the fmalization
       of this report, one of the trailers was removed to avoid rental charges.

•      Offsite staff from the primary contractor in Kansas  City conduct the quarterly sampling for OU3.
       The onsite staff should conduct sampling to eliminate the costs  (approximately $15,000)
       associated with offsite staff traveling from Kansas City to the site four times a year.

Implementing the recommendations to reduce costs would require initial investments,  but savings from
operations and maintenance could offset these initial investments.

A summary of recommendations, including estimated costs and/or savings associated with those
recommendations is presented in Section 7.0 of the report.
                                               11

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                                      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 (phone)
617-918-8427 (fax)
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)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
(732) 409-0344
Fax: (732) 409-3020
dsutton@geotransinc.com
 Army Corp of Engineers:
 Hazardous, Toxic, and Radioactive
 Waste Center of Expertise
 (USAGE HTRW CX)
Dave Becker
12565 W. Center Road
Omaha, NE 68144-3869
(402) 697-2655
Fax:(402) 691-2673
dave.i.becker(S>nwd02.usace. army.mil
                                            in

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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 (RPMs).
                                             IV

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                              TABLE OF CONTENTS
EXECUTIVE SUMMARY	i

PREFACE  	iii

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 AND HISTORY	 3
             1.5.2   POTENTIAL SOURCES	 3
             1.5.3   HYDROGEOLOGIC SETTING	 4
             1.5.4   DESCRIPTION OF GROUND WATER PLUME	 4

2.0  SYSTEM DESCRIPTION	 5
       2.1    SYSTEM OVERVIEW	 5
       2.2    EXTRACTION SYSTEMS	 5
       2.3    TREATMENT SYSTEM	 5
       2.4    MONITORING SYSTEM	 6

3.0  SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE CRITERIA 	 8
       3.1    CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA	 8
       3.2    TREATMENT PLANT OPERATION GOALS	 8
       3.3    ACTION LEVELS	 9

4.0  FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT	  11
       4.1    FINDINGS  	  11
       4.2    SUBSURFACE PERFORMANCE AND RESPONSE  	  11
             4.2.1   WATERLEVELS 	  11
             4.2.2   CAPTURE ZONE 	  12
             4.2.3   CONTAMINANT LEVELS 	  13
       4.3    COMPONENT PERFORMANCE 	  14
             4.3.1   DIFFUSED AIR STRIPPER BASINS (DAS)	  14
             4.3.2   THERMAL OXIDATION UNIT (TOU)	  14
             4.3.3   POWDERED ACTIVATED CARBON TREATMENT SYSTEM (PACT)	  14
             4.3.4   POWDERED ACTIVATED CARBON FEED SYSTEM	  15
             4.3.5   TERTIARY FILTER SYSTEM	  15
             4.3.6   GRANULAR ACTIVATED CARBON (GAC) TREATMENT 	  16
             4.3.7   SOLIDS HANDLING SYSTEM	  16
             4.3.8   ONSITELABORATORY  	  16
       4.4    COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF MONTHLY COSTS	  16
             4.4.1   PROJECT MANAGEMENT  	  17
             4.4.2   LABOR	  17
             4.4.3   UTILITIES	  18

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               4.4.4   NON-UTILITY CONSUMABLES AND DISPOSAL COSTS 	  18
               4.4.5   CHEMICAL ANALYSIS	  19
       4.5     RECURRING PROBLEMS ORISSUES	  19
       4.6     REGULATORY COMPLIANCE	  19
       4.7     TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL CONTAMINANT/REAGENT RELEASES
               	  19
       4.8     SAFETYRECORD  	  20

5.0  EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT  21
       5.1     GROUND WATER  	  21
       5.2     SURFACE WATER	  21
       5.3     AIR	  22
       5.4     SOILS 	  22
       5.5     WETLANDS AND SEDIMENTS  	  22

6.0  RECOMMENDATIONS	  23
       6.1     RECOMMENDED STUDIES TO ENSURE EFFECTIVENESS	  23
       6.2     RECOMMENDED CHANGES TO REDUCE COSTS	  24
               6.2.1   REPLACE DAS UNITS WITH TRAY AERATORS OR PACKED TOWERS	  24
               6.2.2   REEXAMINE NPDES PERMIT AND POTENTIALLY BYPASS PACT SYSTEM	  25
               6.2.3   REDUCE PROCESS MONITORING AND ANALYSIS	  26
               6.2.4   REDUCE GROUNDWATER MONITORING AND ANALYSIS 	  26
               6.2.5   REMOVE EXCESS EQUIPMENT AND DO NOT CONSTRUCT THE PLANNED STORAGE BUILDING
                      	  27
               6.2.6   EVALUATE POTENTIAL REDUCTION IN ONSITE PRESENCE OF US ACE	  27
               6.2.7   REMOVE TRAILERS FROM THE SITE	  28
               6.2.8   HAVE ONSITE STAFF CONDUCT SAMPLING FOR OU3	  28
       6.3     MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT 	  28
               6.3.1   ESTABLISH CONSISTENT SAMPLING METHOD 	  28
               6.3.2   MODIFY PROGRAM FOR WATER-LEVEL MEASUREMENT	  29
       6.4     MODIFICATIONS INTENDED TO GAIN SITE CLOSE-OUT	  30
               6.4.1   ESTABLISH AGREEMENT BETWEEN THE OU2 REMEDY AND THE ROD 	  30
       6.5     SUGGESTED APPROACH TO IMPLEMENTATION OF RECOMMENDATIONS	  31

7.0  SUMMARY	  32
List of Tables

Table 2-1.       Laboratory analysis schedule, Ott/Story/Cordova GWTF, Revised 3/20/01
Table 7-1.       Cost summary table
List of Figures

Figure 1-1.       Site layout of the Ott/Story/Cordova Superfund Site indicating sampling and analysis results of the upper
               portion of the unconfined aquifer from the March 2001 sampling event.
Figure 1-2.       Site layout of the Ott/Story/Cordova Superfund Site indicating sampling and analysis results of the lower
               portion of the unconfined aquifer from the March 2001 sampling event.
Figure 1-3.       Site layout of the Ott/Story/Cordova Superfund Site indicating sampling and analysis results of the semi-
               confined aquifer from the March 2001 sampling event.
Figure 2-1.       Schematic of the Groundwater Treatment Facility
                                              VI

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                                 1.0 INTRODUCTION
1.1           PURPOSE

In the OSWER Directive No. 9200.0-33, Transmittal of Final FYOO - FY01 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 Ott/Story/Cordova Site was chosen based on initial screening of the pump-and-treat systems
managed by USEPA Region 5 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.

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1.2
TEAM COMPOSITION
The team conducting the RSE consisted of the following individuals:

      Frank Bales, Chemical Engineer, USAGE, Kansas City District
      Mike Grain, Hydrogeologist, USAGE HTRW CX
      Peter Rich, Civil and Environmental Engineer, GeoTrans, Inc.
      Doug Sutton, Water Resources Engineer, GeoTrans, Inc.
1.3
DOCUMENTS REVIEWED
Author
US EPA
US EPA
Black & Veatch
Black & Veatch
Black & Veatch
Black & Veatch
EPA
EPA
IT Corp.
FTC&H
Black & Veatch
Black & Veatch
FTC&H
FTC&H
FTC&H
Date
9/29/1989
9/29/1990
10/11/1991
7/23/1992
7/23/1992
4/1997
8/13/1997
2/25/1998
5/1999
5/2000
2/2001
6/2001
7/2001
8/2001
3/2001 - 12/2001
Title/Description
Record of Decision OU1
Record of Decision OU2
Concept Design Analysis, Volume 3
Final Design Analysis Volume One
Final Design Analysis Volume Two
Groundwater Modeling Report, Optimization of
Containment Well Extraction Rates, Ott/Story/Cordova
Site, Muskegon, Michigan
Five Year Review Report
Amendment to Record of Decision OU3
Operation & Maintenance Manual
Monthly Operating Report
Groundwater Summary Report Quarter 20 (December
2000)
Groundwater Summary Report Quarter 21 (March 2001)
Monthly Operating Report
Monthly Operating Report
Daily Logs

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1.4           PERSONS CONTACTED

The following individuals were present for the site visit:

John Fagiolo, EPA Region 5, Remedial Project Manager
Lisa Summerfield, Michigan Department of Environmental Quality, Project Manager
Thomas Berdinski, Michigan Department of Environmental Quality, Surface Water Quality Division
Karl Jaeger, Fishbeck, Thompson, Carr & Huber, Plant Superintendent
Cathy Jaeger, Fishbeck, Thompson, Carr & Huber, Laboratory Manager
Brian Bouwhuis, USAGE, Project Manager


1.5           SITE LOCATION, HISTORY, AND CHARACTERISTICS

1.5.1          LOCATION AND HISTORY

The Ott/Story/Cordova Superfund Site occupies approximately 20 acres in Dalton Township, Muskegon
County, Michigan. The remedies at the site address contamination stemming from a specialty organic
chemical production facility operated under a series of owners from 1957 until 1985.  The area
surrounding the site is predominantly rural with a residential area downgradient to the southeast of the
site along River Road.  Little Bear Creek is also located downgradient of the site and has been impacted
by site-related contamination.

The site has been divided into three operable  units:

•      OU1 requires containment of site groundwater with extraction wells and prevention of further
       contamination of Little Bear Creek.

•      OU2 requires restoration of the aquifer through treating extracted groundwater.

•      OU3 requires excavation and disposal of plant area soils (originally, OU3 required low
       temperature thermal desorption of excavated soils, but this aspect of the remedy was changed to
       disposal in a 1998 ROD Amendment).

It should be noted that during the RSE visit, the contractor was involved in the third phase of a Variable
Operations Plan (VOP) designed to determine the sensitivity of plant effectiveness under various
operational parameters. Although operational parameters were different than normal during this RSE
visit, this did not inhibit the RSE team in becoming familiar with system operation. This RSE report
focuses on pump-and-treat system under its typical operating conditions rather than those adjusted during
the VOP.

