FEASIBILITY STUDY REPORT
              STANDARD CHLORINE OF DELAWARE SITE
                       OPERABLE UNIT 3 (OU-3)
                  NEW CASTLE COUNTY, DELAWARE
                               Prepared for:
                    U.S. Environmental Protection Agency Region 3
                              1650 Arch Street
                            Philadelphia, PA 19103
                        EPA Contract Number: EP-S3-07-05
                      Work Assignment Number: 002RICO03H6
                                July 2009
vHGL
              InC    1835 Market Street, Suite 1210 Philadelphia, PA 19103
             ^^^«    Phone: (215)636-0667 Fax: (215)636-0668
                              www.hgl.com

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                            TABLE OF CONTENTS
EXECUTIVE SUMMARY	ES-1

1.0   INTRODUCTION	1-1
      1.1    PURPOSE AND ORGANIZATION OF THE REPORT	1-1
      1.2    SITE BACKGROUND	1-2
            1.2.1  Site Location and Description	1-2
            1.2.2  Site Operational History	1-3
      1.3    ENVIRONMENTAL SETTING	1-4
            1.3.1  Site Topography and Surface Drainage	1-4
            1.3.2  Geology	1-4
            1.3.3  Hydrogeology	1-5
      1.4    PREVIOUS SITE INVESTIGATIONS AND REMEDIAL RESPONSES	1-8
            1.4.1  Introduction	1-8
            1.4.2  Catch Basin 1 Release and Related Remedial Activities	1-9
            1.4.3  1981 Release and Related Remedial Activities	1-9
            1.4.4  1986 Release and Related Remedial Activities	1-10
            1.4.5  1991-1992 Remedial Investigation and Feasibility Study	 1-10
            1.4.6  1999 Initial PRP Remedial Design Sampling	 1-12
            1.4.7  2002-2004 Remedial Design and Remedial Investigation Activities .. 1-12
            1.4.8  Interim Groundwater Remedy	 1-14
            1.4.9  Ongoing Sampling Activities	 1-15
      1.5    NATURE AND EXTENT OF CONTAMINATION	 1-15
            1.5.1  On Facility Contamination	 1-15
            1.5.2  Northern Area Contamination	 1-20
      1.6    CONTAMINANT FATE AND TRANSPORT	 1-20
            1.6.1  Air Migration	 1-20
            1.6.2  Surface Runoff and Migration	 1-21
            1.6.3  Groundwater Migration	 1-22
      1.7 SUMMARY OF BASELINE RISK ASSESSMENT	 1-22
            1.7.1  Human Health Assessment	 1-22
            1.7.2  Ecological Risk Assessment (Surface Soil)	 1-24

2.0   REMEDIAL ACTION OBJECTIVES	2-1
      2.1    REMEDIAL ACTION  OBJECTIVES	2-1
      2.2    APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS . 2-1
      2.3    DETERMINATION OF REMEDIATION GOALS AND  DESCRIPTION
            OF CONTAMINATED MEDIA	2-8
            2.3.1  Derivation of Risk-Based Preliminary Remediation Goals	2-8
            2.3.2  Volume Estimates	2-13
                                 U.S. EPA Region 3
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                       TABLE OF CONTENTS (continued)
3.0   IDENTIFICATION AND SCREENING OF TECHNOLOGY TYPES AND
      PROCESS OPTIONS	3-1
      3.1    GENERAL RESPONSE ACTIONS	3-1
      3.2    IDENTIFICATION AND SCREENING OF POTENTIALLY
            APPLICABLE TECHNOLOGIES	3-2
      3.3    EVALUATION OF POTENTIAL REMEDIAL TECHNOLOGIES	3-2
            3.3.1  No Action	3-2
            3.3.2  Institutional Controls	3-3
            3.3.3  Containment	3-4
            3.3.4  Treatment	3-8
            3.3.5  Removal and Disposal TPOs	3-18
            3.3.6  Monitoring of Site Conditions and Contaminant Levels	3-21
      3.4    SUMMARY OF TREATMENT TECHNOLOGIES AND SELECTION
            OF REPRESENTATIVE PROCESS OPTIONS	3-21

4.0   DEFINITION AND SCREENING OF REMEDIAL ALTERNATIVES	4-1
      4.1    DEFINITION OF ALTERNATIVES	4-1
            4.1.1  Alternative 1A:  No Action	4-1
            4.1.2  Alternative IB:  Limited Action	4-1
            4.1.3  Alternatives 2A - 2D: Containment	4-2
            4.1.4  Options for Excavated Soil from Surface Cap Construction	4-6
            4.1.5  Alternatives 3A - 3D:  In Situ Treatment	4-9
      4.2    SCREENING OF REMEDIAL ALTERNATIVES	4-12

