I
 DNAPL Remediation: Selected Projects
Where Regulatory Closure Goals Have
Been Achieved
I
STATUS  UPDATE
Section

1.0 PURPOSE	1
2.0 OVERVIEW	2
3.0 CHALLENGES OF DNAPL
CHARACTERIZATION AND REMEDIATION	8
4.0 OVERVIEW OF DNAPL REMEDIATION
TECHNOLOGIES	9
5.0 DNAPL REMEDIATION PROJECTS	13
6.0 SUMMARY OF FINDINGS	13
REFERENCES	16
NOTICE AND DISCLAIMER	19
Appendix A: DNAPL Remediation
Project Profiles	20
Appendix B: Suspected DNAPL Threshholds
Based on Solubility Relative to One Percent
of Aqueous Solubility	49
Appendix C: Acronyms and Abbreviations	51
1.0 PURPOSE

The purpose of this paper is to highlight
sites where dense nonaqueous phase  liquid
(DNAPL) source reduction has been demon-
strated  as an  aid  in  meeting  regulatory
cleanup goals.1 The presence of DNAPL in
the subsurface can serve as a long-term
source of dissolved contaminant plumes in
groundwater, making  it more difficult to
reach regulatory closure. However, once the

1 A few of the projects documented in this report
are still undergoing verification groundwater-
monitoring to confirm no rebound.
                                DNAPL  source  is  addressed,   residual
                                groundwater plumes may be more amenable
                                to treatment, including less aggressive tech-
                                niques such as monitored natural attenuation
                                (MNA) or bioremediation (U.S.  Environ-
                                mental Protection Agency [EPA] 1999b).

                                This paper updates  the document,  DNAPL
                                Remediation: Selected Projects Approach-
                                ing Regulatory  Closure, prepared  in 2004
                                (EPA 2004a) by providing more recent in-
                                formation on technologies and on five addi-
                                tional selected sites at which DNAPL source
                                reduction technologies were applied.

                                The sites were identified by reviewing pro-
                                ject summaries  found on various state and
                                federal  Web  sites and selecting those that
                                met the criteria for inclusion.  The sources
                                also included published and  nonpublished
                                reports, commercial websites,  and  inter-
                                views with regulatory staff. The review was
                                not statistically based, and the sites are pre-
                                sented for illustrative purposes only.

                                Ten of the 13 sites summarized in Table 1
                                and fully profiled in Appendix A have
                                reached regulatory closure (i.e., a no further
                                action [NFA] determination has been made).
                                NFA is defined in this document as (1) no
                                further active intervention will be required,
                                (2) there is currently no active remedial ac-
                                tivity taking place, and (3) the site is suffi-
                                ciently clean that long term monitoring is
                                not required or will not be required after
                                some specified time. At two sites (the confi-
                                dential chemical manufacturing plant in
                                Portland, Indiana, and the Avery Dennison
                                site in Waukgan, Illinois) the remediation
United States
Environmental Protection
Agency
                       Solid Waste and
                       Emergency Response
                       (5203 P)
                                                    EPA 542/R-09/008
                                                        August 2009
                                                      www.CLUIN.org

-------
was aimed at soil and they have met cleanup
goals and institutional controls are in place
to prevent use of groundwater. The King's
Bay site is in a MNA mode with MCLs be-
ing met at the property line. Since the site is
naturally anaerobic, it is anticipated that
monitoring will end soon. Most of the sites
were addressed under state cleanup pro-
grams, but four were addressed under Super-
fund (31%),  and one was addressed as a
state led RCRA corrective action (8%).

The  sites profiled illustrate  that addressing
DNAPL  source areas  can lead to regulatory
closure and, as is the  case in six sites, unre-
stricted use.  As discussed in Section 3.0, the
benefits  of  DNAPL  source  reduction,  and
especially partial source removal, are  still
being debated. Although this paper does not
attempt to resolve this issue, it does provide
information  that illustrates instances where
source reduction has contributed to a  site
meeting  cleanup goals (groundwater maxi-
mum  contaminant  limits   [MCLs]  were
achieved at  five sites). This paper helps, in
part,  to   satisfy the  recommendation  of
EPA's Ground Water Task Force to better
assess  and  document results achieved by
DNAPL  source  reduction. The information
provided is  also part  of a national effort to
better  understand current technology capa-
bilities and to illustrate the use of different
cleanup criteria.

This paper is targeted toward project man-
agers,  federal and state regulatory staff,  site
owners, consultants, and technology provid-
ers with a basic understanding of site reme-
diation approaches  and terminology. Refer-
ences and available Web links are cited for
those seeking further information about spe-
cific remedial technologies in the Reference
section (page 16).

2.0 OVERVIEW

The  presence  of  DNAPLs  in soil   and
groundwater presents unique  challenges to
site remediation. DNAPLs have  a  specific
gravity greater than water, a relatively low
solubility, and a tendency  to  diffuse into
fine-grained materials in an aquifer. These
properties make DNAPL masses and residu-
als difficult to locate and characterize in the
subsurface, and they can prolong the process
of conventional remedial technologies, such
as groundwater pump-and-treat (P&T).

Due to their specific gravity, DNAPLs tend
to sink  in the subsurface. Their migration
pathways tend to be  complex  and hard to
predict due to the heterogeneous nature of
the underlying soil and  fractured bedrock.
As a result, a complicated DNAPL architec-
ture  (shape  and size) can develop that is
made up of pools, ganglia, and globules in
multiple  soil  layers  and bedrock  fracture
zones. And because of their low  solubility,
tendency to displace water from larger soil
pores, and tendency to diffuse  into silt and
clay, DNAPLs can release dissolved con-
stituents  for long periods of time forming
large groundwater plumes.  Constituents in
the migrating plume can diffuse into aquifer
materials  under  certain conditions  only to
back diffuse out at a later time.

DNAPLs  often  are  present at electronics
manufacturers, metal  plating facilities, dry-
cleaners, solvent recyclers,  and other sites
that  have used  chlorinated solvents.  They
also  are  found at wood treatment facilities
that  used creosote and at former manufac-
tured gas plants  (MGPs) that produced coal
tar  wastes.  Chlorinated  solvents, such  as
tetrachloroethene (PCE) and trichloroethene
(TCE), are the most  common  types of or-
ganic soil and groundwater contaminants at
Superfund and other hazardous waste sites.

Site  owners will  likely spend billions of dol-
lars  over the  next several decades cleaning
up DNAPL-impacted sites (EPA 2000).

The  following sections present  some of the
challenges to characterizing and remediating
sites with DNAPL contamination and sum-
marize the many technologies that have been

-------
used to treat the DNAPL source zone. The
13 examples of sites that have successfully
addressed the source zone to meet regulatory
requirements are also summarized, including
information  about the extent of contamina-
tion, the cleanup goals, and  the  treatment
approach. These sites are further detailed in
the profiles  contained in Appendix A. For
quick reference to these sites, see Table 1.
For more information:  The DNAPL focus
area on EPA's CLU-IN  website further ex-
plains their chemistry and behavior as well
as characterization  and  remediation  ap-
proaches:
http: //www .cluin. org/contaminantfocus/defa
ult.focus/sec/Dense_Nonaqueous_Phase_Li
quids  (DNAPLsVcat/Overview/

-------
Table 1. Summary of Selected DNAPL Remediation Projects
    (A List of Acronyms is Found at the End of the Table)
Site Name, Location
Technology, Period
of Operation
Media, Quan-
tity Treated
Project Goals, Program
(mg/kg= soil or sediment
u,g/L= groundwater)
Contaminant Concentrations
(Before Treatment)
(mg/kg= soil or sediment
u,g/L= groundwater)
Contaminant Concentra-
tions (After Treatment)
(mg/kg= soil or sediment
u,g/L= groundwater)
Project Status,
Comments
IN SITU THERMAL TREATMENT PROJECTS
Confidential Chemi-
cal Manufacturing
Facility, Portland, IN
Avery Dennison Site,
Waukegan, IL
Camelot Cleaners,
West Fargo, ND
(Superfund Removal
Program)
Former MGP Gas-
holder, North Adams,
MA
Former Wood Treat-
ment Area, Alham-
bra, CA
In situ conductive
heating (145
heater/vacuum
wells) 7/97 to 12/97
ERH (95 electrodes/
34 recovery wells)
12/99 to 11/00
ERH (56 multi-zone
electrode vents,
array of horizontal
vapor extraction
wells, and dual vac-
uum extraction
wells) 2/05 to 1/06
In situ conductive
heating (25 thermal
wells on 12-ft cen-
ters) 8/03 to 6/05
ISTD (131 heater-
vacuum wells and
654 heater-only
wells 6/03 to 9/05
(actual heating)
Soil, one area
7,500 ft2 by 18
ft deep and a
second area
600 ft2
by 1 1 ft deep
Saturated and
unsaturated
soil, 16,000yd3
Cleanup foot-
print was
10,300 ft2 and
up to 56 ft
deep, GW oc-
curs 3-5 ft bgs
and tends to be
perched
About 2,000
yd3 of soil,
debris, and coal
tar. Depth of 18
ft bgs.
Soil -16,500
yd3
(Average depth
20 ft bgs;
maximum
PCE - 8 mg/kg, TCE - 25
mg/kg, U-DCE-0.08
mg/kg (IDEM Tier II,
Industrial Land Use),
State Voluntary Cleanup
Program
MC - 24 mg/kg (IEPA
TACO), State Voluntary
Cleanup Program
Reduce VOC levels to
less than 3 mg/kg in soil
and 1 mg/L in GW, EPA
Superfund Removal Pro-
gram
Cleanup goals were to
reduce B(a)P levels to 300
mg/kg, naphthalene to
10,000 mg/kg and TPH to
10,000 mg/kg, MADEP
Total PAHs - 0.065
mg/kg (B(a)P-eq), PCP -
2.5 mg/kg, dioxins -
0.001 mg/kg expressed as
2,3,7,8-TCDD TEQ
PCE - 3,500 mg/kg, TCE - 79
mg/kg, 1,1-DCE - 0.65 mg/kg,
Suspected DNAPL
MC - 50,000 mg/kg (maximum
in soil), MC - 1,900 mg/kg (av-
erage in soil), Suspected
DNAPL
Maximum PCE concentrations
detected in soil 2,200 mg/kg and
in water 89 mg/L, Suspected
DNAPL
Maximum detected B(a)P 650
mg/kg, naphthalene 14,000
mg/kg, and TPH 230,000 mg/kg,
Observed DNAPL
Maximum concentrations: Total
PAHs - 35,000 mg/kg, PCP - 58
mg/kg, dioxins - 0.184 mg/kg as
2,3,7,-TCDD, Suspected
DNAPL
PCE -0.53 mg/kg, TCE -
0.02 mg/kg (average in soil)
1,1-DCE -not available
MC - 2.51 mg/kg (average in
soil)
One small area above 3
mg/kg; the rest were below.
All GW samples total VOCs
under 1 mg/L
16,000 gallons of coal tar
recovered; final concentration
averages were B(a)P 0.33
mg/kg, naphthalene 5.7
mg/kg, and TPH 43. 15 mg/kg
All contaminant concentra-
tions were below project
goals.
IDEM NFA letter
(Date not provided)
IEPA NFR letter
(4/01) required
institutional con-
trols
Unconditional no
further action, ex-
traction and moni-
toring wells were
removed
Site owner filed for
an Activity and Use
Limitation to the
MADEP due to
other unrelated site
problems
Certificate of com-
pletion issued
2/08/07

-------
Site Name, Location

Southern California
Edison Company
Visalia Pole Yard,
Visalia, CA
(Super-fund NPL)
Technology, Period
of Operation

ISTD(11 injection
and 8 extraction
wells) 5/97 to 6/00
Media, Quan-
tity Treated
depth greater
than 100 ft bgs
Soil and
groundwater
(Maximum
depth 145 ft
bgs)
Project Goals, Program
(mg/kg= soil or sediment
u,g/L= groundwater)
California Expedited Re-
medial Action Program
Pentachlorophenol 17
mg/kg and 1 ug/L ;
Benzo(a)pyrene 0.39
mg/kg and 0.2 ug/L ; and
TCDD equivalent 0.001
mg/kg and 30 pg/L
Superfund NPL with state
lead
Contaminant Concentrations
(Before Treatment)
(mg/kg= soil or sediment
u,g/L= groundwater)

DNAPL (Creosote) and LNAPL
(diesel with pentachlorophenol)
pools present
Contaminant Concentra-
tions (After Treatment)
(mg/kg= soil or sediment
u,g/L= groundwater)

All contaminant concentra-
tions were below project
goals.
Project Status,
Comments

Final Remediation
Action Completion
Report approved by
state 12/4/08
1C in place com-
mercial and/or in-
dustrial redevelop-
ment only
Ex Situ Thermal
Southern Maryland
Wood Treating Hol-
lywood, MD
(SuperfundNPL)
Excavation and ex
situ thermal desorp-
tion, P&T
Soil, sediment
270,000 tons of
soil
Surface soil: Total PAHs
-0.1 mg/kg B(a)P-eq
Subsurface soil: Total
PAHs -1.0 mg/kg B(a)P-
eq
Sediment: PCP - 0.4
mg/kg PCP, low molecu-
lar wt. PAHs - 3.2 mg/kg,
high molecular wt. PAHs
- 9.6 mg/kg
EPA Superfund NPL
Maximum concentration of
PAHs in surface soil and sedi-
ment 4,120 mg/kg and 41 ug/kg,
respectively, Observed DNAPL
All cleanup goals were met.
Ready for Reuse
determination is-
sued by EPA on
11/18/04. Unre-
stricted use of site
ISCO PROJECTS
Former Southern
California Edison
MGP Site, Long
Beach, CA
Former Cowboy
Cleaners Site,
Broomfield, CO
In situ ozonation
and excavation 1998
to 2001
Potassium perman-
ganate 9/01 to 8/02
Soil and GW,
340 ft by 230 ft
Soil and GW,
65,340 ft2 (1.5
acre) plume
B(a)P-eq- 1.75 mg/kg
(Site-specific risk-based
cleanup level), California
DTSC
Project goals not identi-
fied; State Voluntary
Cleanup Program
Total PAH - 2,484 mg/kg >100
mg/kg B(a)P-eq (maximum in
soil), Suspected DNAPL
PCE - 1,900 ug/L (maximum in
GW), Suspected DNAPL
B(a)P-eq - 1 .4 mg/kg (aver-
age in soil), PAH concentra-
tions in GW reduced to ND
PCE - 48 ug/L (source area)
California DTSC
will issue a Certifi-
cate of Completion
once deed restric-
tions are recorded
NFA letter issued
by State of Colo-
rado (2/03) requires
commercial use

-------
Site Name, Location
Dry Clean USA
#11502, Orlando, FL
Naval Submarine
Base Kings Bay, Site
1 1 , Camden County,
GA
Former Sta-Lube Site
Rancho Dominguez,
CA
Technology, Period
of Operation
SVE: 4/99 to 12/00,
P&T: 4/99 to 1/01
and 2/01 to 11/02,
Hydrogen peroxide:
10/05
P&T: 1993 to 1999
Fenton's reagent:
6/99 to 11/01
Biostimulation,
MNA: ongoing
P&T: 1997-2003
SVE: 2000-2001
Excavation: 2003
Catalyzed hydrogen
peroxide and so-
dium persulfate:
06/05 to 06/08
Media, Quan-
tity Treated
Full-scale
deepest con-
tamination was
68 ft bgs,
plume was 800
ft long and 300
ft wide
GW plume
estimated to be
700 ft by 200 ft
and 30 to 40 ft
deep
Soil and GW,
GW plume
estimated at
200 ft by 80 ft
Project Goals, Program
(mg/kg= soil or sediment
u,g/L= groundwater)
Meet contaminant target
cleanup goals: 3 ug/L
PCE, 30 ug/kg PCE, 30
Hg/kg TCE, 400 ng/kg
cis-DCE, 700 ug/kg trans
DCE, and 7 ug/kg vinyl
chloride, State Drycleaner
Program
Georgia DNR MCLs,
RCRA Corrective Action
50 ug/L MC, California
RWQCB Los Angeles
Region
Contaminant Concentrations
(Before Treatment)
(mg/kg= soil or sediment
u,g/L= groundwater)
PCE - 27,300 ug/L in GW and
3.9 mg/kg detected in soil, Sus-
pected DNAPL
Total chlorinated hydrocarbons -
nearly 200,000 ng/L, Suspected
DNAPL
MC - as high as 2,600,000 ng/L,
Suspected DNAPL
Contaminant Concentra-
tions (After Treatment)
(mg/kg= soil or sediment
u,g/L= groundwater)
10/05 to 10/06 PCE ranged
between 1 .7 and 3 ug/L
Total chlorinated hydrocar-
bons^ 1 to 13.9 ng/L
MC - <50 ug/L
Project Status,
Comments
State Rehabilitation
Order (NFA) issued
2/16/07
Awaiting status of
monitoring and
MNA
Final closure
granted 06/08
OTHER
Pasley Solvents and
Chemicals, Inc.,
Hempstead, NY
(Superfund NPL)
SVE/AS 11/97 to
10/02
Surface soil and
subsurface soil,
and GW, Site is
about 75-ft
wide by 275-ft
long with a 60-
ft wide and
400-ft long
contaminant
plume
Clean up site to residential
risk levels and contami-
nant MCLs, EPA Super-
fund NPL
Maximum detected concentra-
tions were:
Surface soil: total VOCs - 603
mg/kg, total SVOCs - 204
mg/kg
Groundwater: Total VOCs - 37
mg/L, TCE - 320 ug/L, Sus-
pected DNAPL
All contaminants of concern
under 1 mg/kg in soil and GW
concentrations ranged from
NO to 4 ug/L
2006 NFA with
discontinuing of
GW monitoring
activity, No institu-
tional control re-
strictions
Source: Project profiles in Appendix A