1.5.2          POTENTIAL SOURCES

The site served as an organic chemical production facility from 1957 through 1985 under various owners
including the Ott Chemical Company, the Story Chemical Company, and the Cordova Chemical
Company.  Various chemicals were used to manufacture pharmaceutical intermediates, veterinary
medicines, agricultural chemicals, herbicides, dyestuffs, and other products. Waste from the production

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facilities was discharged to unlined lagoons or stored in drums. Groundwater contamination was first
discovered in 1959. By the 1960s, process waters were discharged to Little Bear Creek, then later to the
Muskegon River, and finally by about 1974 to the local sanitary sewer (POTW). By the 1970s, the
lagoons were only used for cooling waters from the plant and concentrated waste was either incinerated
or stored in drums which may have been disposed of onsite.

The contaminants detected in the soil and groundwater include benzene, toluene, xylene, chlorinated
solvents (including tetrachloroethylene (PCE), trichloroethylene (TCE), dichloroethylene (DCE), vinyl
chloride, and carbon tetrachloride), aniline based compounds, DDT, Arochlor-1248, pesticides and
herbicides, arsenic, cyanide, ammonia, acetone, and others. Concentrations of many compounds above
10 ppm suggest the presence of pure product or non-aqueous phase liquid (NAPL).

1.5.3          HYDROGEOLOGIC SETTING

At the site, relatively permeable sand extends from the surface to a depth of approximately 65 feet below
ground surface (bgs).  Layers of silt and clay lay beneath this sand and provide a partial barrier between
the sand and the semi-confined aquifer that begins at approximately 85 feet bgs. This semi-confined
aquifer extends to approximately 120 feet bgs and is underlain by clay.

Groundwater is typically found approximately 5 feet below the surface, and groundwater in the  upper,
unconfined zone typically flows to the southeast and discharges to Little Bear Creek. Estimated recharge
to the unconfined aquifer of approximately 6 to 10 inches per year results from precipitation. Water from
the semi-confined aquifer has a higher hydraulic head than the water in the overlying unconfined sandy
zone and therefore water typically flows upward from this lower zone with more pronounced upward
flow near the creek. The hydraulic gradient in the shallow, unconfined zone is approximately 0.008
while that in the lower zone is approximately 0.003.

1.5.4          DESCRIPTION OF GROUND WATER PLUME

The monitoring events show that the most significant groundwater contamination exists both in the
former production area and near the OU1 extraction system over a half mile downgradient.
Contamination also may exist between these two locations, but this cannot be confirmed due to  the
relatively small number of monitoring wells in this intermediate area. Groundwater contamination
indicative of NAPL is evident in both the shallow and deeper portions of the unconfined aquifer as well
as the semi-confined zone.  Groundwater contamination exceeding the cleanup levels by two or more
orders of magnitude in the area near the OU1 extraction system is predominantly limited to the lower
portion of the unconfined aquifer. Figures 1-1 through 1-3 provide plume maps for total organic
compounds in the upper portion of the unconfined aquifer, lower portion of the unconfined aquifer, and
the semi-confined aquifer.

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                            2.0   SYSTEM DESCRIPTION
2.1           SYSTEM OVERVIEW

The OU1 ROD included 4 extraction wells proposed to prevent migration of contamination to Little Bear
Creek and treatment of extracted groundwater via UV-oxidation, granular activated carbon (GAC),
activated sludge, and filtration.  The OU2 ROD included additional extraction wells including some
closer to the source area.  The current system consists of 10 extraction wells, with an additional one
planned for operation in October 2001, treated through air stripping, biological treatment, powdered
activated carbon, filtration, and GAC.
2.2           EXTRACTION SYSTEMS

The extraction wells comprising the current extraction system are indicated in Figures 1-1 through 1-3.
All wells screen the majority of the unconfmed aquifer with the exception of EW-9, which screens the
semi-confined aquifer. The 10 installed wells have a total design extraction rate of 800 gpm, and EW-11
will have a design flow rate of 40 gpm (although preliminary pump tests suggest it may be capable of
extracting at a flow rate of 100 gpm).  The extraction system typically operates at or above 700 gpm. A
double-walled collection system with  a leak detection system transports the water from the extraction
wells to the treatment plant through four mains that combine into one prior to entering the plant.  The
extraction wells have rehabilitation wells installed adjacent to them, and a comprehensive well-
maintenance program for ensuring the integrity of the extraction wells.
2.3           TREATMENT SYSTEM

Water from the extraction system is split among two treatment trains that each consist of diffused air
stripping (DAS) tanks, addition of a nutrient (phosphoric acid), two stages of aeration and clarification
for biological treatment, addition of powdered activated carbon and ferric chloride, sand filtration, and
liquid phase GAC. Air from the DAS units and the aeration tanks is treated in a thermal oxidation unit
(TOU) before being discharged to the atmosphere.  Treated water is transported through piping to a
stationary aerator prior to discharge to the Muskegon River.  Sludge generated from the biological
systems is conditioned and then transported to filter presses before being disposed of as non-hazardous
waste.  As a whole, the treatment plant is designed for a flow rate of 900 gpm.  A diagram of the
treatment system provided by the plant operators is included as Figure 2-1.

The treatment system is provided with power by two sets of power lines from two power stations, which
decreases the likelihood of interruption in operations due to power failures. Two propane generators have
been installed to provide power to the extraction wells in the event of a power outage.

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2.4
MONITORING SYSTEM
The monitoring system consists of over 40 monitoring wells in the upper portion of the unconfmed
aquifer, 43 monitoring wells in the lower portion of the unconfmed aquifer, and 12 monitoring wells in
the semi-confined system. Water quality monitoring, including samples taken from the 10 extraction
wells, is conducted on a quarterly basis with the following schedule:
March
June
September
December
64 samples
73 samples
62 samples
62 samples
All samples are analyzed for volatile organic compounds using method 8260 and semi-volatile
compounds using method 8270b and plume maps are generated at three elevations for various
contaminants.  In addition, on a monthly basis, water levels are collected from 79 wells, including the 10
extraction wells, and potentiometric surface maps are generated at three elevations.  These potentiometric
surface maps are included in the quarterly groundwater reports.

Sediment and surface water sampling and analysis of Little Bear Creek is conducted on a quarterly basis
by the offsite staff of the primary contractor.

Process monitoring, with the exception of air monitoring, is conducted via an onsite laboratory staffed by
an onsite lab manager and two chemists. The process monitoring schedule during normal plant
operations is provided in Table 2-1. This schedule is not indicative of the sampling conducted during the
Variable Operation Plan. The  schedule indicates that process water samples are also sent offsite for
verification of onsite analysis because the onsite laboratory is not certified.

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                                              Table 2-1. Laboratory Analysis Schedule, Ott/Story/Cordova GWTF, Revised 3/20/01

DAS Influent
DAS Influent
PACTPCT-201
PACT PCT-202
1st. Stage aerat. PCT 201
1st Stage aerat. PCT 202
2nd Stage aerat. PCT 201
2nd Stage aerat. PCT 202
PCT 201 Istclanf. Ovflo
PCT 202 Istclanf. Ovflo
Clanfier eff. C-301
Clanfier eff. C-301
Filter influent
Filter effluent
Lead GAG CA 551
Lead GAG CA 552
NPDES Station
HPDES Station
DAS offgss
TOU exhaust
Site Boundary Air
PACT PCT 202 offgss
PACT PCT 201 offgss
DigestorPCT201 eff.
DigestorPCT202eff.
Filter press filtrate
Filter press cake
Stream discharge
RSP-221 discharge
RSP-222 discharge
RSP-321 discharge
RSP-322 discharge
63 Monitoring wells
63 Monitoring wells
p-
3
o'
1'
1
1
2
3
4
5
6
7
25
26
8
9
10
11
12
13
14
14
15
16
17
18
19
20
21
22
23
24
31
32
33
34


Alkalinity


W
W






W
W






















CBOD


W
W






W
W




W

















Carbon-Biomass




W
W




























O
O
d

5d
5d
5d




5d
5d
5d
5d




5d

















Hardness

M










M



M

















K
UJ

3d
5d
5d




5d
5d
5d
5d




5d

















H
2


BW
BW






BW
BW






















UJ


W
W






W
W






















0


W
W






W
W






















Dissolved O2

3d


5d
5d
2d
2d








5d










W




Q

K

3d
5d
5d
5d
5d
2d
2d
5d
5d
5d
5d




C










W




Q

H
0
3-
0
3-
0
0


5d
5d




5d
5d
5d
5d




4d

















Total Solids























R
R
R
R







Suspended Solids

W
W
W
5d
5d
5d
5d
5d
5d
5d
5d
2d
2d


4d











5d
5d
5d
5d


Suspended Ash




W
W




























1

3d


5d
5d
2d
2d








C















Q

Specific Conductance
















C















Q

H
O

















W
















Volatiles
W
W
W
W




W
W
W
W

W
W
W
W
W
M
M
SA
SA
SA










Q
a
W
W
W
W




W
W
W
W

W
W
W
W
W















Q
1

















W
















1

















SM
















AmenCN

















W
















Metals (Cu, Zn, V)

















W
















Oxygen Uptake Rate




5d
5d




























Dissolved O2 Profile




W
W




























H
O



























R






Settleability




5d
5d




























Microscope Exam




5d
5d




























                                                                                                                                                                  R= as requested





                                                                                                                                                                  SA = semi-annually





                                                                                                                                                                  Q = quarterly





                                                                                                                                                                  M = m onthly





                                                                                                                                                                  SM = semi-monthly





                                                                                                                                                                  BW = biweekly





                                                                                                                                                                  W = weekly





                                                                                                                                                                  5d = 5 days/week





                                                                                                                                                                  4d = 4 days/week





                                                                                                                                                                  2d = 2 days/week





                                                                                                                                                                  C = continuous
Shaded indicates offsite test for contractor
(Note: This table is adapted from Table 6.1 from the July 2001 Monthly Operating Report, FTC&H.)

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      3.0  SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE
                                       CRITERIA
3.1           CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA

Because the pump-and-treat system operates on behalf of both OU1 and OU2, the system must meet the
objectives of both operable units.

The objective for OU1 as documented in the 1989 ROD is as follows:

       The response objectives for this operable unit are to intercept and contain contaminated groundwater
       within the unconfined groundwater system, eliminate potential surface water and air exposure routes
       by preventing contaminated groundwater discharge into Little Bear Creek and its unnamed tributary,
       and to ensure that this operable unit [OU1] is fundamentally compatible with future remedial actions
       at the Ott/Story/Cordova site.