5.0   DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES	5-1
      5.1    EVALUATION CRITERIA	5-1
            5.1.1  Overall Protection of Human Health and the Environment	5-1
            5.1.2  Compliance with Applicable or Relevant and Appropriate
                  Requirements	5-2
            5.1.3  Long-term Effectiveness and Permanence	5-2
            5.1.4  Reduction of Toxicity, Mobility or Volume	5-2
            5.1.5  Short-Term Effectiveness	5-2
            5.1.6  Implementability	5-2
            5.1.7  Cost	5-2
            5.1.8  State Acceptance	5-3
            5.1.9  Community Acceptance	5-3
      5.2 DEFINITION AND INDIVIDUAL ANALYSIS OF ALTERNATIVES	5-3
            5.2.1  Alternative 1A: No Action	5-3
            5.2.2  Alternatives 2A, 2B, and 2C: Common Elements	5-4
            5.2.3  Alternative 2A: Surface Cap	5-5
            5.2.4  Alternative 2B: Surface  Cap with Soil Vapor Extraction	5-11
            5.2.5  Alternative 2C: Surface  Cap with In Situ Thermal Desorption	5-15

                                U.S. EPA Region 3
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                      TABLE OF CONTENTS (continued)
6.0    COMPARATIVE ANALYSIS OF ALTERNATIVES	6-1
      6.1   OVERALL PROTECTION OF HUMAN HEALTH AND THE
           ENVIRONMENT	6-1
      6.2   COMPLIANCE WITH ARARS	6-1
      6.3   LONG-TERM EFFECTIVENESS AND PERMANENCE	6-1
      6.4   REDUCTION OF TOXICITY, MOBILITY OR VOLUME	6-2
      6.5   SHORT-TERM EFFECTIVENESS	6-2
      6.6   IMPLEMENTABILITY	6-3
      6.7   COST	6-3
      6.8   STATE AND COMMUNITY ACCEPTANCE	6-4
      6.9   PREFERRED ALTERNATIVE	6-4

7.0    REFERENCES	7-1
                           LIST OF APPENDICES
Appendix A  PRO Detail Tables
Appendix B  SCO NPDES Permit Equivalence Documentation from DNREC
Appendix C  Remedial Technology Cost Estimates
           •  Appendix C-l - Surface Cap (Multilayer)
           •  Appendix C-2 - Surface Cap (Cement)
           •  Appendix C-3 - Surface Cap (Asphalt)
           •  Appendix C-4 - Soil Vapor Extraction
           •  Appendix C-5 - In Situ Thermal Desorption
                               U.S. EPA Region 3
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                                  LIST OF TABLES
Table 2.1     Applicable or Relevant and Appropriate Requirements (ARARs) for Standard
              Chlorine of Delaware Operable Unit 3
Table 2.2     On Facility Contaminants of Concern and Preliminary Remediation Goals for
              Standard Chlorine of Delaware Operable Unit 3
Table 2.3     Off Facility Contaminants of Concern and Preliminary Remediation Goals for
              Standard Chlorine of Delaware Operable Unit 3
Table 2.4     Estimated Extent of Site Contamination for Standard Chlorine of Delaware
              Operable Unit 3
Table 2.5     Estimated Extent of Site Dioxin Contamination for Standard Chlorine of
              Delaware Operable Unit 3

Table 3.1     Identification and Preliminary Screening of Soil and Soil Gas Technologies For
              Standard Chlorine of Delaware Operable Unit 3
Table 3.2     Evaluation and Screening of Technology Process Options (TPOs) for Standard
              Chlorine of Delaware Operable Unit 3

Table 4.1     Summary of Remedial Alternatives for Standard Chlorine of Delaware Operable
              Unit 3
Table 4.2     Summary of Remedial Alternatives for Standard Chlorine of Delaware Operable
              Unit 3

Table 5.1     Individual Evaluation of Remedial Alternatives for Standard Chlorine of
              Delaware Operable Unit 3

	LIST OF FIGURES	

Figure 1.1    Site Location
Figure 1.2    Site Layout
Figure 1.3    Approximate Extent  of OU-3
Figure 1.4    Soil and Soil Gas Sampling Locations

Figure 2.1    Locations of Samples with Contaminant Concentrations Exceeding PRGs
Figure 2.2    Locations of Samples with Dioxin Concentrations Exceeding PRGs