-------
Notes:
ug/L     micrograms per liter                            ISTD
bgs      below ground surface                           MADEP
B(a)P    benzo(a)pyrene
B(a)P-eq benzo(a)pyrene equivalent                      MC
DCE     dichloroethene                                 MCL
DNAPL  dense non-aqueous phase liquid                  nig/kg
DTSC    Department of Toxic Substances Control          nig/L
EPA     U.S. Environmental Protection Agency            MGP
ERH     electrical resistive heating                       MNA
ft        foot or feet                                    ND
ft2       square foot or feet                              NFA
ft        cubic foot or feet                              NFR
GW     groundwater                                  NPL
HRC®    Hydrogen Release Compound                   P&T
1C       institutional controls                            PAH
IDEM    Indiana Department of Environmental            PCE
         Management                                  REEL
IEPA    Illinois Environmental Protection Agency         RCRA
in situ thermal desorption                        SCE
Massachusetts Department of Environ-             S VE
mental Protection                               SVOC
methylene chloride                              TACO
maximum contaminant level (EPA)
milligrams per kilogram                         TCA
milligrams per liter                              TCDD
manufactured gas plant                          TCE
monitored natural attenuation                    TCEQ
non-detectable
no further action                                TPH
no further remediation                           TRRP
National Priorities List                          VC
pump and treat                                 VOC
polycyclic aromatic hydrocarbon                  yd3
tetrachloroethene
risk-based exposure level
Resource Conservation and Recovery Act
Southern California Edison
soil vapor extraction
semivolatile organic compound
tiered approach to correction action
objectives
trichloroethane
2,3,7,8 tetrachlorodibenzodioxin
trichloroethene
Texas Commission on Environmental
Quality
total petroleum hydrocarbons
Texas Risk Reduction Program
vinyl chloride
volatile organic compound
cubic yard

-------
3.0 CHALLENGES OF DNAPL CHAR-
    ACTERIZATION AND REMEDIA-
    TION

As noted above, the physical and chemical
properties of DNAPLs hinder their charac-
terization and remediation. This section fur-
ther explains some of the challenges.2

Locating and Verifying the Presence
of DNAPLs

DNAPLs tend to migrate  along the path  of
least resistance in the subsurface. Because  of
difficulties  characterizing a heterogeneous
subsurface, DNAPL source zones are often
difficult to locate, and their size and spatial
distribution difficult to  define. Techniques
that can be effective in locating and charac-
terizing DNAPLs include membrane  inter-
face probes, ribbon NAPL  samplers (e.g.,
the  FLUTe™ membrane  system),  partition
interwell tracer testing,  and  direct push va-
dose zone and groundwater profiling. In ad-
dition, cone penetrometers can be equipped
with fluorescence detection systems to help
locate  creosote  and coal tar; Raman spec-
troscopy  to  identify  contaminants  and
DNAPL in situ; or GeoVIS to help visually
identify NAPL through downhole video im-
aging.

It is usually difficult to verify the presence
of DNAPLs through direct observation, even
with downhole  video  imaging. However,
dyes that change color when they encounter
a DNAPL mass or partition into them (e.g.,
Sudan  IV) have been used to  help identify
the presence of clear DNAPLs. Dyes can be
used during  continuous soil coring with a
direct push rig in order to pinpoint DNAPL
masses. The  FLUTe™ system, which in-
volves deploying a fabric dye-treated tube
down a borehole, may be  used, both in soil
  Mention of trade names or commercial prod-
ucts in this report does not constitute endorse-
ment or recommendation for use.
and bedrock, to provide information on the
presence and location of the DNAPL.

The  presence of a DNAPL can sometimes
be inferred based on groundwater concentra-
tion  data and the "1% of solubility" rule of
thumb (EPA 1992). Under this approach,
DNAPL is suspected to be present when the
concentration of a chemical in groundwater
is greater than 1% of its pure-phase solubil-
ity. For example, when the dissolved phase
of PCE is greater than 1,500 micrograms per
liter (|ig/L)—which is 1% of its pure-phase
solubility of 150,000 (ig/L-PCE is  inferred
to be present as a DNAPL. This is a  very
conservative estimate since many DNAPL
residual architectures produce plumes  with
thin, highly  concentrated cores that can be
diluted by  conventional  monitoring  well
construction and sampling techniques. Ap-
pendix B lists the values of  1% solubility
concentrations for several DNAPLs. Note
that  for chemical mixtures the solubility of
an individual chemical may be lower than its
pure phase solubility.

For more information: The Interstate Tech-
nology and  Regulatory  Council's  (ITRC)
report, Technology Overview: An Introduc-
tion  to Characterizing Sites Contaminated
with  DNAPLs  (ITRC  2003a), discusses
characterization approaches, data collection
techniques,  and  investigation methods for
sites  contaminated  with DNAPLs.  EPA's
report, Site  Characterization  Technologies
for DNAPL  Investigations (EPA  2004b),
describes geophysical and non-geophysical
technologies  that  are  useful in  locating,
quantifying,  and verifying the presence of
DNAPLs.

DNAPL as  a Continuing Contaminant
Source and Dissolved Plume Man-
agement

Because DNAPLs slowly dissolve as they
migrate and diffuse into silt and clay, they
can act as continuing sources of groundwa-
ter contamination. The combination of
DNAPL migration and slow dissolution into
groundwater, make DNAPLs difficult to

-------
eliminate using pump and treat extraction
technologies. Although P&T and other
methods may contain and recover or treat
the dissolved fraction of the contaminant
mass, this fraction can be very small com-
pared to the amount of DNAPL sorbed to
soil or pooled in the source area. It can take
many years or decades for the majority of
the contamination to be recovered by con-
ventional means; thus, cleanup goals can be
difficult to attain when even small amounts
of DNAPL are present at a site.

Debate Over Effectiveness of Partial
Source Removal

DNAPL source zones are hard to locate and
verify; thus, DNAPL source  reduction may
achieve only a partial removal of the source
mass. There is an ongoing debate within the
remediation  community regarding the utility
of  partial  source  removal  or  reduction,
where some, but not all, of  the DNAPL
source is removed or destroyed. Recent re-
ports  have emphasized the need for histori-
cal performance data to  better predict the
effectiveness of DNAPL remediation ef-
forts.   For example,  EPA convened an ex-
pert panel to examine four issues regarding
DNAPL  source  zone  management   and
treatment. In its  report, The DNAPL Reme-
diation Challenge:  Is There  a Case for
Source Depletion? (EPA, 2003), the expert
panel concluded  that partial mass depletion
from  DNAPL  source zones has been  a vi-
able strategy at certain sites and is likely to
provide benefits  at a number of other  sites.
However, barriers to more widespread use
of DNAPL source-zone technologies persist.
Additional theoretical analysis and assess-
ment tools, improved monitoring techniques
(site characterization; performance assess-
ment), and  field-scale  demonstrations  that
elucidate  benefits of partial source depletion
are needed to provide a more informed  basis
for decision-making  on whether to under-
take DNAPL source-zone depletion at both
sites with a containment  remedy in place
and at new DNAPL sites.
Variation in Cleanup Levels and Clo-
sure Criteria

Cleanup  levels and closure criteria vary at
sites contaminated with DNAPL. These cri-
teria  include a wide range of quantitative
goals as well as goals that specify qualitative
objectives. Examples of remedial action ob-
jectives  established  as  qualitative criteria
include: "Clean up groundwater to the extent
practicable  for the source area;" "Clean up
the source  area to the extent practicable;"
and "Remove the source  area, then conduct
monitored natural attenuation."

Some  state  agencies, such as the Illinois
EPA  (IEPA),  follow a tiered approach to
developing remediation objectives for con-
taminated  soil  and groundwater. lEPA's
remediation objectives  emphasize the pro-
tection of human health,  but  also take into
account site-specific conditions and land use
to provide flexibility to site owners and op-
erators in developing site-specific remedia-
tion  objectives. Each successive tier of the
three-tiered approach is more  involved than
the previous tier, with Tier III conducted at
sites where remediation possibilities are lim-
ited  due  to physical barriers or at complex
sites requiring full-scale risk assessments or
alternative modeling.

4.0 OVERVIEW OF DNAPL REMEDIA-
    TION TECHNOLOGIES

In situ technologies being used to remediate
DNAPL sources include:

•  In situ thermal technologies,

•  In situ chemical oxidation,

•  Surfactant/co-solvent flushing,

•  In situ bioremediation, and

•  Zero valent iron.

Other technologies that have  been used to
treat DNAPL  sources include  direct pump-
ing of DNAPL, dual-phase extraction, exca-
vation,   soil   vapor  extraction (SVE)/air
sparging,  containment   (e.g.,   engineered

-------
slurry walls and permeable reactive zones),
and stabilization/solidification. P&T may be
successful in treating small residual DNAPL
source zones in very permeable soil, but is
not generally cost-effective for treating lar-
ger pools of DNAPL,  or large or hard-to-
reach areas of residual DNAPL contamina-
tion  because of the long time frames  in-
volved.

In general,  successful source remediation
depends largely on the location and architec-
ture of the DNAPL.  For example, large deep
pools of DNAPL or discharges of DNAPL
to bedrock are especially difficult to address
due  to  limited  accessibility to  treatment.
However, small,  shallow areas of residual
DNAPL  are relatively easy to remediate by
excavation,  SVE, or  even—as  mentioned
above—P&T. The time to reach an NFA de-
cision can be greatly reduced if the source
area and associated  highly contaminated
pore water are treated  directly, rather than
addressing the dissolved plume only. While
there may be some dispute over the value of
treating a complex source zone, especially if
the  goal  is to reach maximum contaminant
levels (MCLs), there is general  agreement
that targeting  the source zone usually can
help clean up a site  in a shorter time frame.
Cleanups of the some of the sites profiled in
this report, for example, the Dry Clean USA,
Former Southern California  Edison MGP,
Pasley Solvents  and Chemicals sites,  were
able to achieve MCLs  onsite. Others, such
as the Former Cowboy Cleaners  and Naval
Submarine Base  Kings Bay  Site 11, ob-
tained MCLs at a point of compliance.

This section provides  an overview of se-
lected technologies  that have been used to
treat DNAPL sources, including  the use of
combined remedies. The  project  profiles in
Appendix A illustrate the use of several of
these  technologies to achieve site cleanup
goals.3
For  more  information:  More  information
about in situ treatment is available in In Situ
Treatment  Technologies for  Contaminated
Soil  (EPA  2006) and the FRTR's compila-
tion  of remediation technology assessment
reports
(http://www.frtr.gov/multisitereports.htm).
Also, the  DNAPL focus  area  on EPA's
CLU-IN   website  contains   information.
http: //www .cluin. org/contaminantfocus/defa
ult.focus/sec/Dense Nonaqueous Phase Li
quids (DNAPLsVcat/Treatment Technologi
es/

In  situ  thermal  treatment  technologies
employ heat in the source zone to volatilize
or sometimes  decrease  the  viscosity of
DNAPLs to increase their  mobility toward
vapor and groundwater extraction wells. In
some applications, such as  methylene  chlo-
ride contamination, high temperature condi-
tions may destroy DNAPLs through pyroly-
sis or enhanced  hydrolysis;  however, the
emphasis of thermal remediation is to re-
cover the contaminants from the subsurface
for subsequent destruction , not to try to de-
story them in place.

Various thermal  approaches  can be  used,
including:

•  Injection  of steam (also referred to as
   "steam-enhanced extraction"), or hot wa-
   ter to heat the source area.

•  Three-phase and six-phase electrical resis-
   tive heating (ERH),  which applies an
   electrical current via electrodes to heat the
   source area.

•  Thermal conduction (also referred to as
   "in situ thermal desorption"), which  sup-
   plies heat to the soil through steel wells in
   the case  of deep contamination or with a
   blanket that covers the ground surface in
   the case of shallow contamination.
  Mention of trade names or commercial prod-
ucts in this  report does not constitute endorse-
ment or recommendation for use.
For  more  information:  In  situ thermal
treatment technologies are described in more
detail in In Situ Thermal Treatment ofChlo-
                                           10

-------
rinated Solvents: Fundamentals and Field
Applications (EPA 2004c).

In  situ chemical oxidation (ISCO) tech-
nologies typically inject chemical oxidants
and some times other amendments directly
into the source area where they react with
the contaminants at the dissolved-phase/
liquid-phase  interface.  This  reaction  de-
stroys the dissolved-phase DNAPL constitu-
ents and  speeds  up the dissolution of the
DNAPL at the water/NAPL interface by
keeping the concentration of the dissolved
phase  below the DNAPL  solubility limit.
Although  injection  of oxidants is  the most
common  delivery method, certain circum-
stances such as  subsurface  heterogeneity,
deep contamination, or low hydraulic gradi-
ent may require other  methods to enhance
the delivery of oxidants to the contaminant.
These  methods include recirculation, deep
soil mixing, or  soil  fracturing. Oxidants that
are delivered in the dissolved phase to the
contaminant will  not attack the DNAPL di-
rectly.

Four of the more common chemical oxidants
used for DNAPL treatment are sodium and
potassium permanganate, hydrogen peroxide
(when  used with iron catalysts, this is gener-
ally referred to  as Fenton's chemistry  or
Fenton's reagent), ozone, and persulfate (ac-
tivated with either iron, hydroxide, or heat).
The oxidants react with the dissolved-phase
contaminant, breaking  chemical bonds and
yielding degradation products, such as car-
bon dioxide,  water, and chloride ion, when
the DNAPL is chlorinated.

Surfactant-enhanced ISCO (S-ISCO™) uses
a  proprietary nonionic surfactant  to  help
solubilize  DNAPL thus enhancing  oxida-
tion.

For more information: ISCO is described
in greater detail  in Engineering Issue:  In
Situ Chemical  Oxidation (EPA 2006) and
Technical and Regulatory Guidance for In
Situ Chemical  Oxidation of Contaminated
Soil and Groundwater  (ITRC 2001). In ad-
dition,  the Environmental Security Technol-
ogy Certification Program and Strategic En-
vironmental Research & Development Pro-
gram are  funding  a number of bench- and
field-scale studies  related to ISCO, as well
as  funding development of a technology
practices manual.  Summaries of these pro-
jects  can  be  found  at http://www.serdp-
estcp.org/ISCO.cfm.

Surfactant and co-solvent flushing tech-
nologies enhance DNAPL removal through
injection   and   subsequent  extraction   of
chemicals  to   solubilize  and/or  mobilize
DNAPL constituents.  Typically, the chemi-
cals used are aqueous surfactant solutions,
which may include electrolytes that aid  in
contaminant  solubilization  or co-solvents
(including alcohols, such as ethanol or iso-
propanol) that lower the interfacial tension.
The chemicals are injected into a system  of
wells designed to flood the  DNAPL zone
within the aquifer.  The chemical "flood" and
the solubilized  or mobilized  DNAPL are
extracted from the subsurface and separated
and treated above ground. S-ISCO™ com-
bines elements  of flushing technology with
ISCO. As noted above, S-ISCO™ may en-
hance chemical  oxidation through use of a
proprietary surfactant, which helps solubi-
lize the DNAPL.

Surfactant/co-solvent flushing technology is
described in greater detail in Technical and
Regulatory  Guidance for  Surfactant/Co-
Solvent Flushing of DNAPL  Source Zones
(ITRC 2003b).

In  situ bioremediation  technologies engi-
neer  subsurface conditions to enhance the
biological  activity of subsurface  microbial
populations. Typically, electron donor sub-
strates, such as lactate or molasses, are in-
troduced into the subsurface using injection-
only  or recirculation  configurations.  The
substrates  provide a  carbon  source  which
creates anaerobic  conditions  that  stimulate
native microbes to degrade chlorinated con-
taminants through the  process of reductive
dechlorination. Advances are being made  in
designing  longer-lived   substrates   (e.g.,
emulsified vegetable oil) that may be more
                                           11

-------
effective  in  higher-concentration  source
zones.  Where sufficient populations of the
necessary   bacteria   are  lacking,   non-
indigenous microbes  can be introduced into
the subsurface (referred to as "bioaugmenta-
tion").

