Final Report Pilot Region Based Optimization Program for Fund Lead Sites in EPA Region 3 Site Optimization Tracker: North Penn Area 1 Superfund Site Souderton Montgomery County Pennsylvania


          Final Report

 Pilot Region-Based Optimization
   Program for Fund-Lead Sites
        in EPA Region 3

    Site Optimization Tracker:
North Penn Area 1 Superfund Site
           Souderton
Montgomery County, Pennsylvania

           EPA Region III
             5>

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               Solid Waste and        EPA 542-R-06-006k
               Emergency Response     December 2006
               (5102P)             www.epa.gov
Pilot Region-Based Optimization Program
   for Fund-Lead Sites in EPA Region 3

       Site Optimization Tracker:
    North Penn Area 1 Superfund Site
               Souderton
   Montgomery  County, Pennsylvania

               EPA Region III

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    Site Optimization Tracker:

North Penn Area 1 Superfund Site
            Souderton
Montgomery County, Pennsylvania
           EPA Region III
           December 30, 2005

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         SECTION 1:



CURRENT SITE INFORMATION FORM

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Date:
12/30/05
Filled Out By:     GeoTrans, Inc.

A. Site Location, Contact Information, and Site Status
1. Site name 2
North Penn Area 1 S
4a. EPA RPM
Maria Garcia (Angie)
4b. EPA RPM Phone Number
215-814-3199
4c. EPA RPM Email Address
garcia.maria@epa.gov
Site Location (city and State) 3. EPA Region
ouderton, Montgomery County, PA 3
5a. State Contact
April Flipse
5b. State Contact Phone Number
484-250-5721
5c. State Contact Email Address
april.flipse@state.pa.us
5. Is the ground water remedy an interim remedy or a final remedy? Interim | | Final IXI
6. Is the site EPA lead or State-lead with Fund money? EPA IXI State I I

B. General Site Information
1 a. Date of Original ROD for Ground Water Remedy
9/30/94 OU2-Interim
2a. DateofO&F
9/24/98
3. What is the primary goal of the P&T system
(select one)?
1 1 Contaminant plume containment
IXI Aquifer restoration
1 1 Containment and restoration
1 I Well-head treatment
lb. Dates of Other Ground Water Decision Documents (e.g., ESD, ROD Amendment)
ESD#1 (10/29/97), ESD #2 (9/24/98)
2b. Date for transfer to State
September 2008
4. Check those classes of contaminants that are
contaminants of concern at the site.
K| VOCs (e.g., TCE, benzene, etc.)
n SVOCs (e.g., PAHs, PCP, etc.)
1 1 metals (e.g., arsenic, chromium, etc.)
1 I other
5. Has NAPL or evidence of NAPL been observed at the site? Yes I I No IXI
,„,,., . , . „ 0* (discontinued in early
6. What is the approximate total pumping rate ! AAC\
7. How many active extraction wells » ft
(or trenches) are there?
9. How many samples are collected
from monitoring wells or piezometers „
each year? (e.g., 40 if 10 wells are
sampled quarterly)
11. What above-ground treatment processes are usec
1 I Air stripping
I | Carbon adsorption
1 I Filtration
I | Off-gas treatment
1 I Ion exchange
8. How many monitoring wells are .
regularly sampled?
10. How many process monitoring samples
(e.g., extraction wells, influent, effluent, etc.) AA
are collected and analyzed each year? (e.g., 24
if influent and effluent are sampled monthly)
(check all that apply)?
1 I Metals precipitation
I | Biological treatment
O UV/Oxidation
I | Reverse osmosis
IXI Other was direct discharge to POTW
12. What is the approximate percentage of system downtime per year? 10% | | 10-20%| | >20% | |

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C. Site Costs
1. Annual O&M costs
O&M Category
Labor: project management, reporting,
technical support
Labor: system operation
Labor: ground water sampling
Utilities: electricity
Utilities: other
Consumables (GAC, chemicals, etc.)
Discharge or disposal costs
Analytical costs
Other (parts, routine maintenance, etc.)
O&M Total
Actual1 Annual
Costs for FY04
$5,489