The objective for OU2 as documented in the 1990 ROD is as follows:

       OU2...has as its primary goal the restoration of the aquifer system below and downgradient of the
       Ott/Story/Cordova Site...The goal of this remedial action [OU2] is to restore all portions of the
       aquifer so that it may serve as a drinking water resource.


3.2           TREATMENT PLANT OPERATION  GOALS

The treatment plant discharges to the Muskegon River; therefore, it must meet the requirements of a
NPDES permit.  The RSE team did not have a copy of the NPDES permit, but some of the permit
requirements can be found in the monthly Discharge Monitoring Reports (DMRs).  The following table
provides the discharge criteria, as listed in the October 1997 DMR, for various constituents of the
extracted water.  The October 1997 DMR was chosen as it was one of the earliest monthly reports to
provide the discharge criteria and many of the parameters have since been determined as posing a lesser
problem and have been switched to "report" status.

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NPDES Requirements from October 1997 DMR
Parameter
dissolved oxygen
pH
nitrogen, ammonia
phosphorus, total
cyanide (amenable)
copper
vanadium
zinc
1,2-dichloroethane
Limit
4.0 mg/L
6.0-9.0
20 mg/L
0.5 mg/L or 5 Ibs/day
47ug/L
lOOug/L
30ug/L
870 ug/L
report
daily minimum
daily min. and max.
daily maximum
monthly average
daily maximum
daily maximum
daily maximum
daily maximum
monthly average and
daily maximum
3.3
ACTION LEVELS
For cleanup levels, the 1990 ROD states that the concentration for any carcinogenic contaminant that
yields no more than a 1 x 10"6 cancer risk for that contaminant is a desirable cleanup level.  Given the
presence of multiple carcinogenic substances, the total cumulative risk for all contaminants should be
approximately 2x 10"5.  The ROD also states that the cleanup level should be the more stringent of the
MCL, the concentration yielding no more than a 1 x 10"6 cancer risk, National Primary Drinking Water
Regulation, or the Michigan Act 307 Type B standard. In 1995, Michigan Act 307 (formerly known as
the Michigan Environmental Response Act) was largely replaced by Part 201 of the Natural Resources
and Environmental Protection Act (NREPA), 1994 PA 451, as amended ("Part 201"). The U.S. EPA and
MDEQ project managers report that they are currently assessing remedy performance and will consider
Part 201 standards in updating the action levels for this remedy. The following table provides the levels
that apply to the site for some representative contaminants until that update occurs.

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Cleanup Goals
Contaminant
Benzene
Chlorobenzene
Chloroform
1,2 Dichlorobenzene
1,2 Dichloroethane
1,1 Dichloroethylene
Ethylbenzene
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Vinyl Chloride
Xylene(s)
Cleanup level (ug/L)
1
60
0.19
10
0.4
0.06
30
0.7
0.7
200
0.015
20
10

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    4.0  FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT
4.1           FINDINGS

The RSE team found an extremely well-operated and maintained groundwater extraction and treatment
facility. The RSE team has not seen a Superfund Pump & Treat System that is more efficient, clean and
well maintained in the country. The monthly reports were very detailed, thorough and should be used as
an example for other projects. The Operations team is commended for their efforts. The observations
provided below are not intended to imply a deficiency in the work of the designers, operators, or site
managers but are  offered as constructive suggestions in the best interest of the EPA and the public.
These observations obviously have the benefit of the operational data unavailable to the original
designers.  Furthermore, it is likely that site conditions and general knowledge of groundwater
remediation have  changed overtime.

The U.S. EPA and MDEQ site managers report that they are currently assessing the performance of this
remedy (including a comparison of past and present groundwater contamination, flow, and computer
models) and will likely revise the  remedy's goals. The U.S. EPA and MDEQ site managers further report
that they will consider the 1995 change in state cleanup standards, the remedy operational data to date,
cost effectiveness, and overall remedy time period.
4.2           SUBSURFACE PERFORMANCE AND RESPONSE

4.2.1          WATER LEVELS

Water levels are collected from 79 locations (including the extraction wells) on a monthly basis, and
these measurements are used to generate potentiometric surface maps in the unconfmed and semi-
confined systems for each of these events.  These potentiometric surface maps are included in the
quarterly groundwater monitoring reports.

Water levels southeast of the GWTF consistently indicate a southeasterly flow of groundwater in the
unconfmed system toward the seven extraction wells located between the source area and Little Bear
Creek. Water levels in the deeper semi-confined system also indicate groundwater flow in a southeasterly
direction but suggest little or no influence from the extraction wells near the creek. The fate of the
groundwater in this lower system may involve discharge to the creek, but a lack of water-level data at this
depth and location cannot confirm this.

Water levels in the unconfmed aquifer near the GWTF suggest flow to the northwest toward EW-8 and
EW-10 indicating some capture of groundwater by these extraction wells.

It should be noted that because the potentiometric surface maps are generated including the water level
measurements from active extraction wells, they may be biased in favor of capture. Water levels are
lowest in extraction wells and are typically much higher only short distances away from the wells. Thus,


                                             11

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a linear interpolation method used in generating the potentiometric surface maps would overestimate
drawdown in the water level between the extraction wells and the closest monitoring wells and may bias
capture zone analyses.
4.2.2
CAPTURE ZONE
The capture zone of the OU1 extraction system, located between the source area and Little Bear Creek,
was analyzed during system design by numerical groundwater modeling and particle tracking.  A target
capture zone was determined based on knowledge of source areas and groundwater contamination.
Various pumping scenarios were then simulated with site model and simulated capture zones were
determined through particle tracking. This analysis demonstrated that the simulated capture zone would
include the target capture zone if EW-1 through EW-4 pump at 100 gpm and EW-5 through EW-7 pump
at 75 gpm. This study also showed that the addition of extraction wells in the source area (EW-8 and
EW-9) would not adversely affect capture downgradient of the source area.

In 1997 the model used in design of the extraction system was modified to include a refined model grid
and through improved calibration based on pumping and non-pumping scenarios. This modified model
was then used to optimize the extraction system by determining the minimum extraction rates that would
still provide capture.  As a safety factor, these optimized extraction rates were increased by 10%.
Particle tracking in simulated groundwater flow under various pumping scenarios indicated that pumping
rates in all but two of the wells could be reduced such that the total extraction rate from this 7-well
network would be 420 gpm rather than the design rate of 625 gpm.  The design, optimized +10%, and
actual (August 2001) extraction rates for these 7 extraction wells are summarized in the following table.
Well ID
EW-1
EW-2
EW-3
EW-4
EW-5
EW-6 (EW-6a)*
EW-7
Total**
Design Extraction Rate
(gpm)
100
100
100
100
75
75
75
625
Optimized Extraction
Rate + 10% (gpm)
88
77
33
33
82
82
66
461
Actual Extraction Rate
for August 2001 (gpm)
94
99
93
99
81
60
83
609
* EW-6a is a replacement well for EW-6
** The total represents the total extraction rate for the containment network (OU1) and does not include the water
pumped from the source area wells EW-8, EW-9, and EW-10 (OU2).

As is evident from the summarized extraction rates, all of the extraction wells, with the exception of EW-
6a are operating near or above extraction rates that demonstrated capture during modeling studies.
Furthermore, these extraction rates are more typical of the more conservative design rates rather than the
recently derived optimized rates.
                                              12

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4.2.3
CONTAMINANT LEVELS
In the vicinity of the containment extraction network (OU1), monitoring wells that screen the upper
portion of the unconfmed system or screen the semi-confined system indicate undetectable
concentrations.  The monitoring wells that screen the lower portion of the unconfmed system, however,
have shown various responses to pumping. Monitoring wells OW-12 (near EW-1), W-107i and OW-23
(between EW-1  and EW-2), and W-l 16i (south of EW-5) indicate significant declines in contaminant
concentrations indicating capture and progress toward restoration in the vicinity of those areas.  On the
other hand, contaminant concentrations in W-l 14i (between EW-4 and EW-5) have increased by a factor
of 3 to 4, but the monitoring well appears to be within the capture zone of EW-4 and EW-5.

The concentrations in all but two of the extraction wells (EW-4 and EW-5) have either remained the
same or declined since pumping began in 1996 (December 1999 for EW-10). Contaminant
concentrations in EW-4 have increased by a factor of 10, and concentrations in EW-5 have increased by a
factor of 2. Concentrations of total organic contaminants, especially in EW4, EW-8 and EW-10,
however, continue to exceed 5,000 ppb, suggesting the presence of NAPL acting as a continuous source
of dissolved phase contamination.

The blended influent concentration of VOCs and SVOCs to the GWTF in August 2001 was
approximately 4,000 ppb (approximately 1,500 ppb VOCs and 2,500 ppb SVOCs). With a flow rate of
approximate 700 gpm through the system, this translates to over 30 pounds per day of organic
contaminants.

In the table below, the estimated treatment plant influent contaminant concentrations from the July 1992
Design Analysis Report are compared to the influent concentrations determined from monitoring the
plant process within  a year of system startup and over two years after startup. The  table demonstrates that
the influent concentrations, in general, have not decreased dramatically during plant operations but are
orders of magnitude  lower than the estimated concentrations that may have been used in designing the
treatment plant.  These estimated concentrations used in design were reportedly selected to ensure
protection of human health and the environment.
Parameter
COD
TSS
Ammonia-nitrogen
Vinyl chloride
1,2 DCA
Toluene
1,1 DCA
Acetone
Units
mg/1
mg/1
mg/1
ug/1
ug/1
ug/1
ug/1
ug/1
Design Basis
(July 1992)
1570
30
80
21,000
19,000
14,000
1,900
26
Actual Influent
(January 1998)
73
39
3.8
120
363
482
86
30
Actual Influent
(May 2000)
61
<4
2.9
105
199
452
63
25
                                              13

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Xylenes
1,1,1 TCA
total SVOCs
ug/1
ug/1
ug/1
1,700
1,600
-15,000
37
166
2982
33
176
3234
4.3
4.3.1
COMPONENT PERFORMANCE
DIFFUSED AIR STRIPPER BASINS (DAS)
The purpose of the DAS units is to remove VOCs in the influent groundwater prior to being introduced
to the PACT system. There are two DAS units arranged in parallel, each unit addresses 350 gpm of
influent groundwater and consists of a 31-foot diameter carbon steel tank with a stainless steel bubble
diffuser. The diffuser air is provided by a blower capable of providing 5500 cubic feet per minute (cfm)
with 400 horsepower drives.  The units also receive the offgas from the Powder Activated Carbon
(PACT) system into its headspace for piping into the thermal oxidation unit. Three bypass fans draw air
from the PACT system into the DAS units.