Although more commonly applied to dis-
solved-phase plumes, in situ bioremediation
has been used at sites to treat  DNAPL
sources.

For more information:  In situ bioremedia-
tion is described  in greater detail  in Engi-
neered Approaches to In Situ Bioremedia-
tion of Chlorinated Solvents: Fundamentals
and  Field Applications  (EPA  2000)  and
Overview of In Situ Bioremediation of Chlo-
rinated Ethene DNAPL Source Zones (ITRC
2005).  Additional  detail  on design, opera-
tion, and performance monitoring is con-
tained in In Situ Bioremediation of Chlorin-
ated Ethene  DNAPL Source  Zones (ITRC
2008).

Zero valent iron technologies deliver nano
or micro scale ZVI suspended in a carrier
fluid or as a powder into the  subsurface so
they can make contact with the contaminant
of concern. Fluids are usually injected, while
powders are mixed in the soil by augering or
by direct placement  in a trench below the
water table. Pneumatic and hydraulic frac-
turing is sometimes used to improve deliv-
ery and distribution of suspended ZVI. In-
troduction of ZVI into the subsurface pro-
motes the chemical reduction of many chlo-
rinated solvents. Use  of ZVI to reduce chlo-
rinated solvents has been studied in perme-
able reactive zones that  treat the dissolved-
phase contaminants present in the ground-
water plume. An innovative variant of ZVI
technology developed by the National Aero-
nautics and Space Administration emulsifies
the ZVI in vegetable oil.  The vegetable oil is
miscible with the  DNAPL source and at-
tacks it directly while forming a coating that
prevents it from dissolving without first go-
ing through the oil with its reactant iron.
For  more  information:  More  information
on the use  of ZVI to treat source zones can
be found  on  the DNAPL  focus  area of
EPA's CLU-IN website  at http://www.clu-
in.org/contaminantfocus/default.focus/sec/D
ense_Nonaqueous_Phase_Liquids_(DNAPL
s)/cat/Treatment  Technologies/p/6.  A  fact
sheet on nanotechnology  is also available at
htto://www.clu-in.org/542f08009.

A combined remedy is a combination of
treatment technologies used  simultaneously
or in sequence (also known as a "treatment
train").  There is increasing  evidence  that
combined remedies can be useful in cleaning
up a site in a much shorter time frame than
traditional  methods  alone.  For  example,
SVE plus thermal remediation is more effec-
tive  in low-permeability formations than
SVE alone  and may eliminate back diffusion
rebound that is  often associated with the
remediation of contaminated silts and clays.

A combined remedy approach is also useful
for sites with operating cleanup systems be-
cause one part of the approach is to continu-
ally  evaluate if an existing  system is  still
suited to the site conditions and whether a
more efficient system is available.  System
optimization   and  continuous  evaluation
should be an integral part of any operation
and maintenance program.

For  more  information: A  discussion of
combined remedies can  be found in Guid-
ance  for  Optimizing Remedy  Evaluation,
Selection, and Design (NAVFAC 2004).
  EPA is interested in identifying additional
  sites where DNAPLs are present, a reme-
  dial technology has been used, and the site
  has since reached regulatory closure or is
  approaching closure. Please contact Linda
  Fiedler at EPA's Office of Superfund Re-
  mediation and Technology Innovation to
  discuss further, at (703)-603-7194, or e-
  mail fiedler.linda@epa.gov.
                                           12

-------
5.0 DNAPL REMEDIATION
    PROJECTS

Thirteen  remediation  projects  illustrating
how treatment of the DNAPL source zone
expedited attainment  of cleanup goals are
profiled in this report. DNAPL was reported
to have been observed at 3 sites and sus-
pected at 10  sites, based on  elevated con-
taminant  concentrations in groundwater.  At
each site:

• A destruction or removal technology was
  used to address the DNAPL source zone;
  and

• Regulatory closure  was reached with  no
  long-term monitoring required; or regula-
  tory goals have been met, but groundwa-
  ter monitoring is still ongoing with the  in-
  tention that it will not be long term (i.e.,
  rebound has not occurred but the regula-
  tors  want to  be sure before abandoning
  the monitoring wells).
For  quick  reference,  Table  1 summarizes
information about  the  remediation projects
profiled in Appendix A. These projects are
not necessarily representative of the range of
DNAPL  sites and the treatment projects be-
ing performed today.

In addition to the  project profiles, the fol-
lowing sources provide further information
about  specific DNAPL-contaminated sites
where aggressive in situ treatment technolo-
gies have been used:

• In Situ Bioremediation of Chlorinated
  Ethene DNAPL Source Zones: Case Stud-
  ies. ITRC. April 2007.
  (http://www.itrcweb.org/Documents/bioD
  NPL Docs/BioDNAPL-2.pdf)

• In Situ Treatment of Groundwater Con-
  taminated with NAPL Contamination:
  Fundamentals and Case Studies. Proceed-
  ings of meeting  sponsored by EPA and
  ITRC,  December 2002.
  (http://cluin.org/studio/napl  121002/1

• In  Situ  Thermal  Treatment  database
  (http://cluin.org/products/thermal')
• In  Situ  Chemical  Oxidation  database
  (http://cluin.org/products/chemox)

• FRTR Cost and Performance Case Stud-
  ies (http://www.frtr.gov/costperf.htm)

• State  Coalition of Drycleaner Case Stud-
  ies (http://www.drycleancoalition.org)

6.0 SUMMARY OF FINDINGS

The  following  general  and  technology-
specific findings about DNAPL characteri-
zation and  remediation are  based  on avail-
able information on the field technology
applications highlighted in this paper.

General Findings

The  13 sites profiled in Appendix A include
3 drycleaning establishments, 4 manufactur-
ing  or  chemical  processing  facilities,  2
MGPs, and 3 wood treatment sites, as well
as 1 landfill.  The majority  of the sites (8)
were suspected to have had chlorinated  sol-
vents (e.g., PCE,  TCE,  and/or methylene
chloride) and, in some cases, their degrada-
tion  products,  in the form of DNAPL or a
dissolved plume. The remaining 5  sites  (the
MGP and wood treatment sites) were con-
taminated with creosote or coal tar DNAPL
and in some cases diesel range hydrocarbons
used as carrier for the  creosote or penta-
chlorophenol. .

The  types of treatment used to address the
DNAPL sources included:

• In situ thermal technologies (six sites)

• Ex situ thermal technologies (one site)

• In situ chemical oxidation (five sites)

• SVE and air sparging (one site)


Source removal  through  the excavation of
contaminated  soil  was conducted at three
sites in addition to the subsequent treatment
application. The  time span from commenc-
ing in situ treatment to receiving  a closure
letter at these sites varied from about one to
eight years.
                                           13

-------
Of the 13 sites examined 7 had restrictions
or conditions placed on closure.  For exam-
ple:

• The NFA letter for the Avery Dennison
  Site, Illinois, required implementation of
  institutional controls.

• The NFA letter for the Former Cowboy
  Cleaners Site,  Colorado, permitted only
  commercial land use.

• The Certificate of Completion  for the
  Former Southern California Edison MGP
  will be signed pending deed restrictions
  that prohibit residential use.
Of the 7 sites where groundwater contami-
nation was treated , six  had MCLs as goals
and 5 achieved the MCLs. For example:

• Following oxidation treatment  the former
   Sta-Lube site achieved methylene chlo-
   ride concentrations of less than the 50
   jig/L MCL goal.

• At the Dry Clean USA site PCE levels
   which started out with a maximum de-
   tected of 27,300  ng/L were in the ND to
   3  (ig/L levels  (MCL 5 (ig/L)  following
   treatment.

• Using  SVE  and groundwater air sparging
   at the  Pasley  Solvents and Chemicals,
   Inc. site total VOCs  and TCE were re-
   duced from 37 mg/L and 320 ug/L re-
   spectively  to between ND and 4 (ig/L.
   The MCL for TCE is 5 ug/L.
Technology-Specific Findings
In Situ Thermal Treatment - Full-scale in
situ  thermal treatment was implemented at
six sites: two  manufacturing  facilities,  one
drycleaner, one MGP, and two wood treat-
ment facilities.  Three  of  the  sites were
treated using  thermal conduction, two with
ERH,  and  one with steam  injection.  The
treated soils primarily were a stratified  mix
of relatively low-permeability units such as
silts, clays, and silty sands. One site con-
tained coarser-grained fill material compris-
ing  sand,  gravel,  and  cobbles.  Volumes
ranging  from  approximately  50,000  to
500,000 ft3 were treated. The deepest con-
tamination treated was  over 145 ft below
ground  surface (bgs). Three  sites  received
closure  letters within less than two years of
commencing   thermal  treatment.  Overall,
these projects showed that in situ thermal
treatment  was able to remediate sites with
varying subsurface conditions in both the
saturated  and unsaturated zones to  satisfy
regulatory requirements.

• The Confidential Chemical Manufactur-
  ing Facility, Portland Indiana, used in situ
  thermal conduction to treat two contami-
  nated areas comprising a total volume of
  about 135,000 ft3 of saturated and unsatu-
  rated soil.  The goal was to reduce TCE,
  PCE, and  1,1-DCE concentrations from
  more than  3,500 mg/kg to less than state
  risk-based  cleanup goals  for  industrial
  land use (25 mg/kg for TCE, 8 mg/kg for
  PCE, and 0.08 mg/kg for 1,1-DCE) in five
  months. These goals were met and a NFA
  letter was issued by the state.

• The Avery Dennison Site, Illinois, used
  ERH to treat approximately 16,000 ft3 of
  saturated and  unsaturated soil. The goal
  was to  reduce  methylene chloride (MC)
  concentrations  from  more  than  50,000
  mg/kg to less  than the  state  risk-based
  cleanup goal (24 mg/kg)  in 11 months.
  While institutional controls were imposed
  the  average soil  concentration  of .51
  mg/kg MC met cleanup goals.

• The Camelot Cleaners Superfund  site in
  North Dakota  used an ERH  system to
  treat approximately 370,000 ft3 of soil and
  groundwater with the deepest zone tar-
  geted at 56 bgs. Cleanup goals (3  mg/kg
  in  soil  and 1  mg/L  total volatiles in
  groundwater) were  largely met with one
  small area having levels above 3 mg/kg.
  The heating and extraction  system oper-
  ated for 11 months.

• A Former  MGP Site in Massachusetts
  used in  situ thermal conduction to recover
  16,000  gallons of coal  tar and clean up
  about 54,000 ft3 of contaminated soil and
  fill in an abandoned gasholder. The goal
  to clean up the soil to meet state cleanup
                                           14

-------
  levels for unrestricted use was met; how-
  ever, the site has institutional controls as a
  whole because there are other areas at the
  site that could not be  cleaned up because
  of their proximity to operating equipment
  and  pipelines.  The  gas holder  project
  lasted approximately two years from ini-
  tial construction to demobilization.

• In situ  thermal desorption was used to
  treat about 450,000 ft3 of soil at the For-
  mer  Wood Treatment Area,  California.
  The goal was to treat soil containing up to
  35,000 mg/kg PAHs and 58 mg/kg PCP to
  levels  of  0.065  mg/kg  (expressed  as
  benzo(a)pyrene  equivalents  [B(a)P-eq])
  and 2.5 mg/kg  PCP. Cleanup goals were
  met  and the  site is open for unrestricted
  use.

• Steam  with injected air was used at the
  Visalia  Pole Yard to treat about 300,000
  pounds  of contaminants. DNAPL (creo-
  sote) and LNAPL (diesel range hydrocar-
  bons were present at the site. The cleanup
  goals of  17  mg/kg  and 1  (ig/L  penta-
  chlorophenol, 0.39 mg/kg  and 0.2 (ig/L
  benzo(a)pyrene and 0.001 mg/kg  and 30
  pg/L TCDD equivalent were all achieved
  by the end of an air sparging and biovent-
  ing polishing step following the steam ap-
  plication.


In  Situ  Chemical  Oxidation -  The  five
ISCO projects were  conducted at two dry-
cleaning facilities, a former MGP, a former
chemical manufacturing plant, and a landfill.
A variety of oxidants were used:

• Fenton's reagent (2 sites)

• Permanganate (1 site)

• Sodium persulfate (1)

• Hydrogen peroxide (1  site)

• Ozone (1 site)
The geology at the ISCO sites  range from
fine- to medium-grained sand to  stiff clay.
Several of the projects involved multiple (up
to four) phases of chemical injection  and the
ozone remediation pulsed ozone and  oxygen
into the subsurface over a two year period .
Three of the sites received  closure letters,
and one will receive a Certificate of Com-
pletion once deed restrictions are recorded.
The landfill site has not yet received an NFA
determination. Although MCLs  have  been
met  at  the  point of compliance (the  site
boundaries)  and the  onsite  plume is ap-
proaching MCLs, groundwater monitoring is
continuing at the landfill to determine when
the onsite plume has met cleanup standards
and ensure compliance.

• The Former MGP Site, Southern Califor-
  nia Edison  used  excavation and in  situ
  ozonation to reduce  total polycyclic aro-
  matic  hydrocarbons  (PAHs)  concentra-
  tions in soil from 2,500 mg/kg to less than
   1.75 mg/kg as B(a)P-eq (the site-specific
  risk-based cleanup goal) in approximately
  three years.  Cleanup goals in groundwater
  and soil were met except for an inaccessi-
  ble area around a highway foundation.

• The Former Cowboy Cleaners  Site, Colo-
  rado,  used potassium permanganate to re-
  duce PCE concentrations in groundwater
  from  1,900  (ig/L  to  48  (ig/L in approxi-
  mately one  year.  This was sufficient  for
  the state to issue a NFA with site uses re-
  stricted to commercial.

• Dry Clean USA #11502, Florida, used a
  combination of P&T, SVE, and hydrogen
  peroxide to treat a groundwater plume ap-
  proximately 800 ft by 300 ft and up to 68
  ft deep. The goal was to reduce PCE con-
  centration in the groundwater  to 3 (ig/L,
  or less. The P&T and SVE systems oper-
  ated about 3.5 years. They were followed
  by  a  one-month application of peroxide
  for polishing. One year PCE  concentra-
  tions varied between  1.7 and 3 (ig/L and
  the state issued an NFA with unrestricted
  use.

• Four injections of Fenton's reagent were
  conducted from 1998 to 2001 at the Naval
  Submarine  Base   Kings Bay, Site   11,
  Georgia. Groundwater P&T to  contain the
  groundwater plume (700 ft by 200 ft and
  30 to 40 ft deep) within the site bounda-
                                           15

-------
  ries had failed, and modeling suggested
  that  if the  plume  concentrations were
  lowered to 100 ug/L total chlorinated hy-
  drocarbons, MNA would treat the remain-
  ing dissolved  contaminants. ISCO  re-
  duced  levels to the target, but made the
  aquifer aerobic in the injection areas and
  some  distance  downgradient. To return
  the now aerobic section of the aquifer to
  reducing conditions, subsequent injections
  of emulsified  oil were  made and these
  created the  necessary  anaerobic  condi-
  tions for degradation. As of 2004, the lev-
  els have been reduced  to less than  13.9
  ug/L.  MNA  is the final corrective action
  for remaining groundwater contamination
  at the  site. MCLs have been met at the site
  property line for all contaminants having
  them.

• Following large-auger excavation of the
  source area, persulfate catalyzed with hy-
  drogen peroxide was injected at the Sta-
  Lube site, California, to treat a methylene
  chloride plume. Due to the  presence  of
  DNAPL, a 80-ft by 30-ft plume  beneath
  the building was not treated by the previ-
  ous SVE  and  P&T systems. Concentra-
  tions were reduced from a maximum  of
  18,000  ug/L to the cleanup goal of 50
  ug/L within  5  months.  Final closure was
  granted in June 2008.

SVE and Air Sparging - Contamination at a
solvent transfer facility was cleaned up prin-
cipally by SVE and air sparging.