$1,013
$669

$8,793
$1,000*
$8,524
$25,668
Estimated2 Annual
Costs for FY05

Estimated2 Annual
Costs for FY06

The O&M total should be equal to the total O&M costs for the specified fiscal years, including oversight from
USAGE or another contractor. For costs that do not fit in one of the above cost categories, include them in the
"Other" category. If it is not possible to break out the costs into the above categories, use the categories as best
as possible and provide notes in the following box.
2. Non-routine or other costs

Additional costs beyond routine O&M for the specified fiscal years should be included in the above spaces. Such
costs might be associated with additional investigations, non-routine maintenance, additional extraction wells, or
other operable units. The total costs billed to the site for the specified fiscal years should be equal to the O&M
total plus the costs entered in item 2.
Notes on costs:

1. FY04 costs are based on costs for EPA's contractor who is conducting the LTRA.
2. Pumping was discontinued in early 2005, soon after the initial optimization evaluation meeting. Costs
for FY05 and FY06 are difficult to predict at this point given the fact that pumping has been
discontinued, and further investigation will be conducted at the site.

* Analytical costs were estimated by the ROET based on the sampling program. The analytical costs are not
incurred by the EPA site team because the samples are analyzed by the CLP program. However, analytical costs
similar to those estimated will likely be incurred by the State when the site is transferred to the State after LTRA.
The decrease from FY05 to FY06 reflects the assumed sampling reduction.
ForFY04 costs, the following comments apply:
- Direct labor is contractor's personnel costs, excluding sampling labor.
- Other costs include: sampling supplies, equipment, shipping of samples, sampling report, and contractor's
indirect costs and fees.

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D. Five-Year Review
1. Date of the Most Recent Five-Year Review       September 26,2003
2. Protectiveness Statement from the Most Recent Five-Year Review
    I  |   Protective                              IXI   Not Protective

    M   Protective in the short-term                	   Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below

The site is considered protective in the short-term, but fluctuating high concentrations at
monitoring well NPA1-S1 should be investigated further before determining the remedy is
protective in the long-term. The 5-year review recommended that such an investigation be
performed to determine the source.
E. Other Information
If there is other information about the site that should be provided please indicate that information in the space
below. Please consider enforcement activity, community perception, technical problems to be addressed, and/or
areas where a third-party perspective may be valuable.

The previously active pumping well produced water with very low concentrations of PCE
(several ug/1), the prime contaminant of concern.  In contrast, monitoring well KPA1-S1,
located downgradient of that sole extraction well, has concentrations in the ppm range for
PCE, Pumping is not occurring from NPA1-S1,

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                             SECTION 2:

               FOLLOW-UP HISTORY AND SUMMARIES
Note: Follow-up summaries are provided in reverse chronological order and include updated
and/or new recommendations.

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                              FOLLOW-UP HISTORY
 Date of Original Optimization Evaluation
            February 8, 2005 (Evaluation meeting)
            August 5, 2005 (Final report)	
           Meeting Date
 Report Date
Item
             July 20, 2005
          November 7, 2005*
  August 5, 2005      Follow-Up #1 (conducted as part of pilot project)
December 30, 2005    Follow-Up #2 (conducted as part of pilot project)
                                                   Follow-Up #3
                                                   Follow-Up #4
                                                   Follow-Up #5
                                                   Follow-Up #6
                                                   Follow-Up #7
                                                   Follow-Up #8
"x" in box indicates the item has been completed
* Although the ROET (including the optimization contractor) was present for follow-up meeting
#2, the RPM was not available and other site team members (e.g., the hydrogeologist) reported
that no additional progress had been made since the previous follow-up meeting. In addition, the
site hydrogeologist noted that there was no need for further technical assistance at this point.

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                           SUMMARY OF FOLLOW-UP #2
Site or System Name
Date of This Follow-Up Summary
Date of Follow-Up Meeting or Call
(Indicate if Meeting or Call)
North Perm Area 1 Superfund Site
December 30, 2005
November 7, 2005 - Meeting*
 * Although the ROET (including the optimization contractor) was present for follow-up meeting #2, the RPMwas
 not available and other site team members (e.g., the hydrogeologist) reported that no additional progress had been
 made since the previous follow-up meeting. In addition, the site hydrogeologist noted that there was no need for
further technical assistance at this point.