No fouling of these units have been reported. During normal operating conditions (i.e., not during the
VOP) the DAS units provide approximately 80% removal of volatile organic compounds.
4.3.2
THERMAL OXIDATION UNIT (TOU)
The TOU system includes a main exhaust fan with variable speed drive and a 12.5 to 200 horsepower
motor to provide the vacuum necessary to induce all contaminated process air from the DAS units into
the TOU. There is an inlet demister, followed by the regenerative thermal oxidizer which consists of
ceramic media in three vertical heat recovery chambers and a single combustion chamber aligned
horizontally across the tops of the recovery chambers.  Following the combustion unit is a caustic
scrubber to neutralize the hydrochloric acid formed during the combustion process.

The TOU generally operates without incident; however, the exhaust fan motor occasionally shuts down
during storm events.
4.3.3
POWDERED ACTIVATED CARBON TREATMENT SYSTEM (PACT)
After the DAS units, each treatment train has a biological/chemical system designed to remove the
remaining VOCs as well as the SVOCs.  Each system consists of a round, domed multipurpose tank that
is 115 feet in diameter with an outside sidewall height of 16 feet, 9 inches. The center of the tank is
occupied by a first stage clarifier, and the "donut-shaped" peripheral area around that clarifier is divided
into three sections: the first stage aerator, the second stage aerator, and waste activated sludge storage
tank (aerobic digester). The second stage clarifier for each system is a stand alone tank outside of the
domed structure.

The first stage aeration tank occupies a portion of the outer ring and has a volume of 476,000 gallons.
Air is forced into the bottom of the tank through diffusers from a 400 horsepower blower (one blower is
                                             14

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used to operate the tanks in both parallel treatment trains). Phosphoric acid is added to the first stage
aeration influent to ensure proper nutrients are available for the microbes that digest the contaminants.

The first stage clarifier is located in the center of the system and has a volume of 200,000 gallons.  Flow
from the first stage aeration enters the tank and is allowed to settle. Clarified water exits over the wall
into the second stage aeration basin.  The majority of the first stage clarifier settled sludge is recycled to
the first stage aeration.  Excess material (biomass and powdered activated carbon) is pumped to the
aerobic digester.

The second stage aeration system also occupies a portion of the outer ring and has a capacity of 269,000
gallons. This system is also aerated by  diffusers in the bottom of the tank.  Powdered activated carbon is
added at this stage to adsorb toxins and contaminants not readily a consumed by the bacteria population.
Polymer is also added at this stage to improve settling. Process water from this stage over flows into the
second stage clarifier, which is a stand-alone system 45 feet in diameter and 15  feet tall with a capacity
of 175,000 gallons.  The majority of the settled sludge in the second stage clarifier is recycled to the
second stage aeration tank. Excess material, since it contains significant levels  of powdered activated
carbon, is  "wasted" to the first stage aeration tank.

The aerobic digester tank is a 200,000 gallon portion of the outer ring. The sludge directed to this tank
consists of wasted carbon and excess biomass solids.  Air is provided to maintain aerobic conditions.
Excess water can be decanted to the wastewater sump in the sludge treatment building and returned for
treatment to the head of the plant. Waste solids are pumped from this tank to one of three onsite plate
and frame filter presses.

As a whole, the PACT system reduces the remainder of the VOCs not removed  by the DAS units
(including approximately 2 mg/L of ammonia and 30 ug/L of acetone), SVOCs, and COD to
concentrations below discharge standards.

4.3.4           POWDERED ACTIVATED CARBON FEED SYSTEM

The powdered activated carbon (PAC) feed system is  comprised of a  3,000 cubic foot bulk storage silo, a
volumetric rotary-type dry chemical feeder, a wetting  chamber and two air driven diaphragm pumps that
deliver the carbon slurry to the second stage aeration system.  A total  of approximately 80,000 pounds of
PAC is added to the  system each year.  This feed system is operator intensive and requires daily
maintenance.

4.3.5           TERTIARY FILTER SYSTEM

Second stage clarifier effluent enters  the tertiary sand  filter storage tank in the groundwater treatment
building. Two pumps are provided to move the water through the sand filters. Ferric chloride is injected
at a concentration of 10 to 12 ppm  into an inline mixer prior to the filters to assist in phosphorus removal
within the filters. The tertiary sand filter beds are 80 inches in depth and are continuously backwashed.

These filters have had problems with solids removal in the past, but an increase in the amount of ferric
chloride to the current concentration of 10 to 12ppm has improved operation of the filters. The filters
now provide approximately 50% removal of total suspended solids.
                                              15

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4.3.6          GRANULAR ACTIVATED CARBON (GAC) TREATMENT

Process water from the tertiary filters passes through two parallel GAC systems that each consist of two
20,000 pound units arranged in series. Because concentrations of the influent into the filters are usually
undetectable or well below the discharge levels for all contaminants of concern, these units are used as an
"insurance policy" to ensure the plant always satisfies its discharge criteria. The lead vessel is changed
approximately every 6 months due to pressure build up.

4.3.7          SOLIDS HANDLING SYSTEM

Waste sludge from the PACT system is removed from the aerobic digesters to the solids handling
process. The sludge can be treated with lime to improve dewatering efficiency; however, it has not been
necessary to add lime as the addition of powdered activated carbon provided sufficient dewatering. The
system was designed to generate approximately 200 to 350 cubic feet per day; thus, three plate and frame
filter presses, each with a capacity of 100 cubic feet, are on site. Actual sludge generation has been
approximately 40 cubic feet per day with approximately 40% solids.  The sludge is nonhazardous and is
disposed of accordingly. The filter press acid wash system has not been necessary to thoroughly clean
the filter presses.

4.3.8          ONSITE LABORATORY

The onsite laboratory is staffed by the laboratory manager and two full time chemists.  The laboratory is
capable of VOC, SVOC, biological, and inorganic analyses. The monitoring schedule for the process
monitoring is provided in Table 2-1.  The analytical load of the laboratory has increased each year since
the beginning of plant operation and may have the ability in 2002 to handle VOC analyses from the
quarterly monitoring program.
4.4           COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
              MONTHLY COSTS

Estimates of the monthly operations and maintenance costs for the OU1 and OU2 extraction and
treatment systems, based on values provided by the site RPM from quantity allowances established in the
operation contract, are presented in the following table.
Project Management and Support
Remedial Action Support and project management (Black and Veatch)
Remedial Action Support and project management (USAGE)
Labor
Labor: operations personnel and on-site lab
Labor: non-routine extraction-well maintenance or repair

$21,000
$24,500

$60,000
$4,200
                                             16

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Utilities
Electricity
Natural gas
Public Water
Non-utility Consumables and Disposal Costs
Chemicals and materials for treatment plant
Additional maintenance materials
Sludge disposal
Well cleaning chemicals
Chemical Analysis
Off-site analytical work
Total monthly costs

$27,500
$6,250
$300

$12,000
$26,500
$600
$1,300

$13,500
$197,650 per month
4.4.1
PROJECT MANAGEMENT
In addition to management provided by the plant operation subcontractor, project management and
support are provided by USAGE and their primary contractor Black and Veatch. The project
management provided by USAGE is primarily administrative, and the nearby USAGE office can respond
to site incidents more readily than MDEQ personnel in Lansing or U.S. EPA Region 5 in Chicago.  In
addition, USAGE was selected as the oversight agency by U.S. EPA and MDEQ because they are
authorized to deal with "inherently governmental" functions.

The U.S. EPA and MDEQ site managers report that they will assess and likely scale back the current
scope and role of Black and Veatch.
4.4.2
LABOR
The onsite staff consists of the following 9 positions working 45 hours per week at a monthly cost of
approximately $64,000:
•   1 superintendent
•   3 shift operators
•   1 lab manager
•   2 lab technicians
•   1 maintenance position
•   1 administrative assistant.

The August 2001, monthly report provides the following breakdown of time by task:
                                             17

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Activity
Operations
Preventative maintenance
Corrective maintenance
Laboratory
Well sampling
Sludge process
Administrative
Custodial
Total
Hours
433.5
48
64.5
373.5
205.5
21.5
307.25
28.75
1483 hours
Percentage of Total
Hours
29%
3%
4%
25%
14%
1.5%
21%
2%
-100%
4.4.3
UTILITIES
Electricity usage comprises the majority of utilities costs (approximately $27,500 per month).  The two
400 horsepower blowers used for the activated sludge/PACT process and the air strippers account for
approximately 90% of the electricity used on site. The extraction well and transfer pumps account for
the large majority of the remaining 10 %.  Natural gas usage (approximately $6,250 per month) is
primarily for the thermal oxidizer.
4.4.4
NON-UTILITY CONSUMABLES AND DISPOSAL COSTS
The primary chemical additions are phosphoric acid, ferric chloride, and polymer.  Together, the cost for
these chemicals approaches $12,000 per month or over $140,000 per year.

"Additional maintenance materials" refers to those materials required for operation and maintenance of
the plant and onsite laboratory in addition to maintenance of the buildings and grounds. The exact items
that fall under this category were not detailed during the RSE. However, the carbon used for the
treatment plant do fall under this category.  Thus, the monthly costs of $26,500 include an approximate
average monthly combined cost of $15,000 for 80,000 pounds of PAC per year and 40,000 pounds of
GAC per year.

Sludge disposal costs approximately $600 per month to dispose of an approximate  daily average of 40
cubic feet of sludge per day.