• The   Pasley   Solvents   and  Chemicals
  Superfund  Site  in  New   York used
  SVE/AS to treat soil source zones (total
  VOCs up to 603  mg/kg) and a 60-ft by
  400-ft-long  chlorinated solvents  plume
  (TCE up to 320 ug/L).  All cleanup goals
  were    met    including    Maximum
  Contaminant    Levels    (MCLs)   for
  groundwater contaminants. A NFA letter
  was issued with no institutional controls
  requirements.  The remediation  took 60
  months with  18  months of subsequent
  groundwater monitoring.
REFERENCES

General

EPA 2007. Recommendations from the EPA
Ground Water Task Force. EPA 500-R-07-
00I.December 2007. http://gwtf.clu-
in.org/docs/report/gwtf report  coverletter.p
df

EPA. 2006. Engineering Forum Issue Paper:
In Situ Treatment Technologies for Con-
taminated Soil, EPA 542-F-06-013.
http: //www .epa. gov/tio/tsp/download/5 42fO
6013.pdf

EPA. 2004a. DNAPL Remediation: Selected
Projects Approaching Regulatory Closure,
EPA542-R-04-016.
http: //www .epa. gov/tio/download/remed/5 4
2r04016.pdf

EPA. 2004b. Site Characterization Tech-
nologies for DNAPL Investigations. EPA
542R-04-017.
http://www.clu-
in.org/download/char/542r04017.pdf

EPA 2004c. In Situ Thermal Treatment of
Chlorinated Solvents: Fundamentals and
Field Applications. EPA 542-R-04-010.
http://costperformance.Org/remediation/pdf/i
n situ  thermal trtmnt.pdf

EPA. 2004d. Cleaning Up the Nation's
Waste Sites: Markets and Technology
Trends. EPA 542-R-04-015.
http: //clu-in. org/market/

EPA 2003. The DNAPL Remediation Chal-
lenge: Is There a Case for Source Depletion?
EPA/600/R-03-143.
http://www.clu-
in.org/download/remed/600R03143 .pdf

EPA. 2002. Handbook of Groundwater Pro-
tection and Cleanup Policies for RCRA Cor-
rective Action. EPA 530 F-01-021.
                                          16

-------
http://www.epa.gov/correctiveaction/resourc
e/guidance/gw/gwhandbk/gwhb041404 .pdf

EPA. 1999a. Groundwater Cleanup: Over-
view of Operating Experience at 28 Sites.
EPA 542-R-99-006.
http://www.clu-
in.org/download/remed/ovopex.pdf.

EPA. 1999b. Use of Monitored Natural At-
tenuation at Superfund, RCRA Corrective
Action, and Underground Storage Tank
Sites. OSWER Directive 9200.4-17P.
htto://www.epa.gov/OUST/directiv/d920041
7.pdf

EPA. 1996. The Role of Cost in the Super-
fund Remedy Selection Process. Publication
9200.3-23FS, 8 pp. EPA 540 F-96/018.
http://www.epa.gov/superfund/resources/cos
t_dir/cost_dir.pdf

EPA. 1993. Guidance for Evaluating the
Technical Impracticability of Ground Water
Restoration. OSWER Directive 9234.2-25.
http://www.epa.gov/swerffrr/pdf/groundwat
er.pdf

EPA. 1992. Estimating Potential for Occur-
rence of DNAPL at Superfund Sites. OS-
WER Publication 9355.4-07FS. National
Technical Information Service (NTIS) Order
Number PB92-963338CDH.
http://www.epa.gov/superfund/resources/gw
docs/non_aqu .htm

Freeze, Allan R. and David B. McWhorter.
1997. A Framework for Assessing Risk Re-
duction Due to DNAPL Mass Removal from
Low-Permeability Soils. Ground Water.
Vol. 35, No. 1, Pages 111-123.

Illinois Environmental Protection Agency
(IEPA). 2004. Fact Sheet. Tiered Approach
to Correction Action Objectives (TACO).
http://www.epa.state.il.us/land/taco/l-
introduction.html
Illinois Administrative Code. Title 35, Sub-
title G, Chapter I, Subchapter f, Part 742:
Tiered Approach to Corrective Action Ob-
jectives.
http://www.ipcb. state .il .us/documents/dsweb
/Get/Document-3 8408/

ITRC. 2004. Strategies for Monitoring the
Performance of DNAPL Source Zone
Remedies (DNAPLs-5).
http: //www.itrcweb .org/gd  DNAPLs. asp

ITRC. 2003a. Technology Overview: An
Introduction to Characterizing  Sites Con-
taminated with DNAPLs.
http: //www .itrcweb .org/gd_DNAPLs. asp

ITRC. 2000. Technology Overview: Dense
Non-Aqueous Phase Liquids (DNAPLs):
Review of Emerging Characterization and
Remediation Technologies.
http://www.itrcweb.org/Documents/DNAPL
s-l.pdf

Kram, Mark L., Arturo Keller, Joseph Ross-
abi, and Lome Everett. 2001. DNAPL Char-
acterization Methods and Approaches, Part
1: Performance Comparisons. Ground Water
Monitoring and Remediation. Fall. Pages
109-123.
http://www.cluin.org/download/char/GWM
R Fall 109-123.pdf

NAVFAC. 2004. Guidance for Optimizing
Remedy Evaluation, Selection, and Design.
UG-2060-ENV.
https: //portal .navfac .navy .mil/portal/page/po
rtal/navfac/navfac ww_pp/navfac nfesc_pp/
environmental/erb/opt/ug-2060-opt.pdf

National Research Council. 2003. Environ-
mental Cleanup at Navy Facilities: Adaptive
Site Management. National Academies
Press.
http://www.nap.edu/catalog.php7record  id=
10599
                                          17

-------
National Research Council. 1997. Innova-
tions in Ground Water and Soil Cleanup -
From Concept to Commercialization. Na-
tional Academies Press.
http://www.nap.edu/catalog.php7record id=
5781

Sale, Tom C. and David B. McWhorter.
2001. Steady State Mass Transfer from Sin-
gle-Component Dense Nonaqueous Phase
Liquids in Uniform Flow Fields. Water Re-
sources Research. Vol.  37, No. 2. pp. 393-
404.

In Situ Bioremediation

EPA. 2000. Engineered Approaches to In
Situ Bioremediation of Chlorinated Sol-
vents: Fundamentals and Field Applications.
EPA 542-R-00-008.
http://cluin.org/download/remed/engappinsit
bio.pdf

ITRC. 2005. Overview of In Situ Bioreme-
diation of Chlorinated Ethene  DNAPL
Source Zones.
http: //www .itrcweb. org/documents/BioDN A
PL-l.pdf

ITRC. 2008. In Situ Bioremediation of
Chlorinated Ethene DNAPL Source Zones.
http://www.itrcweb.org/Documents/bioDNP
L  Docs/BioDNAPL3.pdf

In Situ Chemical Oxidation

Environmental Security Technology Certifi-
cation Program (ESTCP). 1999.  Technology
Status Review: In Situ Oxidation.
http: //www .e step. org/documents/techdocs/IS
O_Report.pdf

Ruling, Scott and Bruce Pivetz. 2006. Engi-
neering Issue: In-Situ Chemical Oxidation,
EPA/600/R-06/072.
http://www.epa.gov/ada/download/issue/600
R06072.pdf
ITRC. 2001. Technical and Regulatory
Guidance for In Situ Chemical Oxidation of
Contaminated Soil and Groundwater.
http://www.itrcweb.org/Documents/ISCO-
2.pdf

Watts, R., Frank Loge, and Amy Teel. 2006.
Improved Understanding of Fenton-Like
Reactions for the In Situ Remediation of
Contaminated Groundwater Including
Treatment of Sorbed Contaminants and De-
struction of DNAPLs. Strategic Environ-
mental Research and Development Program.
http://docs.serdp-estcp.org/viewfile.cfm7Do
c=ER 1288  FRpdf

In Situ  Surfactant/Co-Solvent
Flushing

ITRC. 2003b. Technical and Regulatory
Guidance for Surfactant/Co-Solvent Flush-
ing of DNAPL Source Zones.
http://www.itrcweb .org/gd DNAPLs.asp

In Situ  Thermal Treatment

EPA. 2004c. In Situ Thermal Treatment of
Chlorinated Solvents - Fundamentals and
Field Applications. EPA 542-R-04-010.
http://cluin.Org/techfocus/default.focus/sec/T
hermal_Treatment:_In_Situ/cat/Application/

Davis, E. 1998. Ground Water Issue: Steam
Injection for Soil and Aquifer  Remediation.
EPA 540/S-97/505, 16pp.
http://www.epa.gov/ada/download/issue/stea
minj .pdf

Davis, E. 1997. Ground Water Issue: How
Heat Can Enhance In-Situ Soil and Aquifer
Remediation: Important Chemical Properties
and Guidance on Choosing the Appropriate
Technique. EPA 540/S-97/502, 18 pp.
http://www.epa.gov/ada/download/issue/hea
tenh.pdf

Gavaskar, Arun, Mohit Bhargava, and
Wendy Condit. 2007. Final Report: Cost and
Performance Review of Electrical Resis-
tance Heating (ERH) for Source Treatment.
                                          18

-------
Naval Facilities Engineering Service Center,
TR-2279-ENV, 133 pp.
http://costperformance.org/remediation/pdf/
Navy-ERH Review.pdf

Zero-Valent Iron Injection

EPA, 2008. Nanotechnology for Site Reme-
diation. EPA 542-F-08-009.
http://www.clu-in.org/542f08009

EPA. 2004. Demonstration Injection of In
Situ Dehalogenation of DNAPL through
Injection of Emulsified Zero-Valent Iron at
Launch Complex 34 in Cape Canaveral Air
Force Station Florida: Innovative Technol-
ogy Evaluation Report. EPA/540/R-07/006.
http://www.epa.gOv/nrmrl/pubs/540r07006/5
40r07006.pdf

U.S. Department of the Navy. 2003. Final
Cost and Performance Report - Feroxsm In-
jection Technology Demonstration Parcel C,
Remedial Unit C4, Hunters Point Shipyard,
San Francisco, California, July 11, 2003.
DS.A013.10177
http://costperformance.org/pdf/20040701  3
52.pdf

Combined Remedies

NAVFAC. 2004. Guidance for Optimizing
Remedy Evaluation, Selection, and Design,
User's Guide. UG-2060-ENV.
http: //www .clu-in. org/download/remed/
Navv-OPT-doc-UG-2060-OPT.pdf

NOTICE AND DISCLAIMER

Preparation of this report has been funded
wholly or in  part by EPA  under  Contract
Number  68-W-03-038. Mention  of  trade
names or commercial products does not con-
stitute endorsement or recommendation for
use. A PDF version of this  report  is avail-
able for viewing or downloading from the
Hazardous Waste Cleanup Information (Clu-
In) web  site  at http://clu-in.org. For  more
information regarding this  report,  contact
Linda Fiedler of EPA's Office of Superfund
Remediation and Technology Innovation,  at
(703)603-7194  or  fiedler.linda@,epa.gov.
                                          19

-------
                            Appendix A

          DNAPL Remediation Project Profiles
The DNAPL remediation projects profiled        quantity of DNAPL originally present. Most
here were conducted as full-scale remedia-        of these sites have reached regulatory
tion projects rather than research demonstra-      cleanup goals and require no further action
tions, and the sampling efforts typically          with no further monitoring.
were not sufficient to establish the exact
                                    20

-------
Confidential  Chemical   Manufacturing
Facility, Portland, Indiana

Technology Used: In situ conductive heat-
ing and vacuum (in situ thermal desorption)

Regulatory  Program:  State  Voluntary
Cleanup Program

Project Duration: July to December 1997

Information Last Updated: 2008

Site  Information:  The  16-acre chemical
manufacturing  facility  is  located  in the
southern portion of Portland, Indiana, south-
east of the Salamonie River. Since 1886, the
area has been used as a lumberyard for the
manufacture of wheels, hard rubber products
used in automobiles,  and  plastic exterior
automobile parts. The site has  four buildings
including a north plant building that is cur-
rently being used part-time for the rework-
ing of automotive parts. A sampling event
conducted in June 1994 revealed the pres-
ence of volatile organic compounds (VOCs)
in soil  and groundwater. Additional investi-
gations performed from July 1995 to Febru-
ary 1996 confirmed the presence of VOCs in
subsurface  soil  of two areas near the north
plant building.  Contamination in one  area
covered 150 ft by 50 ft to a depth of 18 ft,
and the contamination in the other extended
to an area of 30 ft by 20 ft to a depth of 11
ft.

Contaminants:  Chlorinated solvents (PCE,
TCE,  and  1,1-DCE) were  detected  in the
unsaturated  zone  at  levels  up  to  3,500
mg/kg, 79 mg/kg, and 0.65 mg/kg,  respec-
tively.  The  elevated  concentration of PCE
suggested  the presence of DNAPL.  VOCs
were not found above  the cleanup goals in
groundwater after treatment.

Hydrogeology: The facility overlies a het-
erogeneous combination of fill, clayey sand,
and construction debris, to a depth of about
7 ft. Tills, consisting of moist, silty clay ex-
tend to a depth of 18 to  19 ft bgs.  Fine to
coarse gray sand with some gravel are found
beneath the till at depths greater than 19 ft
and extending to a maximum of 30 ft. The
estimated hydraulic conductivity of the till
was  10"8 cm/s. Groundwater occurs  at ap-
proximately 22 ft bgs.

Project Goals: Soil cleanup goals were es-
tablished based on the Indiana Department
of Environmental Management (IDEM) Tier
II Cleanup Goals for Industrial Land Use
http://www.in.gov/idem/5516.htm

Cleanup Criteria for Confidential Chemi-
cal   Manufacturing  Facility,  Portland,
Indiana (Tier II)
Contaminant
1,1 -DCE
TCE
PCE
Tier II Cleanup
Level for Soil
(mg/kg)
0.080
25
8
Cleanup Approach: Site investigations be-
gan in 1994. The in situ conductive heating
system began operation in July 1997 to treat
contaminated soil in two source areas. A
total of 130 heater/vacuum wells were in-
stalled on a 7.5-ft triangular spacing  in the
first source area to a depth of 19 ft. Fifteen
heater/vacuum wells were installed on a 7.5-
ft triangular spacing to depths of 12 ft in the
second  source  area. The  heaters  in these
wells  operated  at a temperature of 1,400 -
1,600°F, to raise  the subsurface tempera-
tures within the treatment zone to an average
of275°F.

The heater/vacuum wells also extracted soil
gas. Off-gases were treated with a flameless
thermal oxidizer,  cooled by  a  heat  ex-
changer, and then passed through a carbon
adsorption  bed.  Off-gases were monitored
for hydrogen chloride, which was used as an
indicator of the decomposition of chlorin-
ated solvents. Off-gases were treated with an
1800  standard cubic feet per minute (scfm)
flameless thermal oxidizer with an operating
temperature range of 1,800-1,900°F, cooled
by a heat exchanger, then passed through a
carbon adsorption bed.
                                           21

-------
 To determine the effectiveness of the treat-
 ment system,  about 50 soil  samples were
 collected from  the coldest locations within
 the treatment zone farthest from each heater
 well and analyzed for VOCs. Based on the
 results, heating was discontinued in  Decem-
 ber 1997. Confirmation sampling was  con-
 ducted after monitoring the  soil tempera-
 tures for six months.

 Project Time Line:

 1994 - 1996 Site investigations performed
 7/97 - 12/97 In situ conductive heating per-
 formed
Project Results: Following treatment, re-
sults of confirmation sampling showed that
PCE and  TCE concentrations were below
the cleanup goals. No confirmation samples
were available for the smaller, 1,1-DCE con-
taminated zone area. The table below shows
contaminant concentrations at locations that
had relatively higher  concentrations before
treatment. Based on the results, the IDEM
issued a NFA letter for this property. Infor-
mation about the date or conditions of the
NFA letter was not available.
Comparison of Selected Pre-Heating and Post-Heating Contaminant Concentrations in Soil
Sampling Location
SA 13
GP31
SA4
SB 20
SB 19
Depth
(ft)
9-10
15-16
4-5
4-5
12-14
Contaminant Concentration (mg/kg)
Before Treatment
PCE
3,500
570
23
2.9
76
TCE
79
Not sampled
0.25
0.67
1.6
After Treatment
PCE
0.011
0.18
0.530
0.046
0.048
TCE
0.020
0.008
ND
ND
ND
 ND - non-detect (detection limits not provided)

 Source:  Federal Remediation Technologies
 Roundtable. 2003. "Cost  and Performance
 Report: In situ Conductive  Heating at the
 Confidential Chemical Manufacturing Facil-
 ity, Portland, Indiana."
 http://costperformance.org
                                            22

-------
Avery Dennison Site, Waukegan, Illinois

Technology: ERH

Regulatory Program:  Illinois  EPA  Site
Remediation Program

Project Duration: December 1999  to  No-
vember 2000

Information Last Updated: 2008

Site Information: The Avery Dennison site
is  located in the  Waukegan-Gurnee  Indus-
trial Park in Waukegan, Illinois.  Film coat-
ing operations were performed at this site
from  1975  to 1992. MC was used in these
operations and transferred to above-ground
storage  tanks via underground piping.  Site
investigations showed the occurrence of MC
in the soil and groundwater in several areas
of the site.

Contaminants: Approximately 16,000 ft3 of
soil was contaminated with MC to depths as
great  as 24 ft bgs. Concentrations  of MC
ranged to a high of 50,000 mg/kg and aver-
aged  1,900  mg/kg. Information about  the
concentration of MC in groundwater was not
available.

Hydrogeology: The geology underlying the
two-acre site is predominantly heterogene-
ous silty-clay glacial till to a depth of about
180 ft bgs. An  8-ft-thick running sand unit
occurs  around 22 ft bgs.  Groundwater is
typically found  around  25 ft  bgs with
perched water units encountered  at as shal-
low as 6 ft bgs. Bedrock is found at  depths
ranging from 180 to 270  ft bgs.