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                  SUMMARY OF FOLLOW-UP #1
Site or System Name
Date of This Follow-Up Summary
Date of Follow-Up Meeting or Call
(Indicate if Meeting or Call)
North Perm Area 1 Superfund Site
August 5, 2005
July 20, 2005 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Paul Leonard
Kathy Davies
Peter Rich
Rob Greenwald
Doug Sutton
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
GeoTrans, Inc.
Phone
215-814-3130
215-814-3350
215-814-3315
410-990-4607
732-409-0344
732-409-0344
Email
kuluj Jan. normfficpa . go v
Lconard.paulffi,epa..8ov

davics.kalhy@cpa.gov
prichi».scotransinc.com

rgreenwaldi3-Keotransinc.com

djajUomSiggote^^
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Maria Garcia (Angie)
Affiliation
U.S. EPA Region 3 (RPM)
Phone
215-814-3199
Email
Giisia=Mi!iiiiSsiiy^

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IMPLEMENTATION STATUS OF PREVIOUSLY IDENTIFIED
HIGH PRIORITY RECOMMENDATIONS
Recommendation
Recommendation
Reason
2.1 Prepare a Document that Clearly States and Illustrates the Conceptual Model
Protectiveness
Implementation
Status
In Progress
 Comments: The RPM indicates she is constructing a work request that will include this "Conceptual Model
 task". She hopes to have this work assignment in place by September 2005.
  Recommendation
2.2 Characterize Area near NP1-S1 Initially with a Pump Test (In Place of Planned
Packer Test)
Recommendation
Reason
Protectiveness
Implementation
Status
In Progress
 Comments: The RPM indicates she is constructing a work request that will include this pump test. She
 hopes to have this work assignment in place by September 2005, and hopes that the results will be available
 prior to the next follow-up for this site, which will likely occur in October or November 2005. The RPM
 also noted that she may request Technical Assistance from the Optimization Evaluation Team to review the
 statement of work, cost estimates, etc.
Recommendation
Recommendation
Reason
4.1 Improve Semi-Annual Monitoring Reports
Protectiveness
Implementation
Status
In-Progress
 Comments:  The RPM indicates this recommendation is planned to be implemented.
IMPLEMENTATION STATUS OF OTHER PREVIOUSLY
IDENTIFIED RECOMMENDATIONS
Recommendation
Recommendation
Reason
2.3 Consider Need for Further Characterization
Technical Improvement
Implementation
Status
Delayed (Contingent)
Comments: This recommendation is contingent on the results of Recommendations 2.1 and 2.2.

Recommendation
Recommendation
Reason
4.2 Revise Pumping Strategy at
Technical Improvement
GKM Well
Implementation
Status

Implemented
Comments: Pumping was reportedly discontinued at the GKM well soon after the initial evaluation
meeting, in early 2005.

Recommendation
Recommendation
Reason
5.1 Consider Options for In-Situ Remediation Near NP1-S1
Site Closeout
Implementation
Status
Delayed (Contingent)
Comments: This recommendation is contingent on the results of Recommendations 2.1 and 2.2.

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OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP

   •  The major change is that pumping was discontinued at the lone extraction well, pending
      the results of the pumping test at NP1-S1. Therefore, there is currently no ongoing
      ground water extraction.

   •  The RPM indicates she may ask the evaluation team for technical assistance to evaluate
      the statement of work and cost estimates for the work plan that will address
      recommendations 2.1  and 2.2. The RPM hopes the work assignment will be in place by
      September 2005.
NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP - HIGHEST PRIORITY

None.



NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP - OTHER

None.