Chemicals for well maintenance and rehabilitation generally include acetic acid.  The average monthly
cost is approximately$ 1,300 and is used to generate 600 gallons of acid solution that is used
approximately twice per week.
                                              18

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4.4.5          CHEMICAL ANALYSIS

Offsite chemical analyses are conducted to satisfy the NPDES permit, verify the analytical results of the
onsite laboratory, and analyze the samples from the quarterly sampling events. The monitoring schedule
presented in Table 2-1 indicates those samples analyzed offsite.  In general, approximately 30 samples
are analyzed offsite for the NPDES program, and based on a generic average cost of $150 per analysis,
these samples should cost approximately $4,500 per month. Approximately 261 samples are collected
each year for the quarterly monitoring events, and each sample is analyzed for VOCs and SVOCs.  Given
that a year consists of 12 months, this sampling rate is equivalent to approximately 22 samples per
month. Given a generic average cost of approximately $125 for each VOC sample and approximately
$300 for each SVOC sample, the analyses for the groundwater monitoring, including a number of field
and trip blanks, comprise the remaining $9,000 per month for offsite sampling indicated in the above cost
table.
4.5           RECURRING PROBLEMS OR ISSUES

The most labor intensive operations are maintaining the PAC feed system and the extraction wells. PAC
particles frequently clog in the PAC feed system and require daily attention. The well-maintenance trailer
and acid solution are used approximately twice per week to address those wells that show signs of
fouling.  The current well-maintenance program has been successful in maintaining well yields.
4.6           REGULATORY COMPLIANCE

The monthly reports have not demonstrated any significant non-compliance in the effluent from the plant.
However, occasional deficiencies in dissolved oxygen levels and the requirement to improve dissolved
oxygen levels in the Muskegon River have resulted in the need to install an aerator near the discharge
location. The need to improve dissolved oxygen levels in Muskegon River discharge was identified
during NPDES permit development and discussions.

Site managers report that no appreciable violations of the NPDES discharge permit have occurred in the
7 years of construction, start-up, and  operation to date. Over time, a number of parameters in the plant
discharge have been switched to "report only" status. The State, however, may adjust the permit if major
modifications to the plant are performed.  The site managers report that the State surface water quality
personnel are closely involved and openly communicate in the operation of the remedy.
4.7           TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL
              CONTAMINANT/REAGENT RELEASES

No accidental releases of hazardous chemicals have been documented.
                                            19

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4.8           SAFETY RECORD

The plant has an excellent safety record.  Site managers report that no major lost time accidents have
occurred and that regular safety audits were conducted throughout the construction, start-up, and
operations period to date.
                                            20

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      5.0  EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
                       HEALTH AND THE ENVIRONMENT
5.1           GROUND WATER

Based on a review of the Quarterly Groundwater Monitoring reports and the 1997 capture zone analysis,
it appears that the extraction system is effective in achieving the OU1 goals of plume containment and
preventing discharge of contaminated groundwater to surface water. However, it appears that a
significant mass of contamination may reside in the fine-grained materials in the confining unit and may
be acting as a long-term source of contaminants to the unconfmed aquifer.  Site managers report that this
uncertainty is a contributing reason to why U.S. EPA and MDEQ are assessing the remedy goals and
remedy operation.

Wells EW-8 and EW-10, and the new EW-11 extraction well are source removal wells near the plant site.
EW-8 and EW-10 produce the highest total organic concentrations of all the extraction wells. Their
concentrations have decreased 40-50% since each was put into production. Concentrations in the
monitoring wells in the area near the GWTF and the Cordova Plant remain extremely high for the most
part. Wells on the downgradient edge of the Cordova plant site still show a definite trend of the highest
concentrations in the shallow wells and decreasing concentrations in the lower unconfmed and confined
unit wells. Although the source area wells are removing significant amounts of contaminant mass, it is
not clear whether they are effectively controlling all of the migration of contaminants away from the
source area.

EW-9 is the only extraction well screened in the confined aquifer. The well serves as both a source area
removal well and a containment well. Its operation is coupled with that of EW-8, which is screened in the
unconfmed aquifer, so that an upward gradient is maintained between the confined and unconfmed units.
Total organic compound concentrations in  EW-9 have held fairly steady at approximately 1500ug/l. It
appears to be effectively intercepting the plume and removing mass but the degree of capture being
achieved is difficult to determine due to the lack of monitoring wells in the confined aquifer, particularly
to the east and west of EW-9.
5.2           SURFACE WATER

Little Bear Creek and its unnamed tributary were impacted by site-related contamination that had
migrated from the source area through groundwater prior to implementation of the current remedy. Since
the implementation of OU1, the concentrations between the OU1 extraction system and these creeks have
decreased indicating that migration of contaminants from the source to the creeks has been significantly
reduced through groundwater extraction and treatment.

The effluent from the plant is discharged to a surface water body, Muskegon River.  As the plant meets
the discharge criteria of the NPDES program, no adverse effects on the river are expected.
                                             21

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5.3           Am

The thermal oxidizer has performed well and has not caused any releases to the environment. The
controls of the entire treatment plant do not allow continued operation if the thermal oxidizer is shut
down.  Air samples of the thermal oxidizer influent and effluent air are sent offsite monthly for analysis
and verify the effectiveness of this unit.
5.4           SOILS

Contaminated soils remain onsite at the location of the old chemical facility to the northwest of the
treatment plant. These soils will be excavated and disposed of offsite as part of OU3. Fencing around
that old facility prevents public access. A former representative of the most recent site owner is present
onsite as a caretaker.
5.5           WETLANDS AND SEDIMENTS

Quarterly sampling performed in the Little Bear Creek sediments has shown a significant decrease in site
contaminants since the operation of the pump and treat system has begun.  Under OU3, this sampling will
continue to determine if further remedial action is required for the contaminated sediments.
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                             6.0   RECOMMENDATIONS
Subsequent to the RSE site visit the site managers informed the RSE team that there is a potential
redevelopment/reuse issues at the Ott/Story/Cordova site. The current property owner has expressed
interest in donating the land to the Muskegon County, who has expressed an interest in continuing
operation of the groundwater treatment facility in order to reduce the industrial users wastewater loading
of the Muskegon County POTW.

The RSE team encourages the pursuit of such redevelopment/reuse prospects to the extent that the
remedy remains protective and cost-effective. Data and site interviews during the RSE of this site
indicated that the treatment plant is currently operating near full capacity. Thus, additional flow from
industrial sources would likely represent a small percentage change and should not substantially impact
the system. If substantial industrial flows are to be accepted two options will need to be considered: (1)
reductions in groundwater extraction at the site or (2) enhancements to the treatment system will be
required. The first option should be thoroughly analyzed to ensure the continued protectiveness of the
remedy. The second option should be thoroughly analyzed to ensure that the accepted plan for the
remedy is cost-effective. In analyzing the cost-effectiveness of the plan, the cost-reduction
recommendations below should be considered.

The recommendations below pertain to the  current P&T system at the Ott/Story/Cordova site. The RSE
team recognizes efforts on behalf of the site managers to assess and optimize the system and encourage
the site managers to consider the following recommendations in their assessment. The RSE team also
recognizes that redevelopment/reuse issues may play a role in future operations and maintenance of the
site.  The RSE team encourages immediate consideration of these recommendations and the associated
potential cost savings so that cost-benefit analyses of future redevelopment/reuse plans can account for
the potentially optimized system that could result from implementing the following recommendations.

Cost estimates provided for the following recommendations have levels of certainty comparable to those
done for CERCLA Feasibility Studies (-30/+50%), and these cost estimates have been prepared in a
manner consistent with EPA 540-R-00-002, A Guide to Developing and Documenting Cost Estimates
During the Feasibility Study, July 2000.
6.1           RECOMMENDED STUDIES TO ENSURE EFFECTIVENESS

The groundwater treatment facility continues to regularly meet discharge requirements. An example of
the consistency and quality of the treatment is the evolution of the Discharge Monitoring Report.  Many
of the individual constituents on that report are now listed as "report" (i.e., report the daily maximum
concentration or monthly average concentration) demonstrating the confidence of the regulator in the
treatment plant. Thus, the RSE team has no recommendations regarding the effectiveness or
performance of the treatment plant.

In addition, based on a review of the Quarterly Groundwater Monitoring reports and the capture zone
analysis conducted in 1997, it appears that the extraction system is effective in achieving the OU1 goals
of plume containment and preventing discharge of contaminated groundwater to surface water. Organic

                                              23

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concentrations in the majority of the monitoring wells screened in the upper unconfmed unit near the
creek have dropped to undetectable levels and concentrations in many of the wells screening the lower
portion of the unconfmed unit are decreasing. Surface water and sediment samples collected from the
creek ten months after startup of the extraction system showed dramatic decreases in the concentrations
of organic contaminants. Recent organic concentrations in surface water were at or near undetectable
levels. South of EW-2, the groundwater gradient appears to be toward the wells from the creek. Along
the southern boundary represented by wells EW-4 through EW-7, most of the monitoring wells in the
upper unconfmed unit downgradient of the extraction system have decreased to undetectable levels.
Thus, the RSE team has no recommendations regarding the effectiveness performance of the OU1
extraction system.

However, in the opinion of the RSE team, it is unlikely that the current pump and treat system will
achieve the OU2 objective of groundwater restoration in a reasonable time frame due to the possible
presence  of contamination in the confining unit that is apparently acting as a continuing source of
dissolved phase contamination. Given that this issue impacts the exit strategy of the site, it is discussed
further in Section 6.4 "Recommendations to Gain Site Closeout".
6.2           RECOMMENDED CHANGES TO REDUCE COSTS

6.2.1          REPLACE DAS UNITS WITH TRAY AERATORS OR PACKED TOWERS

Replacing the current DAS units with tray aerators or packed towers would increase VOC removal at a
lower cost.  The current DAS system uses a 400 horsepower blower and provides approximately 80%
removal of VOCs. Two tray aerators, each rated at 500 gpm a piece, could remove 99% of VOCs using a
total of two 20 horsepower fans. This improved removal of VOCs from the process water may also allow
for discontinuing the addition of PAC to the activated sludge system.  Currently, the addition of PAC is
gauged based on the concentrations of VOCs and SVOCs leaving the activated sludge system, and the
improved air stripping would remove the VOCs. The remaining SVOCs would easily be removed
through biological activity or through the subsequent treatment in the GAC units if the lead GAC unit is
replaced more frequently. With the elimination of PAC addition, the use of polymer could also be
reduced as it is typically used to improve the removal of the PAC via filtration. Finally, elimination of
PAC addition will also result in a reduction in the volume of generated sludge.