Project Goals: The remediation objective at
the Avery Dennison site was to  reduce  the
concentration of MC in the soil to below 24
mg/kg, based on lEPA's Tiered Approach to
Corrective Action Objectives.

Cleanup Approach: The  treatment area
was divided into 20 treatment cells. For each
treatment cell,   electrodes  were  installed
around the  perimeter to  a depth of 24 ft. A
total of 95 electrodes were installed includ-
ing six below an active street, and 16 inside
the existing building.  Two thermocouples
were installed in the center of each treatment
cell, at the shallowest (4 ft bgs) and deepest
levels of contamination (24 ft bgs). In addi-
tion, 34  vacuum  extraction wells and five
horizontal wells were installed to extract soil
vapor and steam.  The designed power input
was 1,250 kilowatts (kW). After six months
of operation, target soils reached an average
temperature of  80°C,  with  central  areas
reaching boiling temperatures.

Project Time Line:
1985 - Removal Action
1988 - Installation of grout curtain around
the former bulk storage area
1991-1994 - Soil vapor extraction per-
formed at former bulk storage area. This was
ineffective and discontinued at the end of
1994.
1992-1994 - Pump and treat of groundwater
1994-1998 - Air sparging of groundwater
12/99 - ERH initiated in western portion
6/00 - ERH initiated in eastern  portion

11/00 - ERH completed
4/01 - IEPA issued NFR letter

Project Results: Very little MC was recov-
ered by  the vacuum systems. Analysis of
soil samples  collected  in areas of known
high MC concentrations had high concentra-
tions of chloride ions indicating that the MC
was destroyed in place by hydrolysis. A total
of 125 soil samples were collected and ana-
lyzed for MC. The average MC concentra-
tion in  soil was reduced  to  2.51  mg/kg,
which is below the cleanup goal.  Based on
the confirmatory  sampling results, in April
2001, the IEPA issued  a NFR letter, which
specified  several engineering  and  institu-
tional controls, including a prohibition on
installing  and  using potable water  supply
wells in a specified area around the site. Re-
development  was restricted  to industrial/
commercial reuse, and the site was  subse-
                                           23

-------
quently  redeveloped  into an  office  and        Federal  Remediation Technologies  Round-
warehouse park,                                 table. 2003. "Cost and Performance  Report:
                                                Electrical  Resistive Heating  at  the  Avery
Sources: Current Environmental Solutions        Dennison    Site,   Waukegan,   Illinois."
website: http://www.cesiweb.com.                 http://costperformance.org.
                                           24

-------
Camelot  Cleaners,  West  Fargo,  North
Dakota

Technology: ERH

Regulatory Program: U.S. EPA, Region 8
Superfund

Project Duration: June 2004 to July 2006

Information Last Updated: 2008

Site Information:  Camelot Cleaners is an
operating  drycleaner that uses PCE as its
cleaning  solvent. The cleanup footprint is
about 10,300 ft2 with depths of the contami-
nation ranging to 56 ft bgs.  The area in-
cludes part of the yard of an occupied resi-
dence.

Contaminants: PCE and  its degradation
products  (TCE and DCE) were detected in
soil  and  groundwater. PCE concentrations
were up to 2,200 mg/kg in soil and 89 mg/L
in groundwater. The contaminated  volume
of soil was estimated to be about 370,000 ft3
with the deepest zone targeted at 56 bgs.

Hydrogeology: Camelot Cleaners is under-
lain by low-permeability clay  with goethite
infilling of joints and fractures. Groundwater
occurs between 3 and 7 ft bgs and tends to
be perched. The regional aquifer is at ap-
proximately 60 to 70 ft bgs.

Project Goals: The  project goals were to
reduce PCE levels  to less than 3 mg/kg in
soil and total  VOCs to less than 1 mg/L in
groundwater.

Cleanup Approach:  The deployment of the
six-phase electrical heating system included
56 multi-zone electrode/vent assemblies and
several horizontal  soil vapor  extraction
wells. In especially clayey horizons, the ex-
traction wells were  augmented with  dual
vacuum extraction  wells. Soil temperature
was recorded  at ten temperature monitoring
piezometers.  Nine multi-level  monitoring
wells were installed around the perimeter of
the site to monitor existing conditions and
cleanup success, and to ensure that any sub-
surface migration of contaminants would be
detected. The system removed about  5,188
pounds of contaminants.

Project Time Line:
6/04 - Site construction began
2/05 - Heating began
11/05 - Heating was stopped and the hori-
zontal extraction well system was turned off
1/06 - Dual vacuum extraction well system
was turned off following cool-down period
7/06 - EPA removed the electrode and vent
assemblies, and after discussion with the
North Dakota Department of Health, the
groundwater monitoring wells were aban-
doned.

Project Results: A total of 5,188 pounds of
VOC mass was removed within one year of
ERR operation. EPA confirmation sampling
indicated that soil  contamination had been
reduced by  99.96 to 100% and groundwater
concentrations had been reduced by 99.98%.
Only one area had concentrations of PCE
over 3 mg/kg, and all the groundwater sam-
ples were under 1 mg/L. The site is now in a
no further  action,  no further groundwater
monitoring required status.

Sources: DNAPL  Remediation  In   Low
Permeability Clays Camelot Cleaners Super-
fund Site Fargo, ND
http://www.cesiweb.com.

Personal communication with  Joyce Acker-
man, U.S. EPA Region  8, April 27, 2007
and April 28, 2008.
                                          25

-------
Former MGP  Gasholder, North Adams,
Massachusetts

Technology:   Thermally   enhanced  free
product recovery, in situ thermal solidifica-
tion  (ISTS), and in situ thermal desorption
(ISTD)

Regulatory Program: Massachusetts De-
partment of Environmental Protection

Project Duration: August 2003 to  June
2005

Information Last Updated: 2008

Site  Information: The  former MGP  in
North Adams, Massachusetts, operated from
the 1860s to the 1950s. When the 18-ftdeep,
62-ft-diameter  gasholder  was  decommis-
sioned, it was backfilled with soil and debris
enclosing a volume of approximately 2,013
yd3.  Based on limited soil investigations
within the  gasholder, residual coal tar was
present throughout the soil. The bottom four
feet  of soil were  saturated with coal tar
DNAPL.

Contaminants: The contaminants  of con-
cern  at the site  are  semivolatile  organic
compounds associated  with coal  tar. The
maximum  concentrations  of  some  of the
contaminants detected were: benzo(a)pyrene
(650 mg/kg), naphthalene (14,000  mg/kg),
benzene (6,200 mg/kg), and TPH (230,000
mg/kg).

Hydrogeology: The contents  of the  gas-
holder comprise a mixture  of sand,  gravel,
cobbles, and other fill material. The regional
aquifer is located beneath. Perched ground-
water was found within the gasholder at 3 ft
bgs.

Project Goals: The  project goals, derived
from a  human  health risk  assessment, de-
pended on the depth. Within 6 to 15 ft bgs,
the goals were to eliminate  DNAPL  and re-
duce contaminants below  the Massachusetts
Contingency Plan's upper concentration lim-
its for a potential construction worker expo-
sure scenario,  e.g., benzo(a)pyrene  (300
mg/kg), naphthalene (10,000  mg/kg), ben-
zene  (2,000  mg/kg),  and  TPH  (10,000
mg/kg). Within the bottom of the gasholder
(15 to  18 ft bgs), the goal was to eliminate
DNAPL so that there would not be a risk of
future  release  of DNAPL to  groundwater.
The regional aquifer occurs below the base
of the gasholder.

Cleanup Approach: Three levels of heating
were conducted:  1) Low-temperature heat-
ing for thermally enhanced free product re-
covery of coal tar  from the  gasholder;  2)
Moderate-temperature  heating  for ISTS  of
coal tar at the bottom of the gasholder; and
3) High-temperature heating  and  ISTD  in
the midsection of the gasholder (6-15  ft
bgs).

Twenty-five thermal wells—19 heater-only
wells and  6 heater-vacuum wells—were in-
stalled  to the base of the gasholder. Prior to
heating,  100,000 gallons of water were
pumped from the gasholder and treated by
passing it through an oil/water separator fol-
lowed  by  clay-carbon media  and  activated
carbon.

Next,   low-temperature  heating was  con-
ducted   to  remove  free-flowing  coal tar
DNAPL. Air was injected into each thermal
well to maintain oxidizing conditions within
the lower  part of the gasholder throughout
the remediation process. Thermocouple ar-
rays were  used to  ensure that subsurface
temperatures  within  the  treatment  zone
reached target goals.

The temperature was  then  raised  to  or
slightly above the boiling point of water to
eliminate   16,000  gallons  of  additional
DNAPL via  ISTS. The temperature was
raised again to 325°C to volatilize, boil, py-
rolize,  and oxidize the remaining  contami-
nants through  ISTD. Vapors  were  treated
using a regenerative thermal oxidizer with a
vapor  phase  activated  carbon   unit  for
backup.
                                          26

-------
Project Time Line:

11/03 - Site construction
2/04 - Dewatering tar recovery
7/04 to 3/05 - Full power heating
6/05 - Demobilization

Project Results:  The intermediate heating
recovered 16,000 gallons of coal tar. Within
the upper portion of the gasholder (6 to 15 ft
bgs), full heating brought average concentra-
tions of all constituents of concern below the
Massachusetts upper  concentration limits.
The   final averages  were:  0.33  mg/kg
benzo(a)pyrene,  5.7  mg/kg naphthalene,
0.35 mg/kg benzene, and 43.15 mg/kg TPH.
Within the bottom of the gasholder (15 to 18
ft bgs), full heating reduced concentrations
of benzene to 0.95 mg/kg and naphthalene to
70 mg/kg. In the process, the previously liq-
uid coal tar was thermochemically solidified
to  material that had the appearance of  as-
phalt and no longer a  DNAPL consistent
with the findings of Hayes (2002).

All  goals for the project were met. The
owner filed for an Activity and Use Limita-
tion  to the Massachusetts  Department  of
Environmental Protection, rather than a No
Further Action Determination, because un-
restricted use was not obtainable for the site
as a whole. Elsewhere on the MGP property,
contaminants were  allowed to  remain in
place beneath a cap.

Sources: Fact sheet. Commercial Project—
MGP Gasholder. TerraTherm® Inc.
http: //www .terratherm .com

Baker, Ralph S., et  al. In Situ Thermal De-
struction (ISTD) of MGP Waste in a Former
Gasholder: Design and Installation.
http://www.terratherm.com/resources/TechP
apers/Terratherm%20Paper%205 5 6%20-
%20Monterev.pdf

Baker, Ralph, et al.  Demonstration of Three
Levels of In-Situ Heating for Remediation
of a Former MGP Site.
http://www.terratherm.com/resources/TechP
apers/Baker%20et%20al.%202006%20Mont
erev%20MGP.pdf

Hayes, Thomas D. 2002. Development of In
Situ Thermochemical Solidification for the
Risk Based Treatment of Coal-Derived
Dense Nonaqueous Phase Liquids. GRI-
04/0215. Prepared by Gas Technology Insti-
tute, Des Plaines, IL for Gas Research Insti-
tute.
                                          27

-------
Former Wood Treatment Area,  Alham-
bra, California

Technology Used: In situ thermal desorp-
tion (ISTD)

Regulatory   Program:   Voluntary action
under California Department of Toxic  Sub-
stances  Control  (DTSC)  Expedited Reme-
dial Action Program

Project Duration: May  2002  - February
2007

Information Last Updated: 2008

Site  Information: Southern California Edi-
son's 3 3-acre facility in Alhambra currently
is  used for storage, maintenance, and em-
ployee training. A portion of the facility, the
2-acre  former  wood  treatment  area,  was
used from approximately  1922-1957 to treat
utility poles by immersing them in creosote.
Pentachlorophenol  (PCP) was  also  used
briefly before operations were  shut down.
Spills and/or  leaks led to  the contamination
of underlying soil.

Contaminants: PAHs and PCP were pre-
sent  in site soil at maximum concentrations
of 35,000 mg/kg and 58 mg/kg, respectively,
and  mean concentrations of 2,306 mg/kg
and  <1  mg/kg. Dioxins,  expressed  as
2,3,7,8-tetrachlorodibenzodioxin    (TCDD)
Toxic  Equivalency  Quotient  (TEQ), were
present  at  a  maximum  concentration  of
0.194 mg/kg  and mean concentration  of
0.018 mg/kg.  The PCP used at the site is
believed to be the source of the dioxins. Ap-
proximately 16,500 yd3 of contaminated soil
required treatment.

Hydrogeology: The facility is underlain by
fill and silty sand interbedded with sand, silt,
and clay. The water table is greater than 240
feetbgs.

Project Goals: The following table shows
the soil remediation standards for the treat-
ment area.
Cleanup Criteria for the Former Wood
Treatment Area
Contaminant
Total PAHs
Pentachlorophenol
Dioxins
Soil Remediation
Standard (mg/kg)
0.065*
2.5
0.001**
*Expressed as (B(a)P-eq)
** Expressed as 2,3,7,8-TCDD TEQ.

Cleanup Approach: The ISTD process in-
volved simultaneous application of thermal
conduction heating and vacuum to treat the
contaminated soil  in  situ. A total of 785
thermal wells (131 heater-vacuum and 654
heater-only wells) were  installed on a hex-
agonal  grid within  the  31,430 ft2  target
treatment  zone.  The  heater-vacuum  wells
were installed at the center of each hexagon,
and the heater-only wells were installed at 7-
ft intervals on center. The wells ranged from
7 to 102 ft in depth.

To avoid exceeding the local power supply,
treatment proceeded in two phases. Prior to
Phase 1 of heating, a light aggregate cement
surface was poured  over the wellfield for
insulation and to provide a vapor seal that
prevented steam and vapor loss to the at-
mosphere. To improve the insulation during
Phase 2, a similar cement was poured  above
and below a layer of insulation board.

The target soil temperature  of 620°F was
attained in approximately 6 months of Phase
1 heating and was maintained for three days.
Gases  emerging from the heated soil were
collected under vacuum and conveyed to an
air quality control  system, which consisted
of a thermal oxidizer, heat exchanger to cool
the gases, and vessels of granular activated
carbon in series. Following wellfield cool-
down,  Phase 2 heating was  initiated. Con-
tinuous emissions  monitoring, vapor sam-
pling, and source tests were used to monitor
system performance.
                                          28

-------
Project Time Line:
00 - Treatability study and selection of con-
ductive heating
6/02 - 4/04 Phase  1 In Situ Thermal Desorp-
tion treatment
7/04 - 9/05 Phase  2 In Situ Thermal Desorp-
tion treatment
3/06 - Demobilization from site

2/8/07 - DTSC issues Remedial Action
Completion Report Approval and Certifica-
tion

Project  Results:  The  site-wide  mean
benzo(a)pyrene    equivalent   and  2,3,7,8
TCDD TEQ concentrations in soil were re-
duced from 30,600 ug/kg and 18  ug/kg, re-
spectively,  to  59  ug/kg and  0.11 ug/kg.
These concentrations are below their respec-
tive 65  ug/kg  and  1  ug/kg cleanup goals.
The mean PCP  soil concentration was 1.25
mg/kg. PCP was not detected in any of the
soil samples  at or above the remediation
goal of 2.5 mg/kg.

Dioxin emissions were 0.0084 ng TEQ/dsm3
compared to the 0.2 ng TEQ/ dsm3 standard.
In February 2007,  the California Department
of Toxic Substances Control issued a Reme-
dial  Action Completion Report Approval
and  Certification  stating that the treatment
area had been remediated to allow for unre-
stricted land use and that no further action
was  required. The cost of treatment was es-
timated to be 40% lower than the  cost for
excavation.

Sources: Fact sheet:  Former Wood Treat-
ment Area. TerraTherm® Commercial Pro-
ject-California.
http: //www .terratherm .com/Case Studie s/WS
%20Final%20Alhambra%20Sheet.pdf

Baker, Ralph S. Devon  Tarmasiewicz, and
John  M.  Bierschenk (TerraTherm,  Inc.),
Jennie King and Tony  Landler (Southern
California  Edison),  and  Doug Sheppard
(Lopez  and Associates  Engineers).  2007.
Completion of In-Situ Thermal Remediation
of PAHs, PCP,  and Dioxins at a Former
Wood Treatment Facility. Presented at IT3
'07 Conference, May  14-18, 2007 in Phoe-
nix, AZ.
http://www.terratherm.com/resources/TechP
apers/07-A-88-AWMA-IT3-
Baker%20rev%20a.pdf
                                          29

-------
Visalia Pole Yard, Visalia, California

Technology Used:  Grout wall,  pump and
Treat  (P&T),  in  situ thermal  desorption
(steam), and excavation

Regulatory Program: US EPA Superfund
NPL site with state lead

Project Duration: 1976 to 2008

Information Last Updated: February 2009

Site Information: Southern California Edi-
son  operated  a  20  acre fabrication yard
(Visalia  Pole  Yard)  to  produce  wooden
poles for use in the distribution of electricity
throughout the utility's service territory from
1925 to 1980. Western red cedar trees were
logged  and transported  to the yard, de-
barked, shaped,  and chemically preserved,
Until  1968, chemical preservation consisted
of immersion  of the  poles in heated bulk
creosote. From 1968 to cessation of opera-
tions, a solution  of pentachlorophenol and
diesel was substituted  as the wood preserva-
tive (DTSC 2005).