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UPDATED COST SUMMARY TABLE
Recommendation
Reason
Implementation
Status
Estimated
Capital Costs
($)
Actual Capital
Costs
($)
Estimated Change
in Annual Costs
($/yr)
Actual Change in
Annual Costs
(S/yr)
Original Optimization Evaluation Recommendations
2 . 1 Prepare a Document that
Clearly States and Illustrates the
Conceptual Model
2.2 Characterize Area Near
NP1-S1 Initially with a Pump
Test (In Place of Planned Packer
Test)
2 . 3 Consider Need for Further
Characterization
4.1 Improve Semi- Annual
Monitoring Reports
4.2 Revise Pumping Strategy at
GKM Well
5 . 1 Consider Options for In-
Situ Remediation Near NP1-S 1
Protectiveness
Protectiveness
Protectiveness
Technical
Improvement
Technical
Improvement
Site Closeout
In progress
In progress
Delayed
(Contingent)
In progress
Implemented
Delayed
(Contingent)
$20,000
$40,000
Not quantified
$5,000
$5,000
$20,000

Not quantified

$0
$0
Not quantified
$2,000
$0
Not quantified

Not quantified

New or Updated Recommendations from Follow-up #1, July 20, 2005
None.

New or Updated Recommendations from Follow-up #2, November 7, 2005*
None.

Costs in parentheses imply cost reductions.
* Although the ROET (including the optimization contractor) was present for follow-up meeting #2, the RPMwas not available and other site team members (e.g., the
hydrogeologist) reported that no additional progress had been made since the previous follow-up meeting. In addition, the site hydrogeologist noted that there was no
need for further technical assistance at this point.

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                          APPENDIX: A




   ARCHIVE OF TECHNICAL ASSISTANCE PROVIDED BY THE ROET






Note: Technical assistance items are provided in reverse chronological order.

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Technical assistance has not been provided by the ROET to date.

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           APPENDIX: B

BASELINE SITE INFORMATION SHEET AND
  OPTIMIZATION EVALUATION REPORT

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           Streamlined
 Optimization Evaluation Report

North Penn Area 1 Superfund Site
           Souderton
Montgomery County, Pennsylvania

           EPA Region III
            August 5, 2005

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          SECTION 1:



BASELINE SITE INFORMATION FORM

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Date:    3/21/05
Filled Out By:     GeoTrans

A. Site Location, Contact Information, and Site Status
1. Site name 2
North Penn Area 1 S
4a. EPA RPM
Maria Garcia (Angie)
4b. EPA RPM Phone Number
215-814-3199
4c. EPA RPM Email Address
garcia.maria@epa.gov
Site Location (city and State) 3. EPA Region
ouderton, Montgomery County, PA 3
5a. State Contact
April Flipse
5b. State Contact Phone Number
484-250-5721
5c. State Contact Email Address
april.flipse@state.pa.us
5. Is the ground water remedy an interim remedy or a final remedy? Interim! | Final IXI
6. Is the site EPA lead or State-lead with Fund money? EPA IXI State I I

B. General Site Information
1 a. Date of Original ROD for Ground Water Remedy
9/30/94 OU2-Interim
2a. DateofO&F
9/24/98
3. What is the primary goal of the P&T system
(select one)?
1 1 Contaminant plume containment
IXI Aquifer restoration
1 1 Containment and restoration
1 I Well-head treatment
lb. Dates of Other Ground Water Decision Documents (e.g., ESD, ROD Amendment)
ESD#1 (10/29/97), ESD #2 (9/24/98)
2b. Date for transfer to State
September 2008
4. Check those classes of contaminants that are
contaminants of concern at the site.
K| VOCs (e.g., TCE, benzene, etc.)
n SVOCs (e.g., PAHs, PCP, etc.)
1 1 metals (e.g., arsenic, chromium, etc.)
1 I other
5. Has NAPL or evidence of NAPL been observed at the site? Yes I I No IXI
6. What is the approximate total pumping rate? 2.2 gpm
7. How many active extraction wells 1
(or trenches) are there?
9. How many samples are collected
from monitoring wells or piezometers „
each year? (e.g., 40 if 10 wells are
sampled quarterly)
11. What above-ground treatment processes are usec
1 I Air stripping
I | Carbon adsorption
1 I Filtration
I | Off-gas treatment
1 I Ion exchange
8. How many monitoring wells are .
regularly sampled?
10. How many process monitoring samples
(e.g., extraction wells, influent, effluent, etc.) .
are collected and analyzed each year? (e.g., 24
if influent and effluent are sampled monthly)
(check all that apply)?
1 I Metals precipitation
I | Biological treatment
O UV/Oxidation
I | Reverse osmosis
IXI Other direct discharge to POTW
12. What is the approximate percentage of system downtime per year? 10% | | 10-20%| | >20% | |