Figure 4.1    Projected Extent of Surface Capping and Treatment Areas

Figure 5.1    Typical Multilayer Cap Design Schematic
Figure 5.2    Typical Asphalt and  Concrete Cap Schematic
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                   LIST OF ACRONYMS AND ABBREVIATIONS
AE          assessment endpoint
amsl         above mean sea level
ARAR       applicable or relevant and appropriate requirements

bgs          below ground surface
BLRA       Baseline Risk Assessment
BTAG       Biological Technical Advisory Group
BTEX       benzene, toluene, ethylbenzene, and xylene
BTF         biotransfer factor

CAA         Clean Air Act
CCR         Certified Construction Reviewer
CERCLA    Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS    Comprehensive  Environmental  Response,   Compensation,   and   Liability
             Information System
COC         chemicals of concern
COPC       chemicals of potential concern
CTE         central tendency exposure
CWA        Clean Water Act

DDD         dichlorodiphenyldichloroethane
DDE         dichlorodiphenyldichloroethylene
DDT         dichlorodiphenyltrichloroethane
DNAPL      dense non-aqueous phase liquid
DNREC      Department of Natural Resources and Environmental Control
DOT         Department of Transportation
DRBC       Delaware River Basin Commission
DRGHC      Delaware Regulations Governing Hazardous Substance Cleanup
DRGHW     Delaware Regulations Governing Hazardous Waste
DSWA       Delaware Solid Waste Authority

Eco-SSL      Ecological Soil Screening Level
EPA         U.S. Environmental Protection Agency
EPC         exposure point concentration
ER          electrical resistivity
ERT         emergency response team
ET          evapotranspiration

FFS         Focused Feasibility Study
FML         flexible membrane liner
FRTR       Federal Remediation Technologies Roundtable
FS          Feasibility Study

GAC         granular activated carbon
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	LIST OF ACRONYMS AND ABBREVIATIONS (continued)


GETS       groundwater extraction and treatment system
GRA        General Response Actions

HI          hazard index
HGL        HydroGeoLogic, Inc.
HHRA       Human Health Risk Assessment
HRS         Hazardous Ranking System
HSCA       Hazardous Site Cleanup Act

1C          institutional control
IGR         Interim Groundwater Remedy
ISCO        in situ chemical oxidation
ISTD        in situ thermal desorption
ITRC        Interstate Technology and Regulatory Council

LDR        land disposal restrictions
LOAEL      lowest observed adverse effect level
LTTD       low temperature thermal  desorption

ME         measurement endpoint
mg/kg       milligrams per kilogram
MPRSA      Marine Protection, Research, and Sanctuaries Act

NAPL       non-aqueous phase liquid
NCP        National Contingency Plan
NOAEL      no observed adverse effect level
NPDES      National Pollutant Discharge Elimination System
NPL         National Priorities List

O&M        operation and maintenance
ORNL       Oak Ridge National Laboratory
OU         Operable Unit

PAHs        polycyclic aromatic hydrocarbons
PCBs        polychlorinated biphenyls
PCE         tetrachloroethene
PID         photoionization detector
PPE         personal protective equipment
PRG         Preliminary Remediation Goal
PRP         potentially responsible party

RA         Remedial Assessment
RBC         risk based concentration
RAGS       Risk Assessment Guidance for Superfund
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	LIST OF ACRONYMS AND ABBREVIATIONS (continued)


RAO        Remedial Action Objectives
RCRA       Resource Conservation and Recovery Act
RD          Remedial Design
RFH        radio frequency heating
RGO        Remedial Goal Objectives
RI           Remedial Investigation
RME        reasonable maximum exposure
ROD        Record of Decision

SARA       Superfund Amendments and Reauthorization Act
SB          soil boring
SCO        Standard Chlorine of Delaware Site
SDWA       Safe Drinking Water Act
SSL         Soil Screening Level
SVE        soil vapor extraction
SVOCs       semivolatile organic compounds

TAL        Target Analyte List
TBC        to be considered
TCDD       2,3,7,8-tetrachlorodibenzo-p-dioxin
TCE        trichloroethylene
TCL        Target Compound List
TEQ        Toxicity Equivalent
THQ        target hazard quotient
TOC        total organic carbon
TPO        Technology Process Option
TRV         toxicity reference value
TSCA       Toxic Substances Control Act
TSSA       temporary soil staging area

USGS       U. S.  Geological Survey

VOCs       volatile organic compounds

WWTP       wastewater treatment plant
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                     FEASIBILITY STUDY REPORT FOR
               STANDARD CHLORINE OF DELAWARE SITE
                          OPERABLE UNIT 3 (OU-3)
                    NEW CASTLE COUNTY DELAWARE
EXECUTIVE SUMMARY
This Feasibility Study (FS) Report has been developed for Operable Unit 3  (OU-3) of the
Standard Chlorine of Delaware (SCD) Site under Contract Number EP-S3-07-05 with Region 3
of the U.S. Environmental Protection Agency (EPA).