Contaminants: Substantial releases of creo-
sote which contains  numerous  polycyclic
aromatic hydrocarbons including benzo(a)-
pyrene, pentachlorophenol  (PCP),  which
contains  polychlorinated  dibenzo-p-dioxin
and furan impurities, and  diesel fuel used as
a carrier fluid for the PCP have occurred.
Other contaminants of concern include chry-
sene, 2-methylnaphthalene, naphthalene, and
phenanthrene (EPA 1994).

Hydrogeology: The sediments  underlying
the VPY are composed of alluvial-fan de-
posit  from the Kaweah  River and its di-
stributaries.  The  important   hydrostrati-
graphic units beneath the site are as follows:
the shallow aquifer (30 to 50 feet bgs; dewa-
tered since the 1980s), the shallow aquitard
(50 to  75 feet bgs), the intermediate aquifer
(75 to  100 feet bgs), the  intermediate aqui-
tard (100 to 125 feet bgs), and the deep aqui-
fer (125 to about 180 feet bgs).  Aquitards
generally consist  of silty  materials whereas
aquifers are composed of sand.  Testing of
the intermediate aquifer  indicated a trans-
missivity of approximately  50,000 gallons
per day per foot (gpd/ft) and the shallow
aquitard restricts vertical movement  of the
groundwater when  saturated.   Short-term
pumping from the deeper  aquifer affects
water in the  intermediate aquifer (DTSC
undated).

Project Goals: The  following table  shows
the remediation goals for  several  of the con-
taminants of concern.
Cleanup Goals
Parameter
Pentachlorophenol
Benzo(a)pyrene
TCDDequivalent1
Soil
17 mg/kg
0.39
mg/kg
0.001
mg/kg
Groundwater
lug/L
0.2 ng/L
30pg/L
1  Dioxin concentration  expressed  as 2,3,7,8-
  tetrachlorodibenzodioxin
Source:DTSC 2005

Cleanup Approach:  Excavation  and dis-
posal of affected soils  has occurred on nu-
merous  occasions   beginning  in   1972.
Cleanup of the groundwater began in 1975
with the installation of a pump and treat sys-
tem. In 1977 a slurry wall was built and
keyed into the shallow aquitard to  about 60
feet bgs (DTSC undated).

In 1997 it was  decided to use in situ steam
desorption as a means for  remediating the
source zones. The system applied steam and
air to the subsurface and the steam front was
monitored using electrical resistance tomo-
graphy. The steam remedy  operated in two
phases, between May 1997 and  June 2000.
Phase  1 operations focused on the interme-
diate aquifer, with injection and extraction
wells screened between 80 and 100 feet bgs.
Phase 2 operations began in November 1998
and included steam injection and extraction
below the intermediate aquitard,  with injec-
tion wells screened between 125  and 145
feet bgs. Phase 2 operations continued until
June 2000, when a precipitous drop in the
                                           30

-------
rate  of removal of WTCs  was measured
(DTSC undated).

Following cessation of the steam treatment,
the enhanced biological  degradation system
was  installed and operated (SCE, 2001) to
augment existing  physical  processes  that
were initiated by the steam treatment and to
encourage  natural  biological processes to
flourish. This system was in operation from
June 2000 until March 2004. It included va-
dose zone  bioventing  and  saturated  zone
biosparging,   coupled   with   continued
groundwater   pump-and-treat  operations.
Construction completion of the enhanced
Project Time Line:
1972—onward Excavation and removal ac-
tivities
1975—2004 Pump and treat
1976-1977—Placement of slurry wall
May  1997—June  2000 Two phase  steam
injection
June 2000—March 2004  Enhanced biologi-
cal degradation system
July 2006  Removal of  PCP hotspot (ap-
proximately two-thirds cubic yard)
May  2007  Covenant  to  Restrict Use  of
Property Environmental Restriction

Project Results: While the cleanup did not
        leave the land open to  unrestricted
        use, soil cleanup  goals were met in
        the first ten feet  of the subsurface.
        This is  the interval considered nec-
        essary for construction  purposes of
        commercial or industrial properties
        (SCE 2008).
  An Aerial View of the Visalia Site. Injection Wells are Shown
  in Magenta circles. Extraction Wells are Yellow squares.
                                         Conrtesv: DOE
biological degradation system  was  docu-
mented in the 2001 Preliminary Close Out
Report (DTSC undated).

A post-remediation soil investigation of the
surface soils  was conducted at this site in
November   2004.   Tetrachlorodibenzo-p-
dioxin (TCDD) was detected slightly above
the cleanup standards at four locations. As a
result of the  2005 Five-Year  Review, con-
taminated surface soil (soil between zero
and ten feet below grade) was  removed in
July  2006 and verified with confirmatory
sampling to be below the cleanup standards
prescribed in the ROD (DTSC undated).
        The  steam remediation effort  re-
        moved  approximately  1,330,000
        pounds of organic chemicals  from
        the subsurface (SCE 2008).

        The pump and treat system  com-
        bined with the  bio enhancement
        system polished the groundwater to
        an extent that risk based concentra-
tion  goals were met  as  well  as  the  three
MCL values (DTSC undated).

The City of Visalia has indicated an interest
in purchasing the property, following delist-
ing, for an expansion of their current  Gen-
eral Services operations (DTSC undated).

Sources:  DOE.  2000.  Hydrous  Pyrolysis
Oxidation/Dynamic Underground Stripping,
EM-0504, 26 pp.
http://www.osti.gov/bridge/product.biblio.js
p?osti  id=766922
                                           31

-------
DTSC.  undated.  Final  Close Out Report
Southern  California Edison Visalia Pole
Yard Superfund Site Visalia, Tulare County,
California, 11 pp.
http: //www .envirostor. dtsc. ca. gov/public/pro
file report.asp?global id=54490002

DTSC.  2005.  Southern  California Edison
Company, Visalia Pole Yard Superfund Site,
5-Year Review, 14 pp.
http://www.envirostor.dtsc.ca.gov/public/pro
file report.asp?global id=54490002

EPA.  1994. Record  of Decision: Southern
California  Edison Co. (Visalia  Poleyard),
EPA ID: CAD980816466,  OU 01, Visalia,
CA, 06/10/1994, 13 pp.
http://cfpub.epa.gov/superrods/index.cfm7fu
seaction=data.siterods&siteid=0902061
EPA Region IX. 2001.
Out  Report,  Southern
Visalia Pole Yard.
Preliminary Close
California  Edison
Southern   California   Edison   Company
(SCE). 2001. Visalia Steam Remedial Ac-
tion Plan, Construction Complete Report.
http://www.envirostor.dtsc.ca.gov/public/pro
file report.asp?global id=54490002

Southern California Edison Company. 2008.
Remedial Action Completion Report 2008, 9
pp.
http://www.envirostor.dtsc.ca.gov/public/pro
file report.asp?global id=54490002
                                           32

-------
Southern Maryland Wood Treating Site,
Hollywood, Maryland

Technology Used: Excavation and ex situ
thermal desorption with some offsite dis-
posal, P&T

Regulatory Program: Superfund

Project  Duration:  Construction  of the
thermal desorption units began  in October
1997 and treatment was completed by Octo-
ber 2001.

Information Last Updated: 2008

Site Information: The Southern Maryland
Wood Treating facility  was owned and op-
erated  by  the  Southern  Maryland  Wood
Treating  Company from  1965  to   1978.
Wood treating operations were conducted on
approximately 25  acres  of the  94-acre prop-
erty. Wood was pressure-treated using creo-
sote and PCP, and the liquid process  wastes
were disposed in six unlined lagoons. Seep-
age from the lagoons contaminated the un-
derlying  soil and groundwater.  Contami-
nated  groundwater discharged to an onsite
pond contaminating surface water and sedi-
ments. In addition, groundwater and pond
water discharges  to Old  Tom's  Run con-
taminated the  stream  sediments. Contami-
nated  ground-water was not detected in pe-
rimeter monitoring wells or nearby private
drinking  water wells.  Storage  of treated
wood onsite contaminated surface soil.

Contaminants: PAHs  and  benzene with
DNAPL well below the surface of the shal-
low groundwater table.

Hydrogeology: Silty and  clayey sand ex-
tends to a maximum depth of 40 ft bgs at the
site.  The  sand  is underlain by a low-
permeability, dense blue clay that  is ap-
proximately 20 ft thick. DNAPL was ob-
served atop this clay layer in the area below
the lagoons. The drinking water aquifers of
the underlying  Chesapeake Group  are  lo-
cated  approximately  285  to  600  ft bgs.
Drinking water wells in the area were  not
found to be contaminated.

Project Goals: The remedy  required that
soil and groundwater be cleaned up to resi-
dential standards. PAHs in surface and sub-
 Before: Floating Contamination on Pond,
 Summer 1999
surface  soil  were to be cleaned  up to  0.1
mg/kg (B(a)P-eq), and 1.0 mg/kg  (B(a)P-
eq),  respectively.  The cleanup  goals  for
 After: Restored Wetland Swale,
 Spring 2001
sediment were 0.4 mg/kg  PCP, 3.2 mg/kg
low molecular weight PAHs and 9.6 mg/kg
high molecular weight PAHs.

Cleanup Approach:  Contaminated soil and
sediment were excavated from the  site and
placed into one of two  onsite thermal de-
sorbers equipped with vapor recovery sys-
tems.  The lagoon  area was dewatered prior
                                          33

-------
to excavation, and the water was treated on-
site. Approximately  270,600 tons  of con-
taminated soil  and sediment were  treated
and backfilled onsite. Highly contaminated
soil and sediments not readily treated by
thermal desorption were shipped offsite for
proper disposal.

Surface water  from the  onsite  pond was
pumped and treated until the  source soil and
sediment were cleaned up.

The site was regraded and revegetated with
a diverse mixture of wildflowers  and grains
suitable for wildlife habitat.

Project Time Line:
3/14/85 First removal action (excavation of
contaminated pond sediment)
6/10/96 Site placed on the National Priori-
ties List
6/29/93 Second removal action (included
construction of an underflow dam to reduce
flow of contaminants from the pond to the
stream)
10/7/97 Construction activities began
2/00 Excavation of stream began

1/17/01 Soil and sediment treatment com-
plete
8/01 Remedial Action Completion Report
issued
2003 Two years of groundwater monitoring
complete
11/18/04 Ready for Reuse determination
issued by EPA for unrestricted use of site
4/5/05 Site deleted from NPL

Project Results: All cleanup goals were
met. Two  years of groundwater monitoring
that  followed soil  and  sediment  cleanup
verified that the cleanup  was a success. In
2004, a Ready for Reuse  determination was
issued by  EPA for unrestricted use of the
site.

Sources: U.S. EPA, 2004. Ready for Reuse
Determination  Southern  Maryland Wood
Treating Superfund Site, November  18.

U.S. EPA, 1999. Five-Year Review Report:
Southern  Maryland Wood Treating Super-
fund Site,  Hollywood, Maryland. September
30.
http://cfpub.epa.gov/fivevear/index.cfm7fus
eaction=fyrsearch.showSitePage&id=03003
05

U.S. EPA, 1995. EPA Superfund Record of
Decision:  Southern  Maryland Wood Treat-
ing, EPA  ID: MDD980704852, OU 2, Hol-
lywood, Maryland. (EPA/ROD/R03-95/197)
September 8.
http://cfpub.epa.gov/superrods/index.cfm7fu
seaction=data.siterods&siteid=0300305
                                          34

-------
Former Southern California Edison
Manufactured Gas Plant (MGP) Site.
Long Beach, California

Technologies: ISCO  (ozonation), excava-
tion

Regulatory Program:  Voluntary  action
under DTSC's Expedited Remedial Action
Program

Project Duration:  1998 to 2003

Information Last Updated: 2003

Site  Information: The Former Southern
Edison MGP site produced gas from oil and
coal  from 1902 to  1913, and contaminated
soil and groundwater with PAH and TPH.
The 340-ft by 230-ft strip of land is wedged
between  a  freeway and the Los  Angeles
River flood control channel. A  dense infra-
structure of power transmission cables, un-
derground  utilities, and elevated bridges
made conventional treatment difficult.

Contaminants: The  initial concentrations
of soil contaminants measured at the site
were  2,484  mg/kg total PAH  and 27,800
mg/kg TPH. The  chemicals of potential
concern identified  for soil included seven
carcinogenic PAHs, nine  noncarcinogenic
PAHs, and  TPH. A benzo(a)pyrene equiva-
lent  (B(a)P-eq) value was calculated for
each  carcinogenic  PAH and summed to-
gether to estimate  the total B(a)P-eq con-
centration.  Prior to treatment,  B(a)P-eq in
soil was slightly higher than 100 mg/kg.

Dissolved  concentrations  in  groundwater
were as high as 912 ug/L  TPH, 4.82 ug/L
benzene, 20  ug/L naphthalene, and 0.34
ug/L benzo(a)-pyrene.

Hydrogeology: The site is underlain by a
thin  layer of fill overlying  poorly  sorted
medium- to fine-grained sand. The water
table is approximately  10 ft bgs.
Project Goals: The remedial strategy for the site
was to meet an industrial cleanup  objective  of
1.75 mg/kg B(a)P-eq in soil.

Cleanup Approach:  ISCO through  ozonation
was conducted to treat soil and groundwater.  In
October 1998, 33 vertical sparging wells were
installed in  the  contamination  plume.  The
sparging wells were made of Teflon tubing for
most  of their length, and  stainless steel  rods
wrapped with stainless steel wire mesh over the
lower 25 ft for the distribution of ozone. In addi-
tion, a  single horizontal sparging  well with a
135-ft screened section was installed through the
center of the plume approximately 6 ft below the
water table.

Ozone was pulsed into the wells in both the satu-
rated  and vadose zones to promote  chemical
oxidation and enhanced biodegradation. Ozone
generation  was initiated in January  1999 and
continued  until system shutdown in  January
2001. Approximately  19,100  pounds of ozone
and 280,000 pounds of  oxygen  were generated
and injected. An SVE system was  used to pre-
vent unreacted ozone from reaching the surface.
Approximately 215 yd3  of highly contaminated
soil were excavated and disposed offsite.

Project Time Line:
10/98-11/98 - In situ ozonation system con-
structed
12/98 - Pilot test conducted
1999-2003 - Ozone generation conducted

11/22/05 - Site removed from Expedited Reme-
dial Action Program

Project Results:  Groundwater  concentrations
were  reduced below detectable  levels  after the
first quarter of ozone treatment. The concentra-
tion of benzo(a)pyrene was  reduced to less than
the 0.2 ug/L MCL. Site-wide soil concentrations
were reduced from more than 100 mg/kg to 1.4
mg/kg of B(a)P-eq. PAH and TPH concentra-
tions in groundwater were reduced to non-detect
levels after the first injection. A thin lens of con-
taminated  soil that contains up to 105 mg/kg  of
B(a)P-eq remains at depth. Because of the posi-
tion of highway foundations, the lens could not
                                            35

-------
be treated. DTSC will issue a Certificate of
Completion  once deed restrictions are re-
corded for the property.

Sources: In-Situ Oxidative  Technologies,
Inc. Case Study: Former MGP Site. South-
ern California Edison. Undated.
http: //www. insituoxidation. com/image s/C A
SE-21 %20MGP%20Site.%20California.pdf

Department of Toxic Substances Con-
trol, Edison/Long Beach II MGP (Ocean
Blvd), Envirostor.
http: //www. envirostor .dtsc. ca. gov/public
/profile  report.asp?global id=19490213
Dablow, Jay, Mark Seaman, and Bruce
Marvin, IT Corporation, 2001. In Situ Ozona-
tion to Remediate Recalcitrant Organic Con-
tamination. Paper presented at the 2001 In-
ternational Containment & Remediation
Technology Conference and Exhibition, Or-
lando, FL.
http://www.containment.fsu.edU/cd/content/p
df/352.pdf
                                            36

-------
Former Cowboy Cleaners  Site, Broom-
field, Colorado

Technology:  ISCO (potassium  permanga-
nate)

Regulatory Program: Colorado Voluntary
Cleanup Program

Project Duration: 2001 to 2002

Information Last Updated: 2003

Site Information:  The  Former  Cowboy
Cleaners  site  is  located in Broomfield,
Colorado, near Denver. A site investigation
revealed soil  and groundwater contamina-
tion. The approximate 1.5-acre  plume oc-
cupied portions of five  separately owned
properties   and  crossed  beneath a  street.
Small portions  of the plume also flowed
beneath a retail building and a residence.
The remediation  was handled  under the
Colorado Voluntary Cleanup Program.