$3,393
$753

$5,100

$9,930
$22,156
Actual Annual Costs
forFY04
$5,489

$1,013
$669

$8,793

$8,524
$24,668
Projected Annual
Costs for FY05

Costs are based on costs for EPA's contractor who is conducting the LTRA.
Direct labor is contractor's personnel costs, excluding sampling labor.
Other costs include: sampling supplies, equipment, shipping of samples, sampling report,
and contractor's indirect costs and fees.
Sampling analysis conducted by EPA's lab.
Costs for FY05 are difficult to predict at this point given the fact that further
investigation will be conducted at the site, and pumping strategy may be modified.

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D. Five-Year Review
1. Date of the Most Recent Five-Year Review      September 26,2003
2. Protectiveness Statement from the Most Recent Five-Year Review

    I  |   Protective                              IXI   Not Protective

    M   Protective in the short-term                	   Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below

The site is considered protective in the short-term, but fluctuating high concentrations at
monitoring well NPA1-S1 should be investigated further before determining the remedy is
protective in the long-term. The 5-year review recommended that such an investigation be
performed to detrmine the source.
E. Other Information
If there is other information about the site that should be provided please indicate that information in the space
below. Please consider enforcement activity, community perception, technical problems to be addressed, and/or
areas where a third-party perspective may be valuable.

The active pumping well produces water with very low concentrations of PCE (several ug/1),
the prime contaminant of concern. In contrast, monitoring well NPA1-S1, located
downgradient of the sole extraction well, has concentrations in the ppm range for PCE.

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            SECTION 2:

STREAMLINED OPTIMIZATION EVALUATION
   FINDINGS AND RECOMMENDATIONS

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   Date of Evaluation Meeting:
 North Penn Area 1 Superfund Site



February 8, 2005        Date of Final Report:
August 5, 2005
ROET MEMBERS CONDUCTING THE STREAMLINED OPTIMIZATION EVALUATION:
Name
Norm Kulujian
Kathy Davies
Peter Rich
Rob Greenwald
Steve Chang
Jean Balent (by phone)
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
U.S.EPAOSRTI
U.S. EPAOSRTI
Phone
215-814-3130
215-814-3315
410-990-4607
732-409-0344

202-564-1709
Email
Kulujian.norni@epa.gov

DavicsJcathvj^toja^gQY
grlch@gcotianginc.coni
rgreeiiwald@geotransinc.com

Chang.steve@epaniail.epa.gov
Balcnt.ican@cpa.pov

SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Maria Garcia (Angie)
Affiliation
U.S. EPA Region 3 (RPM)
Phone
215-814-3199
Email
GarciaMarjajgtoBa.gov

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1.0 SIGNIFICANT FINDINGS BEYOND THOSE REPORTED ON SITE INFORMATION FORM

The evaluation team observed an RPM who appears to be an effective manager. The observations
and recommendations herein are not intended to imply a deficiency in the work of either the
designers or operators, but are offered as constructive suggestions in the best interest of the EPA and
the public. Recommendations made herein obviously have the benefit of site characterization data
and the operational data unavailable to the original designers.

Findings beyond those reported on the site information form include the following:

There are 2 Operable Units - OU1 (soil) and OU2 (ground water). This review pertains to
OU2.

The "site" consists of the following three properties in proximity to each other:
o Gentle Cleaners (former dry cleaner)
o Granite Knitting Mills (GKM), active, operations have included use of PCE
o Parkside Apartments, once included a dry cleaning establishment

The primary ground water contaminant is PCE.

• All of the residences in the area are reportedly on public water. The nearest supply well is
approximately a half-mile away.

Five wells are routinely sampled (semi-annually), including four monitoring wells and the
sole extraction well.
o The extraction well on the GKM property is called GKM well.
o Monitoring well NP1-S1 is also on GKM property, about 200 feet southwest of GKM
extraction well.
o NP1-S2 is a deeper monitoring well, approximately 1,000 feet south of the GKM
extraction well.
o NP1-S3 and NP1-D3 are an even greater distance from the extraction well, near the
Parkside Apartments.