Considerations with replacing the DAS are fouling issues, loading to the thermal oxidizer and locating
these units onsite. During the RSE visit, it was noted that no scaling or precipitation is apparent in the
existing DAS system, and the RSE team anticipates that fouling for tray aerators or packed towers should
not present a greater fouling problem than that of the existing DAS system. The thermal oxidizer costs
and operation will not change due to the increased loading after initial adjustments are made. The
smaller drives and blowers and the new tray aerators could fit in the existing blower building or packed
towers could be  located near the existing DAS units.

The estimated cost to replace the DAS units is $750,000, but the associated reduction in electrical
utilities (assuming $0.07 per kilowatt hour) would result in a monthly cost savings of approximately
$10,000.  The elimination of PAC usage would decrease monthly costs by approximately $10,000, but an
increase in the frequency  of GAC replacements (perhaps by a factor of 3) would be required resulting in
an increase in monthly costs  of approximately $10,000. Thus, no net savings from a reduction in carbon


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usage would be expected. However, chemical usage and sludge volume could reduce by 50% providing
a savings of over $6,000 per month. Thus, a total monthly savings of approximately $16,000 or an
annual savings of approximately $192,000 could be realized, and this modification should pay for itself
in less than four years. The possibility of reducing plant labor should also exist given that the PAC feed
system requires substantial maintenance on a daily basis.  By comparison, maintenance for two tray
aerators should be less than 8 hours per month.

6.2.2          REEXAMINE NPDES PERMIT AND POTENTIALLY BYPASS PACT SYSTEM

Improving VOC removal to 99% would allow all remaining VOCs (with the exception of acetone) to be
easily addressed by the GAC polishing step at the end of the treatment train.  The remaining
contaminants of concern in the process water would be SVOCs, acetone, and ammonia.  SVOCs are
easily addressed by adsorption to GAC whereas removal of acetone and ammonia require biological
treatment at this plant. At influent rates of approximately 30 ug/L, acetone is well below Water Quality
Based Effluent Limit of 500 ug/L stated in the 1989 ROD. If the discharge criteria for acetone is similar
to that stated limit the influent concentrations of acetone are well below the effluent limits and biological
treatment is not necessary for meeting the discharge criteria for acetone. The average ammonia
concentration in the extracted groundwater is approximately 2 mg/L, which is extremely low compared to
effluent limit of 20 mg/L specified in the October 1997 Discharge Monitoring Report (subsequent reports
specify that this parameter need only be reported).  If the discharge criteria for acetone is substantially
greater than the influent concentration of 30 ug/L and the discharge criteria for ammonia is, in fact, 20
mg/L the treatment plant could reliably treat the extracted groundwater and satisfy the discharge criteria
without the entire PACT system at substantial savings.

If this is the case, then the treatment system would be comprised of air stripping, filtration, and GAC
adsorption. Without the PACT system, the second 400 horsepower blower and chemical additions would
not be required. Also, for this simplified system the onsite laboratory may not be required. The samples
that are currently collected and sent to an offsite  lab for the NPDES program would likely be sufficient
for monitoring operational effectiveness and predict potential operational or discharge problems.  In
addition, other operations and maintenance labor could be reduced. For example, the onsite staff of 9
people likely could be reduced to an onsite staff of 3 to 4 people consisting of a plant manager, operator,
and one or two maintenance people.

The capital costs associated with bypassing the PACT system, including design work and
implementation, could be as high as $400,000. However, substantial savings in O&M could be realized.
The following O&M cost savings (beyond those  provided in Section 6.2.1) should result:

•       Eliminating the use of the second 400 horsepower blower could save approximately $11,000 per
        month.

•       Eliminating the addition of phosphoric acid, polymer, and ferric chloride should result in
        addition savings of approximately $6,000 per month.

•       Although not specifically quantified by the RSE team, eliminating the onsite laboratory may save
        up to $2,000 per month in materials and  supplies.
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•      A reduction in the labor force to a staff of three or four would likely decrease the monthly labor
       costs by $25,000.  The resulting labor cost of approximately $39,000 would be required for a
       plant manager, operator, and one or two maintenance people to be onsite 40 to 45 hours per
       week.

Thus, in total, simplifying the system should result in additional savings of $58,000 per month or
$696,000 per year.  This annual savings would easily offset the costs of implementation within a year.
Combining this annual cost savings with those provided in  Section 6.2.1, simplifying the system would
result in an overall cost savings of $888,000 per year.

6.2.3           REDUCE PROCESS MONITORING AND ANALYSIS

Regardless of the recommendations in 6.2.1 and 6.2.2, the sampling and analysis of the process water
could likely be reduced without sacrificing effectiveness. The current process sampling schedule,
including those samples sent offsite for the NPDES program, is depicted in Table 2-1.  During the RSE,
the plant operator mentioned that wasting rate, phosphoric acid,  ferric chloride, and PAC addition are
the primary aspects of the  system that can be controlled and are controlled by the plant operator. The
wasting rate  is  modified every few months, and the phosphoric acid addition is modified approximately
once a month based on the phosphorous concentration in the first stage clarifier.  Ferric chloride addition
does not require much adjustment, and the PAC addition is modified less frequently than once a month
based on VOC and  SVOC concentrations prior to the GAC. Thus, it appears that the sampling conducted
for the NPDES permit and possibly a limited number of additional samples analyzed onsite may be
sufficient for effective plant operation.  As a result, the analytical work conducted in the onsite
laboratory could likely be  reduced. Substantial cost savings would result due to a decrease in the
technician labor— approximately $100,000 per year would be saved if a single person could operate the
laboratory at reduced capacity or approximately $50,000 per year would be saved if two people were
required. Additional savings in laboratory supplies would also be expected.

6.2.4          REDUCE GROUNDWATER MONITORING AND ANALYSIS

A number of monitoring wells consistently have undetectable levels of organic compounds, particularly
in the upper portion of the unconfined unit. The sampling frequency for many of these wells has already
been reduced to once per year, with many of the wells being sampled only during the March sampling
round. However, there is some opportunity to make further reductions. During the March 2001  sampling
round, 26 of the 64  wells sampled had undetectable concentrations. Of those 26 wells with undetectable
concentrations, 14 of them are both located in the upper portion of the unconfined aquifer and sampled
once per year.  Some  these wells can be eliminated completely from the monitoring program, either
because they are located close to each other (ex. W-104s and W-105s) or because they are well outside
the plume (ex.  MW-33s and MW-34s). Two wells in the upper portion of the unconfined unit (W-13s and
W-16s) are sampled three  times per year (in every quarter except March). This may be due to access
problems during the late winter months  or simply to keep the number of wells sampled during the March
round to a reasonable number. In either  case, these wells could be reduced to a semi-annual sampling
schedule with no adverse impact on the  ability to recognize the meaningful trends in the data.  Because of
their locations, conditions  are not likely to change at either well and both could be reduced to semiannual
or even annual sampling.
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In the lower portion of the unconfmed unit, well K3 Id is sampled quarterly and has consistently yielded
undetectable concentrations since 1998. In addition, well K3d is sampled three times per year (every
quarter except for March) and has consistently yielded undetectable concentrations over the past four
sampling events. Monitoring in both of these wells can be reduced to annually. A few other wells in the
lower portion of the unconfmed unit can also be eliminated altogether or at least reduced to annual
sampling due to their proximity to other monitoring wells or to extraction wells. These wells include W-
1051, OW-12, OW-23, and W-12H.

Four of the wells in the semi-confined unit (W-123d, MW-23d, MW-16d, and MW-34d) are sampled
every March and have had undetectable concentrations for two or more years. Sampling of these four
wells could be eliminated completely. In addition, the quarterly sampling of MW-12d has consistently
yielded undetectable concentrations, and sampling of this well can be eliminated from the monitoring
program.

In general, with 21 quarters of data, it is clear that the quarterly sampling of wells within the plume is not
necessary to determine the concentration trends.  Annual sampling of wells within the plume, including
the extraction wells, would be sufficient for trend analysis.  With the specific mentioned reductions in
monitoring and this general recommendation to reduce the sampling frequency, the monitoring program
recommended by the RSE team consists of quarterly sampling in approximately 20 wells and  annual
sampling in approximately 65 wells. Thus, a total of 125 samples would be collected and analyzed each
year instead of the approximate 260 wells that are currently sampled.  Given that the samples  are
analyzed for both VOCs and SVOCs at a total cost of $425 per sample ($125 for VOCs and $300 for
SVOCs), this recommendation could result in an annual savings of over $55,000 per year in analysis
costs alone.

6.2.5           REMOVE EXCESS EQUIPMENT AND DO NOT CONSTRUCT THE PLANNED STORAGE
               BUILDING

A large amount of unused equipment is stored onsite and can be removed if additional storage space is
required. A new building should not be constructed for additional storage space. Three filter presses
with a capacity of 100 cubic feet are onsite, but only 40 cubic feet are processed each day.  Thus, only
one filter press is required.  Current practice is to alternate use of each of the filter presses.  Only one
filter press should be used and the other two should be removed to allow for storage  space.

The blower building houses six 400 horsepower blowers, but only two are used, and if recommendations
6.2.1 and 6.2.2 are implemented, then none of these blowers would be used. The unused blowers should
be removed if storage space is required. Other equipment can also be removed such as the filter press
acid wash system and lime feed.  Other equipment that will be not be needed after implementing the
recommendations in 6.2.1, 6.2.2, and 6.2.3 should also be removed and made available to other Fund-
lead P&T systems that may need the equipment (see Section 6.5).

6.2.6           EVALUATE POTENTIAL REDUCTION IN ONSITE PRESENCE OF USACE

Now that the system has been operating for over 4 years and has consistently met discharge requirements,
oversite from USACE could likely be reduced. Current costs  are approximately $24,500 per month
(approximately  13% of the total site costs) and involves  onsite representation of USACE approximately
three times per week.  Adequate oversite may be provided by  less frequent site visits. If other cost-
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reducing recommendations are implemented, the system will be simplified and should require even less
oversite.

6.2.7          REMOVE TRAILERS FROM THE SITE

At the time of the RSE site visit, two large office trailers remained at the site, and the RSE team
recommended removing at least one of them because adequate space can be made in other buildings and
the costs of the trailer rentals can be eliminated. One trailer continues to be used by USAGE for
administrative purposes and the other, which was maintained by a technical support partner of the
operations subcontractor, has been removed.