Contaminants: Groundwater at the  site  is
contaminated with PCE.  Maximum initial
concentration of PCE was 1,900 (ig/L (sus-
pected DNAPL).

Hydrogeology: The site  is underlain by a
stiff clay to silty (sometimes  sandy) clay  at
3 ft bgs and a sandy clay layer at 8 ft bgs.
Groundwater is at 25 bgs.

Project Goals:  The State of Colorado de-
termined that the  low risks to potential re-
ceptors justified a remediation of the source
areas, allowing the groundwater plume to
clean up naturally overtime.

Cleanup Approach: A system of 12 nested
injectors was installed in the source area.
Semi-permanent injectors constructed  of
one-inch  diameter PVC  screen  and riser
were installed to allow the controlled injec-
tion of permanganate reagent directly into
the contaminated area. Each injector was
installed with a sand pack to just above the
screen, and grouted to the  surface.
Once the grout set, a charge of permanganate
was pressure-injected into each injector. A 10%
by weight solution of permanganate was  intro-
duced into each injector, with as much volume
as each injector would take, to  a maximum of
100 gallons. The injectors were  then connected
to each other in ranks,  and to a head tank by
PVC piping. Continuous gravity feeding to all of
the injectors was then started. Each injector was
equipped with valves  to control flow, and the
system was kept in balance for about four to five
months. Up to 300 gallons per day of 1-2% solu-
tion  were  fed into the  system during remedia-
tion.

Most of the  injectors were completed above the
water table to avoid drainage of reagent directly
into groundwater without extensive soil contact.
To   control  PCE   that was  mobilized  into
groundwater from the soil source area, a line of
injectors (curtain  wall) was  installed  down
stream.  These  injectors  were operated  at very
low volumes, and controlled based on the results
of a monitoring well immediately downgradient.

Project Time Line:
09/01 - Application of permanganate
01/02 - Post-treatment monitoring

08/02 - Post-treatment monitoring complete
02/03 - NFA Determination letter issued by
Colorado Department of Public Health and En-
vironment

Project Results: One  month into the remedia-
tion process, the PCE concentration had dropped
to 926 (ig/L and decreased further to 48 (ig/L in
about a year. Downgradient PCE concentrations
decreased  from 40  ug/L to  15  ug/L within a
year. Quarterly monitoring showed PCE concen-
trations in source-area  groundwater were  re-
duced by 99% and downgradient concentrations
were  less than the  Colorado  drinking  water
MCL. In February 2003, the State of Colorado
issued a NFA  Determination Approval, stating
that the property could be used for commercial
purposes, and did not pose an unacceptable risk
to human health and the environment.
                                            37

-------
Sources: Colorado Department of Public       Viellenave, J.H., J.P. Lauer, and J.V. Fontana.
Health and Environment. 2003. NFA Ap-       2002.  Using Risk  Based Cleanup  Goals for
proval.  James Viellenave. December  16,       ISCO  of PCE in Vadose Zone Soils Under a
2003.                                        Voluntary Cleanup Program. Paper presented at
                                             IPEC 2002.
E-mail to Raji  Ganguli, Tetra Tech EM,       http://ipec.utulsa.edu/Conf2002/viellenave_lauer
Inc. providing information on the Former        fontana 66.pdf
Cowboy Cleaners Site in Broomfield, Colo-
rado.
                                           38

-------
Dry Clean USA No. 11502, Orlando, Flo-
rida

Technologies: ISCO (hydrogen peroxide),
P&T, SVE

Regulatory Program:  Florida Department
of Environmental Protection's  Dry cleaning
Program

Project Duration: April 1999 to October
2005

Information Last Updated: 2008

Site Information: The Former Dry Clean
USA  operated in a shopping  plaza in Or-
lando, Florida, from 1988 to 1998. Investi-
gations indicated that PCE was released  to
the soil beneath the floor slab of the facility
in the area where the drycleaning machine
was located. Releases also occurred from the
sanitary sewer line.

SVE  and  P&T systems were run between
April 1999 to November 2002 with only 9.8
Ibs of VOCs recovered through SVE and a
negligible   amount  of VOCs  recovered
through P&T.

Contaminants: PCE was detected at  con-
centrations of up to 27,300 (ig/L in ground-
water and 3.9 mg/kg in soil. The  contami-
nant plume extends to about 68-ft bgs and is
800-ft long and 300-ft wide.

Hydrogeology: The site is  underlain by a
slightly silty, fine- to medium-grained  sand
to a depth of 47 ft bgs. This unit is in turn
underlain by a 6-ft-thick, slightly sandy clay
followed by a 20-ft-thick, fine- to medium-
grained sand that is interbedded with clayey
sand.  A 4-ft-thick fine  to coarse sand  with
shell fragments overlays a hard, phosphatic,
limestone  bedrock that occurs 93 to 94 ft
bgs. The depth to groundwater is 8 to 10 ft
bgs.

Project Goals: The goal was to treat PCE to
the Florida MCL of 3 (ig/L for groundwater
and 30 (ig/kg (leachability) for soil.

Cleanup Approach: SVE for soil contami-
nation and P&T for groundwater were suc-
cessful in  reducing groundwater contamina-
tion levels to <10 (ig/L. Rebound did occur
near the source area, so a  1% hydrogen per-
oxide solution was used as a polishing step.

Project Time Line:
4/99 - SVE and P&T systems start
12/01/00-SVE turned off
1/17/01 - P&T system shut down
2/26/01 - P&T system restarted because of
rebound
11/02 - P&T system turned off
10/04/05 - 10/05/05 - Peroxide injections
2/07 - Site Rehabilitation Completion Order
signed

Project Results:  One year of post oxidation
groundwater monitoring showed concentra-
tions of PCE ranging from non-detect to 3
(ig/L.  The Site Rehabilitation Completion
Order was signed February 16, 2007,  and all
wells were abandoned.

Sources: State Coalition for Remediation of
Dry cleaners   profile.   Dry   Clean   USA
#11502. June 2008.
http://www.drvcleancoalition.org/profiles/di
splay.cfm?id=24

Personal communication with William Linn,
May 8, 2007.
                                          39

-------
Naval Submarine Base Kings Bay Site 11,
Camden County, Georgia

Technologies:  P&T,  ISCO  (Fenton's re-
agent), biostimulation, MNA

Regulatory Program: RCRA Corrective
Action

Project Duration: 1993 to present

Project Last Updated: 2004

Site Information: Site 11, the former Cam-
den County Landfill, is  located on Kings
Bay Naval Submarine Base.  The 25-acre site
was used for municipal waste disposal  from
1973 until 1980. Trenches 2-3 m deep  were
excavated, filled with trash, and covered.

Contaminants:  Chlorinated  solvents  that
were disposed in the landfill are the source
of a groundwater contaminant  plume  esti-
mated to be 700-ft  long, 200-ft wide, and
30- to 40-ft deep. Measured concentrations
of the  contaminants of concern ranged  as
high as 8,500 ug/L PCE, 550  ug/L TCE,
1,300 ug/L cis-DCE, and 4,500  ug/L vinyl
chloride. Profiling with direct push equip-
ment  identified  two  localized DNAPL
source areas.

Hydrogeology: Site 11 is underlain by mar-
ginal marine sediments of barrier island and
back-barrier lagoon origin. The most perme-
able sand underlying the site  is between  32
and 42 ft bgs. This permeable  zone is under-
lain and overlain by  a finer-grained sand and
clay unit, which is  characterized by lower
hydraulic conductivity. A layer of organic-
rich sand overlies the  aquifer. As precipita-
tion infiltrates this organic layer, it becomes
anaerobic, thereby forming  a naturally oc-
curring  anaerobic biodegradation  system.
Groundwater  is encountered  at  about 6 ft
bgs. An important feature of the groundwa-
ter  chemistry  is  that  the  sulfate-reducing
conditions  predominate  near the  landfill
while iron-reducing  conditions exist further
downgradient.  The  sulfate reducing condi-
tions favor degradation of PCE, TCE, and
 Organic rich layer at outcrop
                             Courtesy USGS
DCE, while  the  iron-reducing  conditions
favor degradation of vinyl chloride.

Project Goals: The goal of remedial action
at the  landfill was to  reduce contaminant
concentrations in the  groundwater plume to
levels below  the MCLs established by the
Georgia Department  of Natural  Resources
(GDNR).

Cleanup Approach: P&T was  chosen to
contain  and  treat  the  groundwater plume
with UV oxidation. The P&T system, which
was installed  in 1993, was expected to oper-
ate for at least fifty years to meet GDNR's
cleanup goals. This projection was based on
                            Approximate Extent
                            ofpre-1998
                            Contaminant Source
                            Area
  Vinyl Chloride Plume before Cleanup
                            Courtesy: USGS
                                          40

-------
                             Approximate Exlenl
                             of the Fenton's
                             Reagent Treatment
 Vinyl Chloride Plume after Cleanup
 (January 2004)
                             Courtesy: USGS
the high concentrations of chlorinated com-
pounds at the site and their low solubility,
and on P&T performance data.

The July 1998 corrective  action plan called
for containment of the plume  at the Navy
property line. Containment would be facili-
tated with extraction wells at the perimeter
of  the  installation.  The extraction wells
would operate until contaminant concentra-
tions were low enough for MNA to be effec-
tive on any off site contamination.

ISCO was selected to treat total VOCs in the
source area to below 100  ug/L. Since it was
not considered possible to achieve zero lev-
els of contamination in the source area, the
corrective action plan relied on the  reason-
able expectation that after removal of the
source  material, the  downgradient plume
would attenuate. The USGS  used  natural
attenuation software to calculate the levels
of residual contamination in the source area
that would allow downgradient attenuation
to meet the remediation goals. These calcu-
lations provided rational performance  stan-
dards for the source removal contractors.
The treatment area consisted of an estimated
3,000 tons of contaminated soil and 80,000
gallons of contaminated groundwater.
 In November 1998, two extraction wells and
 six process monitoring wells were installed
 along with 23  specially  designed  injection
 wells that were placed in and  around the
 source area.  The monitoring  wells were
 sampled twice  daily and  analyzed for pH,
 specific conductance,  alkalinity, iron, sul-
 fate, sulfide,  dissolved hydrogen,  and dis-
 solved oxygen as well as any change in con-
 taminant concentrations.
Injection Well
                          Courtesy U.S. Navy
 Fenton's  reagent containing 50% hydrogen
 peroxide was injected twice. The first injec-
 tion focused on the central part of the con-
 taminant plume, while the second  focused
 on the  downgradient areas that were  not
 treated during the  first injection. Following
 the second injection,  during which  21 new
 injectors were added, elevated contaminant
 concentrations (1,700 ug/L) were detected
 near one injector indicating the presence of a
 previously  unidentified  source  area.  Thus,
 two more injections were conducted with the
 final injection in November 2001.

 Since  adding Fenton's reagent to an aquifer
 can change both the  geochemistry  and the
 microbial population, monitoring was per-
 formed. Measurements  in one  monitoring
 well showed an increase in dissolved oxygen
 from non-detect before  injection to over 7
 mg/L after injection. Also, microbial activity
 decreased  after each injection. Dissolved
 hydrogen  concentrations indicated that the
 injection of the ferrous iron activator had
                                           41

-------
                       Courtesy: U.S. Navy
shifted the microbial activity from sulfate-
and  iron-reducing  to  a more  purely iron-
reducing environment. To reverse this trend,
biostimulation was conducted by injecting a
solution of emulsified vegetable  oil (35%
soybean oil with lecithin  and 65% water)
into  the aquifer after the  third and fourth
injections  to return the subsurface to an an-
aerobic environment and restore some of the
sulfate-reducing activity that increases PCE
and  TCE  degradation.  Microbial activity
generally rebounded within a few months of
each Fenton's reagent injection.

In all, about 48,000 gallons of 50% hydro-
gen peroxide solution and  a similar volume
of ferrous sulfate catalyst were injected into
the aquifer—principally in the  more  perme-
able  zone between 32 and 42 ft bgs. In addi-
tion, about 25,000 gallons  of the emulsified
soybean oil solution were injected following
the third and  fourth injections of Fenton's
reagent application.
Project Time Line:

1993—Began P&T containment system
November 1998 to February
1999-Performed first ISCO treatment
June 1999 to July 1999-Performed second
ISCO treatment
Fall 1999-Shut down P&T system
July 1999 to January 2001-Performed third
ISCO treatment
November 2001—Performed fourth and final
ISCO treatment
Project Results: Levels of total chlorinated
hydrocarbons in the most contaminated area
decreased from nearly 200,000  ug/L in 1999
to 120  ug/L  in 2002.  As  of 2004, they
ranged from  <1 to 13.9 ug/L. The plume
size shrank by about 70%.

The  USGS  modeling,  supported by field
data, indicated that when the concentrations
of  total  chlorinated   hydrocarbons   in
groundwater  were lowered  to about  100
ug/L,  MNA would complete cleanup of the
plume in about three years. As of May 2003,
no exceedances of MCLs occurred in any of
the offsite monitoring wells, and many of
the onsite monitoring wells had no measur-
able levels of contaminants. As a result, the
P&T system was shut off two  months after
the second ISCO treatment,  and MNA  has
been  implemented as the final corrective
action for the landfill. There was no need for
further treatment with UV oxidation. Shut-
ting down the P&T system slowed the trans-
port  rate of  contaminants  downgradient,
which increased the effectiveness of the bio-
degradation process.

The estimated cost of the remedial action
from  1991  to  1997 was  $9.8  million.  The
estimated cost for the ISCO and biostimula-
tion is approximately $5 million. This repre-
sents a $9 million savings over the estimated
$15 million that the P&T system would have
cost.
                                          42

-------
Sources: Chapelle, F.H. and P.M. Bradley.
1999. Selecting remediation goals by assess-
ing  the  natural  attenuation  capacity  of
ground-water systems.  Proceedings of the
Technical Meeting Charleston, South Caro-
lina. March 8-12, 1999, Volume 3 of 3 Sub-
surface Contamination From  Point Sources,
Water-Resources Investigations Report  99-
4018C.     U.S.     Geological    Survey
http://toxics.usgs.gov/pubs/wri99-
4018/Volume3/kevnote/3102  Chapelle/inde
x.html

Chapelle, F.H., P.M. Bradley, and C.C.  Ca-
sey. 2005. Behavior of a chlorinated ethene
plume following source-area  treatment with
Fenton's reagent. Ground Water Monitoring
& Remediation, Vol. 25 No 2, p 131-141,
Spring

Chapelle,  F.H. and M. Singletary. 2006.
Combining  Source  Area  Treatment with
Monitored Natural Attenuation, NSB Kings
Bay. PowerPoint presentation from Federal
Remediation Roundtable meeting
http://www.frtr.gov/pdf/meetings/may07/cha
pelle presentation.pdf
FRTR. 2000.  In  situ Chemical  Oxidation
Using Fenton's Reagent at Naval Submarine
Base Kings Bay,  Site 11, Camden County,
Georgia. Federal Remediation Roundtable
http://costperformance.Org/pdf/KingsBav.P
DF

Spinner,  J.   2004.   Groundwater  Almost
Clean. The Periscope April 29, 2004
http://www.kingsbavperiscope.eom/stories/0
42904/kin groundwaterOOl .shttnl

NAVFAC SOUTHDIV. Undated. Site  11,
Old Camden County Landfill, Remedial Ac-
tion Operation, Summary Report: Remedial
Action Operation  Optimization. U.S. Navy,
8pp
http://costperformance.org/pdf/KingsBav C
hemOx.pdf
                                          43

-------
Former  Sta-Lube  Site, Rancho  Domin-
guez, California

Technologies:  SVE,  P&T,  large-diameter
auger excavation with offsite disposal, ISCO
(catalyzed  hydrogen  peroxide  to  activate
sodium persulfate)

Regulatory Program: California Regional
Water Quality  Control Board  (RWQCB),
Los Angeles Region

Project Duration: June 2005 to June 2008

Information Last Updated: 2008

Site Information: The former Sta-Lube site
occupies  2.8 acres. From 1968-1986, Sta-
Lube, Inc.  manufactured paint,  varnish  re-
mover, and fuel additives and blended and
packaged hand cleaners, greases, and petro-
leum-based lubricants.

Contaminants: Past industrial activities at
the site used a variety of chemicals, includ-
ing petroleum hydrocarbon derivatives and
solvents  such as methylene chloride. Site
investigations   indicated  that   soil   and
groundwater were contaminated  with vola-
tile organic compounds; methylene chloride
was  the  main contaminant  of concern. A
past  release of methylene chloride  from a
leaking UST caused  extensive  contamina-
tion. In 1995, the dissolved plume measured
200-feet long by 80-feet wide. By 2005, the
size of the plume had been  reduced to 80-
feet long by 30-ft wide, most of which was
under the building.  The highest  concentra-
tion  of methylene  chloride detected in the
groundwater was 2,600,000  ug/L, well ex-
ceeding the 1%  solubility limit of 200,000
ug/L.