Originally there was to be a second recovery well (S-9), which was a production well for the
North Penn Water Authority located near the Parkside Apartments where contamination was
originally discovered. ESD #1 in 1997 eliminated potential recovery from S-9 because of
low concentrations (< 10 ug/1 PCE), indicated there would be direct discharge to POTW
without onsite treatment, and also changed cleanup levels from background to MCLs. Well
S-9 was eventually abandoned, and monitoring well NPA1-S3 is in the same general area
where S-9 was located. ESD #2 in 1998 made the interim remedy for OU2 the final remedy.

There is no on-site treatment. The extracted water is discharged to the POTW.

The extraction well (GKM well) consistently pumps approximately 2.2 gpm, but only
produces PCE concentrations generally under 10 ug/1. However, nearby monitoring well
NP1-S1 (open hole 15 to 59 feet) has ppm levels of PCE. Other monitoring wells have very
low VOC concentrations for several constituents (several ug/1).

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During the Remedial Investigation there was a packer test at the GKM well testing intervals
to 187 ft bgs, and the upper interval (< 28 ft) had the highest concentration of 330 ug/1 PCE.
The intent was to pump from that interval. However, during the optimization evaluation
meeting, it was noted that the pump is currently set at 53 feet, and the packing off for
remediation pumping was never implemented.

It was noted during the optimization evaluation meeting that the routine monitoring reports
do not include tabulations or figures indicating historical data or trends.

During the optimization evaluation meeting it was reported that the contractor is planning a
packer test at monitoring well NP1-S1, the most impacted well.

During the optimization evaluation meeting, the site hydrogeologist, indicated that
downgradient well NP1-D3 has a long open hole and is artesian. The hydrogeologist is
concerned that sampling this well from near the surface, without packing off the deep
interval, could potentially obscure higher concentrations in deeper intervals of the well.

Water levels do not appear to be routinely evaluated.
2.0 RECOMMENDATIONS TO IMPROVE SYSTEM PROTECTIVENESS

2.1 PREPARE A DOCUMENT THAT CLEARLY STATES AND ILLUSTRATES THE CONCEPTUAL
MODEL

The site conceptual model is not clearly laid out in recent documents such as monitoring
reports or the five-year review. An effort should be made to update the conceptual model to
clearly summarize well construction, geologic cross-sectional information, interpreted flow
patterns (horizontal and vertical), and likely fate and transport of contaminants. This
conceptual model should also attempt to explain the observed concentration differences
between the GKM well and NP1-S1, and including the influence of packering during the
remedial investigation and during the remediation. The influence of precipitation variation
over time on concentrations should also be evaluated. The site hydrogeologist has a history
of hydrogeologic evaluation with this particular bedrock setting and will be a valuable
resource for this exercise. It is estimated that this effort, which does not involve any field
work or data collection, might cost $20,000.

2.2 CHARACTERIZE AREA NEAR NP1-S1 INITIALLY WITH A PUMP TEST (IN PLACE OF
PLANNED PACKER TEST)

It was noted during the optimization evaluation meeting that the contractor was planning a
packer test of NP1-S1. Given that this is a relatively shallow well (open only to 59 feet) the
likely benefits of a packer test are limited. Instead, it is recommended that a pump test be
performed at NP1 -S1 with the goal of determining how much water this well can produce, at
what concentrations, and how those concentrations will sustain over time. If desired, the
pump from the GKM well could potentially be used for this test. Given that discharge is to

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the POTW, which likely has a standard of 2.13 mg/L Total Toxic Organics, and PCE
concentrations higher than 2.13 mg/L have been observed at this well, consideration can be
given to storing this water in a tank and testing the water prior to discharge (with a mobile
lab or a fast turnaround from a fixed-based lab) or treating the water through GAC.

If NP1-S1 does not produce much water, the observed contamination may be very localized.
If it does produce water, and that water can be discharged to the POTW without treatment,
the pumping should continue and concentrations of pumped water should be monitored over
time (perhaps weekly for a month, monthly for a year) to see the trends. If the concentration
declines quickly, there likely is no major contamination problem, and the need for additional
characterization is diminished. However, if high concentrations (perhaps 50 ug/1 or higher
for PCE) are sustained over a year, then additional characterization of the source area and
contamination extent may be appropriate.