6.2.8          HAVE ONSITE STAFF CONDUCT SAMPLING FOR OU3 AND EVALUATE FOR POTENTIAL
              REDUCTION OF SAMPLING

Although a substantial staff of 9 people of the operations subcontractor are onsite each day, sampling and
the surface water and sediments in OU3 are conducted by the offsite staff of the primary contractor. This
sampling could be conducted by the onsite staff and sent to the primary contractor accordingly. This
would save the labor and costs associated with the staff of the primary contractor traveling from Kansas
City to the site four times per year. If a staff of two individuals is required to conduct the OU3  sampling
over a period of 3 days, and an additional day is required for travel each way, then approximately
$15,000 could be saved each year by having the onsite staff do the sampling. These cost reductions
would result primarily from eliminating labor costs associated with travel and lodging and per diem
required over the three to four day period.
6.3           MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT

6.3.1          ESTABLISH CONSISTENT SAMPLING METHOD

There has been a substantial effort made to improve the quality and efficiency of the groundwater
sampling program by installing dedicated bladder pump systems in many of the more frequently sampled
wells and utilizing low flow sampling methods. These efforts are commendable. However, there is still
significant variation in sampling methods between different groups of wells, which likely introduces
greater variability to the data and may make it difficult to correlate concentrations between wells. This
could potentially lead to erroneous conclusions about the performance of the remediation system. Some
wells are sampled with peristaltic pumps and others are sampled with bailers. This is due to several
factors, such as sampling frequency, depth to water and well construction/condition issues. The
comparability of data between wells sampled with the dedicated bladder pumps and peristaltic pumps,
both utilizing low-flow methods, is probably fairly good. However, it is difficult to compare data from
the wells sampled with bailers to data generated from either of the other two methods. It would be much
more preferable to arrive at a single method for sampling all the wells that do not have dedicated pumps
that will produce data of comparable  quality to the  dedicated systems.

Due to the depth to water in some of the wells, some type of portable down-hole pump would probably
be the best alternative. The plant staff indicated that some  of the wells would not accommodate the
dedicated pump system due to well alignment problems or small-diameter casings. However, bladder
pump systems have  recently come on the market in diameters as small as 0.5 inches that may overcome


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some of those problems. The Groundwater Summary Report refers to the Micropurge dedicated sampling
pumps, which is a trademark name for pump systems made by QED Environmental. The same firm
markets portable pump systems in diameters as small as 0.75 inches that operates off the same controller
unit as many of their other pumps, so the capital investment for the new pump would be relatively small.
If there are wells that will not accommodate the small diameter pump, due to the condition of the well,
serious consideration should be given as to whether those wells are suitable for sampling. They may need
to be replaced with a new well, replaced in the program by substituting another well in the same area, or
just eliminated from the program altogether.

Modification of the sampling method and purchasing of materials and a portable pump, approximately
$2,000, should be delayed until the number of monitoring wells or frequency of monitoring has been
reduced as suggested in Section 6.2.4.

6.3.2           MODIFY PROGRAM FOR WATER-LEVEL MEASUREMENT

Monthly water levels are collected in 79 wells and piezometers. The data that have been collected over
the last five years show normal seasonal fluctuations of 1-5 feet.  Since the baseline has been well
established, the frequency of measurement could easily be decreased to quarterly during normal system
operation without affecting the ability to evaluate the effectiveness of the system. Selected wells that
have proven to be located in more dynamic parts of the aquifer may need to remain on a monthly
schedule if the additional data has an impact on the operation of the extraction system. Likewise, when
changes are made in the operation of the extraction system  such as changing pumping rates or adding  or
removing an extraction well, water levels should be taken at least monthly within the area influenced by
the change until the system reaches a new equilibrium. Any affects of short-term shutdowns for
maintenance or well rehabilitation will have negligible effect on the groundwater flow system and would
not create the need for increased monitoring frequency.

Water levels are also collected in the extraction wells and are used to construct water level contour maps
and assess the degree of capture. The water levels for the extraction wells are measured in the
piezometers installed in the  extraction well filter pack.  It would be more appropriate to use the water
levels in the three rehabilitation wells surrounding the well for contouring purposes and evaluating the
effectiveness of the capture  system. The water level in the filter pack is affected by the head loss at the
borehole wall and vertically converging flow immediately surrounding the well. Because of these effects,
the water level in the filter pack will not be representative of the water level in the  formation and will
overestimate the degree of capture being achieved. The water levels from the three rehabilitation wells
could be averaged to arrive at a single value or one of the three wells could be selected as representative
of the location based on past water level records.

The costs associated with this recommendation are negligible. It is likely that a reduction in the
frequency of measuring water levels will decrease labor potentially making it easier for the site to operate
with a smaller staff.
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6.4           MODIFICATIONS INTENDED TO GAIN SITE CLOSE-OUT

6.4.1          ESTABLISH AGREEMENT BETWEEN THE OU2 REMEDY AND THE ROD

The pump and treat system at the Ott/Story/Cordova site addresses two operable units: OU1, which has
an objective of plume containment in the unconfined aquifer, and OU2, which has an objective of aquifer
restoration. In the opinion of the RSE team, it is unlikely that the current pump and treat system will
restore groundwater to its beneficial use in a reasonable time frame due to the possible presence of
contamination in the confining unit that apparently acts as a continuing source of dissolved phase
contamination. The site managers should consider if the remedy will achieve the OU2 goals of
restoration. One strong possibility for addressing the possible discrepancy between the remedy and the
associated goals is to consider modification of the  OU2 goal from aquifer restoration to plume
containment.

If this avenue is considered, three main approaches could be taken:

       the OU2 extraction system could be shutdown leaving the OU1 wells to contain the plume at the
       downgradient location;

       the OU2 extraction system could continue operating to extract mass and provide the current
       extent of capture; and

       the capture zones of the OU2 extraction system can be analyzed to determine if it is adequately
       containing the source area and the system  can be augmented if with additional pumping if
       necessary.  This approach has no direct added benefit to protection of human health and the
       environment, but if the source area  is  adequately contained, it may facilitate the potential use of
       effective aggressive source removal technologies that may be developed in the future.

Unless substantial savings in O&M can be demonstrated by shutting down the OU2 extraction system
(and that seems very unlikely), the RSE team  does not endorse that approach. In order to determine the
better of the two remaining approaches, the  RSE team recommends that a preliminary capture zone
analysis and cost-benefit analysis be conducted on the OU2 extraction system.

Because the OU2 extraction wells had a goal of aquifer restoration and not containment, the capture
zones of these wells have not been thoroughly analyzed. It is evident that EW-8 through EW-10 (and
EW-11 when  it begins operating) capture the source area plume  to some degree, but it is unclear to what
extent. A thorough analysis of capture should be included in the site managers' current assessment of the
remedy and should include the following steps for both the confined and semi-confined aquifers:

       delineating the source area through  analysis of groundwater samples;

       determining a target capture zone based on the high concentration areas that should be contained;

       developing potentiometric surface maps from water level measurements;

       estimating the capture zone according to these potentiometric surface maps; and
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•      comparing the target capture zone with the estimated one.

This preliminary analysis should give an indication of the degree to which contaminants are being
captured by the OU2 system. If this analysis indicates capture is incomplete, the need for additional
pumping and possibly additional wells should be weighed against the costs of adding those wells and
treating the additional extracted water.  It should be noted that while contamination in the unconfmed
system that eludes the OU2 extraction system will likely be captured by the OU1 extraction system, this
is not the case for contamination in the semi-confined aquifer. The OU1 wells, do not screen the semi-
confined aquifer; therefore, if EW-9 does not provide adequate containment of the deep contamination,
the deep plume could continue to migrate unabated. Thus, a more thorough analysis of the EW-9 capture
zone, including modeling of the groundwater flow, may be warranted.
6.5           SUGGESTED APPROACH TO IMPLEMENTATION OF
              RECOMMENDATIONS

A number of the above recommendations can be implemented immediately and concurrently. However,
due to the relatively high cost savings, complexity, and time sensitivity of some recommendations
compared to others, some recommendations should take precedence.  One of the most immediate
concerns is addressed by Recommendation 6.2.5. With the large amount of building space onsite, there
is no need to construct a new storage building as planned. Rather, unused equipment should be removed
as discussed in Section 6.2.5 to provide adequate storage space. Recommendations 6.2.3 (reduce process
monitoring), 6.2.4 (reduce groundwater sampling program, 6.2.6 (evaluate the potential for reduction in
USAGE oversight), 6.2.7 (remove the trailers),  and 6.2.8 (have onsite staff conduct OU3 sampling) are
relatively simple to implement and may be accomplished before the next groundwater sampling event.

Due to the potential for significant cost savings , the site managers should clarify the discharge criteria
for those parameters that must be addressed by  the biological treatment (e.g., ammonia and acetone). If
the influent of the plant is below this discharge  criteria, the PACT system should be bypassed and the
system simplified as discussed in Section 6.2.2. If ammonia and acetone do require treatment in order to
meet the discharge criteria, then the PACT system  must remain in operation. However, the DAS units
could be replaced by an efficient air stripper and the PAC addition can be eliminated as discussed in
Section 6.2.1.  If the PACT system can be bypassed but implementing the change requires a new decision
document, other aspects of system simplification (such as replacement of the DAS units with the air
strippers) should not be delayed.

As the above recommendations are implemented Recommendations 6.3.1, 6.3.2, and 6.4.1 should be
implemented as time permits.  That is, they should be implemented as soon as possible but should not
interfere with  implementation of the other recommendations. Similarly, delays with the other
recommendations should not delay implementation of these recommendations.
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                                     7.0  SUMMARY
In general, the RSE team found a well-operated treatment system. 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.