A membrane interface probe (MIP) survey
later  indicated  that  methylene  chloride
DNAPL  was  trapped in sandy stringers
within the clayey soil underlying the build-
ing.

Hydrogeology: The site is  located within
the Central Groundwater Basin, which is
part of the Los Angeles Coastal Plain.  The
near-surface sediments at the site are part of
the Bellflower Aquiclude, a portion of the
Recent Alluvium primarily comprising  silts
and clays. These fine-grained sediments are
found beneath the Sta-Lube site to a depth of
approximately 45 feet bgs. The depth to the
water table  is approximately 40 feet  bgs.
Using the MIP,  an 8-foot thick clay zone
with thin sand stringers (4-8 inches)  was
delineated between 40 to 48 feet bgs, while
coarse sand is found from 48 feet to over
130 feet bgs.

The groundwater beneath the Sta-Lube site
correlates regionally with the Gaspur Aqui-
fer. The  bottom of the Gaspur  Aquifer is
approximately 140  feet beneath the  Sta-
Lube site. Beneath this aquifer, several clay-
lens aquitards limit vertical migration of the
contaminant to the Silverado and Sunnyside
Aquifers,  which are  at  depths  of approxi-
mately 450 to 700 feet bgs. These deeper
aquifers are considered  high-quality  drink-
ing water aquifers.

The  California Water  Company has  indi-
cated that the closest active drinking water
well is located 1,750 feet to the southwest of
the Sta-Lube site. The well screen is set at
301 to 650 feet bgs and penetrates the Sil-
verado   and  Sunnyside   Aquifers.   The
groundwater  flow  direction  in  the  upper
saturated  zone is  towards  the  southwest
placing the well downgradient  of the  site.
However, the Sta-Lube  plume is located at
40 to 60 feet bgs, which is the upper 20 feet
of the saturated zone beneath the site.

Project Goals: After 6 years of SVE, P&T,
and a large-diameter auger excavation, the
overall goal of implementing ISCO was to
quickly  attain closure of the site from the
RWQCB. The cleanup  goal  was to attain
concentrations less than  50 ug/L of methyl-
ene chloride in groundwater.

Cleanup Approach: A P&T system  was
operated at the Sta-Lube site starting in 1997
to treat the dissolved-phase plume. The P&T
system operated until 2003. An SVE system
                                          44

-------
supplemented with hot air injection was op-
erated at the site starting in May 2000  and
continuing until October 2001.  Concentra-
tions of methylene chloride in groundwater
from the  pumping  wells  were  below  100
ug/L, and the  soil  and groundwater were
close to attaining closure from the RWQCB.
However, when the systems were turned off,
the concentrations  of methylene chloride
rebounded significantly suggesting presence
ofDNAPL.

A supplemental site investigation conducted
using MIP revealed DNAPL source zones in
sandy stringers trapped within clayey zones
at depths  of 40 to 48 feet. To remove the
DNAPL, these source zones were excavated
to a depth of 48 feet using large-diameter
augers. The excavated soil, which was con-
taminated (266 cubic yards), was staged and
disposed  of offsite.  Despite these efforts,
groundwater contamination levels still re-
mained high (Table  1). Further investigation
revealed methylene  chloride had migrated
into the clayey soil beneath the building and
was slowly seeping  out and contaminating
the groundwater.
Table 1. Groundwater Contaminant
Concentrations Measured June 14, 2004
Contaminant
Acetone
Benzene
Toluene
Bromochloromethane
1,1 -DCA
1,1 -DCE
Trans-l,2-DCE
Bromoform
Dibromochloromethane
Chloroform
Methylene Chloride
1,1,2,2-TCA
Concentration
Range (jig/L)
ND - 220
ND - 6.7
ND-34
ND-110
ND-27
ND-89
ND-73
ND- 16
ND- 11
ND-88
ND - 18,000
ND-25
ND = non-detect

On December  15, 2004, the RWQCB  ap-
proved ISCO using catalyzed hydrogen per-
oxide  activation  of  sodium   persulfate
(Kloziir®) for groundwater remediation.
Activated sodium persulfate is a strong oxi-
dant that creates sulfate radicals, which are
effective in treating  dissolved  recalcitrant
contaminants.  The catalyzed hydrogen per-
oxide (a Fenton's type reaction) attacks con-
taminants directly with the hydroxyl radicals
that are produced. The Fenton's reaction is a
highly exothermic reaction that helps to strip
the sorbed contaminants from the soil  and
convert them to the dissolved phase.

A total of 23 application wells were installed
at the site-16 inside and 7 outside the build-
ing (Figure  l)-with an  estimated radius of
influence of 8  to 12 feet. The target ground-
water remediation zone was 40 to 48  feet
below grade surface.
                                                 Figure 1.  ISCO Application Wells
                                                                       Courtesy: Gary Cronk
Approximately 7,700 gallons of 22%  so-
dium persulfate  solution was injected over
the course of six days. This was followed by
an injection of 12,044 gallons of 17.5%  hy-
drogen peroxide for  14 days to activate  the
persulfate.  Downhole thermocouples moni-
tored the temperature underground to ensure
a temperature  of 120 to 160°F for optimum
generation  of  hydroxyl  radicals with mini-
mal  decomposition of the hydrogen perox-
ide.  Logistical challenges included  the  use
of angled wells to minimize disruption of
business operations  in  the  building   and
safely performing injections inside an active
facility. The reaction of catalyzed peroxide
produces hydroxyl radicals, heat, and oxy-
gen which tend to force treated groundwater
and vapor up to the ground surface via con-
                                           45

-------
duits (e.g., soil crevices, abandoned borings,
utility lines, etc.). Therefore, the flow of the
injectants had to be optimized to control the
reaction.

Project Time Line:

1997-2003—Operation of pump and treat
system to treat dissolved-phase plume.
2000-2001-Operation of SVE and hot air
injection to treat the vadose zone soils.
2003—Large-diameter auger excavation of
DNAPL source area and disposal of con-
taminated soil offsite. Subsequent discovery
of additional DNAPL beneath the building.
December 15, 2004- RWQCB approves use
of ISCO to treat contaminated soil beneath
building and the groundwater contaminant
plume emanating from it.

June 2005—Persulfate and peroxide injected
into treatment area.
November 2005—Cleanup goal of 50 ug/L
methylene chloride is reached.
2005-2008—Quarterly monitoring

June 2008-California RWQCB grants final
closure of site.
Project Results: Monitoring results indi-
cated that ISCO reduced methylene chloride
levels by 94% to 97% within 4 months fol-
lowing treatment and below the 50 ug/L
cleanup goal within 5 months (Figure 2).
The most significant reduction observed was
a decrease from 15,000 to  18 ug/L in one
well. Quarterly monitoring followed and in
June 2008, the site obtained final closure
from the California RWQCB.
100,000 i
10,000
ll.OOO
0
1 100
5 10
<;
^15,000
^/3,200
/ ^V11° 110 140
/ ^NJf " "
*'^WV^V

-^MW-1A
— MW-9A
MW-11
MW-12

flT^IO


Figure 2. Methylene Chloride Concentra-
tions in Groundwater During ISCO
Courtesy: Gary Cronk
Sources: Personal communication with
Gary Cronk, September 18, 2007.
Cronk,  Gary.  2006.   Optimization  of  a
chemical oxidation treatment train process
for groundwater remediation" Presentation
at the Battelle 5th International  Conference
on Remediation of Chlorinated and Recalci-
trant Compounds. May 25, 2006. Monterey,
CA.
http: ll\ agconsultinggroup.com/uploads/Full
Paper - Cronk  Battelle 2006.pdf

California Regional Water Quality Control
Board, Los Angeles  Region.  Letter from
Executive Officer, Jonathan S.  Bishop, to
Judi Proetel of Sta-Lube, Inc.

FMC  Environmental  Solutions.  Klozur™
Resource Center. Project Description In-Situ
Chemical  Oxidation,  Activated  Persulfate
Treatment of Methylene Chloride Chemical
Plant in Los Angeles, CA.
http://www.envsolutions.fmc.com/Portals/
fao/Content/Docs/Remediation%20of%20M
ethvlene%20Chloride%20Plume%
20Using%20H2O2%20Catalvzed%20Persul
fate MECX.pdf
                                          46

-------
Pasley  Solvents   and  Chemicals,  Inc.,
Hempstead, New York

Technologies: SVE, air sparging

Regulatory Program: U.S. EPA Superfund

Project Duration: November 1997 to Au-
gust 2003

Information Last Updated: 2007

Site Information:  Pasley  Solvents  and
Chemicals, Inc., is a former tank farm that
stored oils, solvents, and other chemicals in
above-ground tanks  prior  to  transferring
them to 5 5-gallon drums for delivery to cus-
tomers. The property is about 75 ft wide and
275 ft long. Poor housekeeping  and  spills
have  contaminated  soil  and groundwater
with VOCs and semivolatile organic  com-
pounds (SVOCs).

Contaminants:  The  contaminants of con-
cern at the  site were 1,1-DCA, 1,1-DCE,
trans-DCE,   chloroform,  TCE,  toluene,
chlorobenzene, ethylbenzene, and xylenes.
The  highest concentration of total VOCs
(mostly  PCE  and   trans-\,2-DCE)   and
SVOCs detected in surface  soil was 603
mg/kg  and 204  mg/kg,  respectively.  The
maximum concentration  of  total VOCs
measured  in groundwater  was  37  mg/L
(mostly trans-].,2-DCE). The highest TCE
concentration was  320  ug/L, well higher
than the 5 ug/L MCL. The 60-ft by 400-ft
groundwater contaminant plume extended
beyond the site boundary.

Hydrogeology: The site  is underlain by 60
ft of glacial  outwash deposits consisting of
unconsolidated sand and gravel. These  de-
posits are  underlain by the Magothy Aqui-
fer, a 400- to 500-ft thick formation consist-
ing of fine sand with discontinuous layers of
silt and clay.  Public water supply wells for
the nearby Town of Hempstead draw water
from the Magothy Aquifer.
Project Goals: The project goals were to
clean up the site to residential risk levels and
MCLs.

Cleanup Approach: Chemical source areas
in the vadose zone were treated with SVE,
and the groundwater plume was treated us-
ing air sparging wells to encourage aerobic
bioremediation and volatilization.

For the onsite contamination, 19 2-inch PVC
air sparging wells screened 50 to 52 ft bgs;
eight shallow  2-inch  PVC  SVE  wells,
screened  5 to  10 ft bgs; eight 4-inch PVC
SVE wells, screened 15 to 20 ft bgs; and
five monitoring well clusters were installed.
To treat the offsite plume, 15 2-inch PVC air
sparging wells, screened 50 to 52 ft bgs; five
2-inch PVC SVE wells, screened 15 to 20 ft
bgs; and six monitoring-well clusters were
installed. Collected vapors were treated with
activated carbon.  In accordance with the
Consent  Decree and  O&M  Manual, the
O&M  period was  to  be performed  for a
minimum of  five years  followed by post-
remediation monitoring.

Project Time Line:
6/97 - Construction of the remedy begins
10/97 - Remedy construction completed

11/97 - Remedy becomes operational
10/02 - SVE/AS system shut down to test
for rebound
July 2000 and April 2003 - Confirmation
soil sampling

2004 - Remediation equipment removed
from site
2004-2006 - Semi-annual groundwater
monitoring
2006 - NFA discontinue groundwater moni-
toring

Project Results: Soil confirmation sampling
indicated that residential cleanup values (all
under 1 mg/kg for the contaminants of con-
cern) were  met.  Concentrations  of total
VOCs in monitoring wells also met ground-
                                          47

-------
water treatment goals. Within two years of
air  sparging  operation,  concentrations  of
total  VOCs  in  onsite  monitoring  wells
ranged from  non-detect to 4 (ig/L, which
was   down  from  original  concentrations
ranging as high as 7,496 ug/L.  After five
years,  concentrations in offsite monitoring
wells were all below MCLs for  12 straight
quarters.

Sources:  Personal  communication  with
Sherrel Henry, U.S. EPA Region  2, April 2,
2007.
U.S. EPA. 1992. Record of Decision: Pasley
Solvents  &  Chemicals,  Inc.   EPA  ID:
NYD991292004,  OU 01  Hempstead, NY.
http://www.epa.gov/superfund/sites/rods/full
text/10292171.pdf

U.S. EPA. 2004. Five-Year Review Report
Pasley Solvents and Chemical Site Town of
Hempstead  Nassau  County, New  York.
http://www.epa.gov/superfund/sites/fivevear
/F04-02026.pdf
                                          48

-------
            Appendix B

 Suspected DNAPL Thresholds Based
On Solubility Relative to One Percent of
         Aqueous Solubility
                 49

-------
                    Suspected DNAPL Thresholds Based on Solubility
                          Relative to 1% of Aqueous Solubility
Chlorinated Solvent (CAS Number)
PCE (127-18-4)
TCE (79-0 1-6)
cw-DCE( 156-59-2)
frans-l,2-DCE (156-60-5)
,1-DCE (75-35-4)
,1,1-TCA (71-55-6)
,1,2-TCA (79-00-5)
,2-DCA (107-06-2)
,1-DCA (75-34-3)
Carbon Disulfide(75-15-0)
Carbon Tetrachloride (56-23-5)
Chlorobenzene (108-90-7)
Chloroform (67-66-3)
Hexachlorobutadiene (87-68-3)
Methylene Chloride (75-09-2)
1,1,2-Trichlorofluoromethane (75-69-4)
1 , 1 ,2-Trichlorotrifluorethane (76-13-1)
Aqueous Solubility
Gig/L@20°C)
150,000
1,100,000
3,500,000
600,000
400,000
1,360,000
4,500,000
8,690,000
5,500,000
2,100,000
800,000
500,000
8,000,000
2,550
20,000,000
1,100,000
200,000
1% of Aqueous Solubility
Gig/L@20°C)
1,500
11,000
35,000
6,000
4,000
13,600
45,000
86,900
55,000
21,000
8,000
5,000
80,000
25
200,000
11,000
2,000
Notes:
    1. The source for all Aqueous Solubility and 1 Percent Rule except 1,2 cis DCE: Cohen, R.
      and J. Mercer. 1993. DNAPL Site Evaluation, EPA 600/R-93/022.
      http://www.cluin.org/download/contaminantfocus/dnapl/600r93022.pdf

    2. Source for 1,2-cis DCE solubility datum: Howard, P. (ed.).1989. Handbook of Environ-
      mental Fate and Exposure Data for Organic Chemicals. Lewis Publishers.

    3. DCA (dichloroethane), DCE (dichloroethene) PCE (tetrachloroethene), TCA (trichloro-
      ethane), TCE (trichloroethene)
If the chemicals are part of a mixture, then their solubility will be less than the solubility of the
pure substances. The effective solubility of each component can be estimated using Raoult's
Law and is equal to the mole fraction of the component in the NAPL times its pure form solubil-
ity (Cohen and Mercer 1993).
                                          50

-------
       Appendix C




Acronyms and Abbreviations
            51

-------
(ig/L       micrograms per liter
bgs        below ground surface
B(a)P      benzo(a)pyrene
B(a)P-eq   benzo(a)pyrene equivalent
CEAM     Conceptual Environmental Assessment Model
COC       certificate of completion
DCE       dichloroethene
DNAPL    dense non-aqueous phase liquid
DTSC      Department of Toxic Substances Control
EPA       U.S. Environmental Protection Agency
ERH       electrical resistive heating
ft          foot or feet
ft2         square foot or feet
ft3         cubic foot or feet
gpm       gallons per minute
GW       groundwater
HRC®      Hydrogen Release Compound
1C         institutional controls
IDEM      Indiana Department of Environmental Management
IEPA      Illinois Environmental Protection Agency
ISTD      in situ thermal desorption
L          liter
MADEP   Massachusetts Department of Environmental Protection
MC       methylene  chloride
MCL      maximum contaminant level (EPA)
mg/kg      milligrams per kilogram
mg/L      milligrams per liter
MGP      manufactured gas plant
MNA      monitored natural attenuation
ND        non-detectable
NFA       no further action
NFR       no further remediation
NPL       National Priorities List
P&T       pump and treat
PAH       polycyclic  aromatic hydrocarbon
PCE       tetrachloroethene
REEL      risk-based exposure level
RCRA     Resource Conservation and Recovery Act
SCE       Southern California Edison
scfm       standard cubic feet per minute
SVE       soil vapor extraction
SVOC     semivolatile organic compound
TACO     tiered approach to correction action objectives
1,1,1-TCA  trichloroethane
TCE       trichloroethene
TCEQ      Texas Commission on Environmental Quality
TPH       total petroleum hydrocarbons
TRRP      Texas Risk Reduction Program
VC        vinyl chloride
VOC       volatile organic compound
yd3        cubic yard
                                         52

-------