Initial pump testing of NP1-S1 (several days) should cost on the order of $25,000. If
pumping then continues at NP1-S1 (likely in place of the GKM well), and discharge directly
to the POTW can continue, then long-term costs should be similar to the existing system,
though there may be higher POTW fees if pumping rate is higher, and there may be added
costs for sampling and evaluating concentration trends over the course of a year. The site
team could assume additional costs of $15,000 might occur over one year of extended
testing, relative to the costs of the current system. Thus, a total of $40,000 of additional cost
is estimated for this activity.
2.3 CONSIDER NEED FOR FURTHER CHARACTERIZATION

Based on the results of Recommendations 2.1 and 2.2, additional characterization may still
be needed. It was noted during the optimization evaluation meeting that, if this site was
currently in the RI phase, more characterization would likely be performed. Since the need
and potential scope for such characterization will depend on the results of Recommendations
2.1 and 2.2, costs are not estimated at this time.
3.0 RECOMMENDATIONS TO REDUCE SYSTEM COST

None.

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4.0 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT

4.1 IMPROVE SEMI-ANNUAL MONITORING REPORTS

These reports should include a more clear statement of the site conceptual model (developed
as part of Recommendation 2.1), and also include historical data so that trends can be
presented and evaluated. This may increase cost of these reports by $4,000 for the first
report, and perhaps $1,000 for each subsequent report (i.e., for semi-annual reporting, $5,000
the first year and $2,000 each subsequent year).

4.2 REVISE PUMPING STRATEGY AT GKM WELL

Based on results of Recommendations 2.1 and 2.2, pumping at the GKM well should either
be eliminated or limited to the top interval (< 40 feet) as originally conceived. The costs of
implementing this, assuming pumping continues at the GKM well, are approximately $5,000.

5.0 RECOMMENDATIONS To SPEED SITE CLOSEOUT

5.1 CONSIDER OPTIONS FOR IN-SITU REMEDIATION NEAR NP1-S1

An alternate approach to P&T may include in-situ chemical oxidation or injection of zero
valent iron at well NP1-S1. This would only be potentially appropriate if the well does
produce sustained water during the recommended pumping test or if high concentrations
requiring treatment prior to discharge continue during long-term pumping. Depending on the
volume of the subsurface to be treated, a relatively small ISCO or ZVI treatment might cost
$200,000 to $500,000 to implement. A focused evaluation of these alternatives might cost
$20,000. A cost-benefit analysis for implementing a full-scale system, versus the cost of
continued P&T (which might include treatment if very high concentrations are sustained
under long-term pumping) should be performed prior to deciding to whether or not to invest
$20,000 to evaluate alternatives.
PRIORITIZATION AND SEQUENCING OF RECOMMENDATIONS

Recommendation 2.1 should be implemented first, followed by 2.2. Recommendation 4.1 should be
implemented with the next semi-annual report. Recommendations 2.3, 4.2, and 5.1 should be
considered based on the results of Recommendations 2.1 and 2.2.
OTHER ACTION ITEMS

None.

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                                        Cost Summary Table
Recommendation
2. 1 Prepare A Document That
Clearly States And Illustrates The
Conceptual Model
2.2 Characterize Area Near NP 1-
Sl Initially With A Pump Test (In
Place Of Planned Packer Test)
2 . 3 Consider Need for Additional
Characterization
4.1 Improve Semi- Annual
Monitoring Reports
4.2 Revise Pumping Strategy at
GKM Well
5 . 1 Consider Options for In-Situ
Remediation Near NP 1 -S 1
Reason
Effectiveness
Effectiveness
Effectiveness
Technical Improvement
Technical Improvement
Site Closeout
Estimated Additional
Capital Costs
($)
$20,000
$40,000
Not quantified
$5,000
$5,000
$20,000
Estimated Change in
Annual Costs
($/yr)
$0
$0
Not quantified
$2,000
$0
Not quantified
Costs in parentheses imply cost reductions.

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