The treatment plant regularly meets the discharge criteria and the pump and treat system has successfully
reduced discharge of contaminated groundwater to nearby surface water.  As a result, the RSE team does
not provide specific recommendations with regard to effectiveness.  The RSE team does, however, make
several recommendations that, if implemented, could result in significant cost savings.  These
recommendations include replacing the current diffused air strippers with a more efficient model,
reexamining the NPDES permit and potentially bypassing the PACT system, and reducing process and
aquifer monitoring. With regard to technical improvement of the site operations, the RSE team
recommends modifying the monitoring well sampling and the water-level measurement programs.
Finally, it is the opinion of the RSE team that the OU2 remedy will not likely meet the  objective of
aquifer restoration as stated in the 1990 ROD due to the presence of subsurface contamination that may
act as a continuing source of dissolved phase contamination.  The RSE team recommends that the site
managers consider if the remedy will achieve the OU2 goals of restoration.  The RSE team provides
strategies that may assist the site managers in bringing the remedy and goals into agreement.

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
6.2. 1 Replace DAS units with tray
aerators or packed towers
6.2.2 Reexamine NPDES permit
and potentially bypass PACT
system
6.2.3 Reduce process monitoring
and analysis
6.2.4 Reduce aquifer monitoring
and analysis
6.2.5 Remove excess equipment
and do not construct the planned
storage building
6.2.6 Evaluate potential reduction
in onsite presence of USAGE
6.2.7 Remove trailers from the site
6.2.8 Have onsite staff conduct
sampling for OU3
6.3.1 Establish consistent
sampling method
6.3.2 Modify program for water-
level measurement
6.4.1 Establish agreement between
the OU2 remedy and ROD
Reason
Cost
Reduction
Cost
Reduction
Cost
Reduction
Cost
Reduction
Cost
Reduction
Cost
Reduction
Cost
Reduction
Cost
Reduction
Technical
improvement
Technical
improvement
Site Closeout
Estimated Change in
Capital
Costs
$750,000
$400,000
$0
$0
Not
quantified
Not
quantified
Not
quantified
$0
$2,000
$0
Not
quantified
Annual
Costs
($192,000)
($696,000)
($50,000)
to
($100,000)
($55,000)
Not
quantified
Not
quantified
Not
quantified
($15,000)
$0
$0
Not
quantified
Lifecycle
Costs *
($5,010,000)
($20,480,000)
($1,500,000)
to
($3,000,000)
($1,650,000)
Not
quantified
Not
quantified
Not
quantified
($450,000)
$2,000
$0
Not
quantified
Lifecycle
Costs **
($3,094,000)
($11,215,000)
($806,000)
to
($1,612,000)
($886,000)
Not quantified
Not quantified
Not quantified
($242,000)
$2,000
$0
Not quantified
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
                                                 33

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FIGURES

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   FIGURE 1-1.  SITE LAYOUT OF THE OTT/STORY/CORDOVA SUPERFUND SITE INDICATING SAMPLING AND ANALYSIS RESULTS OF THE UPPER PORTION
   OF THE UNCONFINED AQUIFER FROM THE MARCH 2001 SAMPLING EVENT.
                                                      • OTT/STORY/CORDOVA
                                                      CHEMICAL  PRODUCTION
                                                             FACILITY
                         GROUNDWATER
                          TREATMENT
                            FACILITY
                                                                                                                     4.
                                                                                                                                 -N-
                                                                                                                         NOTES:

                                                                                                                     1.   CONCENTRATIONS IN  UG/L
                                                                                                                     2.
CONCENTRATIONS OF TOTAL ORGANIC
COMPOUNDS IN  EXTRACTION WELL
SAMPLES  ARE SHOWN.  VALUES WERE
NOT USED FOR  CONTOURING BECAUSE
EXTRACTION WELLS ARE SCREENED
OVER ENTIRE UNCONFINED SYSTEM.

ND IS  NOT DETECTED
NS IS  NOT SAMPLED

IF COMPOUND WAS  NOT DETECTED IN
SAMPLE, A ZERO VALUE WAS ASSIGNED
FOR CONTOURING PURPOSES.

CONCENTRATIONS ARE THE TOTAL
CONCENTRATION  OF THE VOLATILE
ORGANIC  (SW-846 METHOD 8260)
AND SEMIVOLATILE ORGANIC (SW-846
METHOD 8270A) ANALYSES.
                                                                                                                                LEGEND

                                                                                                                            GROUNDWATER MONITORING
                                                                                                                          W WELL

                                                                                                                          A EXTRACTION WELL
                                                                                                                                                700
                                                                                                                           SCALE  IN  FEET
(Figure reproduced from Figure 4.1 of the Groundwater Summary Report—Quarter 21, Ott/Story/Cordova Operable Units 1 and 2, Black and Veatch Special Projects
Corp., June 2001).

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   FIGURE 1-2.  SITE LAYOUT OF THE OTT/STORY/CORDOVA SUPERFUND SITE INDICATING SAMPLING AND ANALYSIS RESULTS OF THE LOWER PORTION
   OF THE UNCONFINED AQUIFER FROM THE MARCH 2001 SAMPLING EVENT.
                                   W-5D®
                                     NS
                                      f

                               W-6D*
                                 NS
• OTT/STORY/CORDOVA
CHEMICAL  PRODUCTION
       FACILITY
                                                           EW-10
                                                           12,204
                                                        W-18S
                                               000
                                     W-127S. '
                                       NS  '  EW-11
   UW1
   NS
   EW-8
   20,886
                         GROUNDWATER
                          TREATMENT
                            FACILITY
                                                                                                UNNAMED
                                                                                                TRIBUTARY
                                                                         EW-
                                                                       A576.2

                                                                         W-1171
                                                                          398
                                                                       7 On
                                                                                                                      4.
                                                                                                                                  -N-
                                                                   NOTES:

                                                               1.   CONCENTRATIONS  IN UG/L
                                                                                                                      2.
CONCENTRATIONS OF TOTAL ORGANIC
COMPOUNDS IN EXTRACTION WELL
SAMPLES ARE  SHOWN.  VALUES WERE
NOT USED FOR CONTOURING BECAUSE
EXTRACTION WELLS ARE SCREENED
OVER ENTIRE UNCONFINED SYSTEM.

ND IS  NOT DETECTED
NS IS  NOT SAMPLED

IF COMPOUND  WAS  NOT DETECTED IN
SAMPLE, A ZERO VALUE WAS ASSIGNED
FOR CONTOURING PURPOSES.

CONCENTRATIONS ARE THE TOTAL
CONCENTRATION OF THE VOLATILE
ORGANIC  (SW-846 METHOD 8260)
AND SEMIVOLATILE ORGANIC (SW-846
METHOD 8270A) ANALYSES.
                                                                           LEGEND

                                                                      GROUNDWATER MONITORING
                                                                    W WELL

                                                                    A EXTRACTION WELL
                                                                                                                                                 700
                                                                                                                            SCALE  IN  FEET
(Figure reproduced from Figure 4.4 of the Groundwater Summary Report—Quarter 21, Ott/Story/Cordova Operable Units 1 and 2, Black and Veatch Special Projects
Corp., June 2001).

-------
   FIGURE 1-3.  SITE LAYOUT OF THE OTT/STORY/CORDOVA SUPERFUND SITE INDICATING SAMPLING AND ANALYSIS RESULTS OF THE SEMI-CONFINED
   AQUIFER FROM THE MARCH 2001 SAMPLING EVENT.
                                                       • OTT/STORY/CORDOVA
                                                       CHEMICAL PRODUCTION
                                                             FACILITY
                                                                                                           -33D
                                                                                                                                  -N-
                                                                                                                          NOTES:

                                                                                                                      1.   CONCENTRATIONS  IN UG/L

                                                                                                                      2.   CONCENTRATIONS  OF TOTAL ORGANIC
                                                                                                                          COMPOUNDS IN EXTRACTION WELL
                                                                                                                          SAMPLES ARE SHOWN.   VALUES WERE
                                                                                                                          NOT USED  FOR CONTOURING BECAUSE
                                                                                                                          EXTRACTION WELLS ARE SCREENED
                                                                                                                          OVER ENTIRE UNCONFINED SYSTEM.

                                                                                                                      3.   ND  IS NOT DETECTED
                                                                                                                          NS  IS NOT SAMPLED

                                                                                                                      4.   IF COMPOUND WAS NOT DETECTED IN
                                                                                                                          SAMPLE,  A ZERO  VALUE WAS ASSIGNED
                                                                                                                          FOR CONTOURING PURPOSES.

                                                                                                                      5.   CONCENTRATIONS  ARE THE TOTAL
                                                                                                                          CONCENTRATION OF THE VOLATILE
                                                                                                                          ORGANIC  (SW-846 METHOD 8260)
                                                                                                                          AND SEMIVOLATILE ORGANIC (SW-846
                                                                                                                          METHOD  8270A)  ANALYSES.
       LEGEND

  GROUNDWATER MONITORING
W WELL

A EXTRACTION WELL
                                                                                                                                                 700
         I I                                                                 T

(Figure reproduced from Figure 4.7 of the Groundwater Summary Report—Quarter 21, Ott/Story/Cordova Operable Units 1 and 2, Black and Veatch Special Projects
Corp., June 2001).

-------
FIGURE 2-1. SITE LAYOUT OF THE OTT/STORY/CORDOVA SUPERFUND SITE INDICATING SAMPLING AND ANALYSIS RESULTS OF THE UPPER
PORTION OF THE UNCONFINED AQUIFER FROM THE MARCH 2001 SAMPLING EVENT.
                                                                                                     I TfttJod fCyoanJ tVaifT

                                                                                                      TO HH/SKEGQH
                                                                                                           E»
                                                                                                           :, JuwLeS
                                                                                   GRANULATED
                                                                                    ACTIVATED  :•
                                                                                    CARBON

                    DIFFUSEO AIM  ««wr IJ!dir«
                     STRIPPERS
                                                                Se-wndary staga
                      THERMAL/
                      OKJDATION |
                        uwnr  I
*
               SRClUNDWATER TREATMENT PROCESS
               OTT/STORY/CORDOVASUPERFUND SITE
                                                                                                                  TQ
                                                                                                            Disposal
(Note: This figure was provided to the RSE team by the superintendent (FTH&C) of the Groundwater Treatment Facility.)

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                                                             Solid Waste and
                                                             Emergency Response
                                                             (5102G)
542-R-02-008S
October 2002
vwwv.clu-in.org/rse
www.epa.gov/tio
U.S. EPA National Service Center
for Environmental Publications
P.O. Box 42419
Cincinnati, OH 45242-2419

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