The purpose of this FS Report is to develop and evaluate  remedial alternatives that may  be
feasible for addressing potential risks to the  human health and the environment posed  by
contaminated soils and soil gas at the SCD site.  This FS was conducted in accordance with the
National Contingency  Plan  (NCP)  and the current  USEPA Superfund guidance, using the
following approach:
   1)  Site history and setting, as well as current site characteristics, were summarized.
   2)  Remedial action objectives were established,  including  identification of applicable  or
       relevant  and appropriate  requirements  (ARARs). Site-specific Preliminary Remedial
       Goals (PRGs) were developed, and the areas and volumes of soil requiring remediation
       were estimated.
   3)  Technologies with the potential to remediate soil and soil gas at the site were identified
       and screened.
   4)  The  technologies retained after the initial screening were assembled into  remedial
       alternatives, which were then evaluated to identify the most promising alternatives for
       the site contamination.
   5)  Detailed analysis of the remedial  alternatives  retained  in  the previous step  was
       conducted.
   6)  Remedial alternatives  retained  for the detailed   analysis  were  summarized  and
       compared.
   7)  Recommendations were made for the final alternative selection.

SUMMARY OF THE SITE CONDITIONS AND HISTORY

The  SCD  Site  is located on  Governor Lea Road near the intersection with River Road,
approximately three miles northwest of Delaware City in New Castle  County, Delaware.  It is
surrounded by a mixture of industrial facilities,  farm  land,  and  undeveloped properties. There
are residential and commercial properties located to the north and west within one mile of the
facility.

The SCD facility was built in 1965  on approximately  46 acres of farmland purchased from the
Diamond Alkali Company.  Chlorinated benzene compounds were  manufactured at the SCD

                                  U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware

facility from 1966 until its closure in May  2002.  In addition,  chlorinated nitrobenzene was
manufactured from the expansion of the SCD Facility  in the early 1970s until the late 1970s. In
December of 1998, SCD was sold to Charter Oak Partners, which reorganized the company as
Metachem Products,  LLC (Metachem).   SCD and Metachem have been identified as PRPs.
Metachem closed the facility on May 4, 2002 and abandoned the SCD Site on May 14, 2002
after declaring bankruptcy.  The EPA and the Delaware Department of Natural Resources and
Environmental Control (DNREC) have been cooperating since then to implement emergency
cleanup and remedial actions while developing an approach for the long-term rehabilitation of
the SCD Site.

Following the 1981 release of approximately 5,000 gallons of chlorobenzene  during tank car
loading activities, the EPA conducted an initial site inspection and a Preliminary Assessment of
the SCD Site. The results  of these investigations were  used to assemble a Hazard Ranking
System (HRS) package that resulted in addition of SCD Site to the National Priorities List
(NPL) on July 22, 1987. Prior to the site's addition to  the NPL, a  1986 tank collapse, and
resulting  damage to  surrounding  tanks,   released  approximately  569,000  gallons   of
dichlorobenzenes and trichlorobenzenes.   This release impacted portions of the facility as well
as the  underlying groundwater, drainage  pathways, the  surrounding wetlands, and Red Lion
Creek.  The initial Remedial Investigation (RI) and FS, conducted by  SCD to address the spill
pathways, groundwater,  and  off-site contamination, were completed  in 1992  and  1993,
respectively.

A Record of Decision (ROD) for the SCD Site  groundwater and  spill  pathway soils and
sediments was completed on March 9,  1995.  An  Administrative  Order for remedial design
(RD) and remedial action (RA) was signed on May 30, 1996. To reduce/eliminate the flow of
groundwater contamination to Red Lion Creek, EPA constructed the Interim  Groundwater
Remedy (IGR) in 2006/2007. The IGR includes a subsurface containment barrier (installed to
an average depth of 70 feet around the majority of the upland portion of the SCD Site) and a
groundwater extraction and treatment system (GETS). The GETS is  being used to lower the
groundwater elevation within the barrier  and limit/prevent  the spread of contamination from
the impacted Columbia Aquifer to the underlying Potomac Aquifer.
Other releases, site investigations and remedial responses known to have occurred at the SCD
site include:
   •   Releases from Catch Basin 1  (discovered in 1976)  and related response activities;
   •   1999 Initial PRP Remedial Design Sampling conducted by SCD; and
   •   2002-2004 Remedial Design and  Remedial Investigation Activities including  human
       health and ecological Baseline Risk Assessment for the site.

Of the  approximately 65 acres that  make  up the SCD Site,  approximately 25  acres  are
surrounded by a fence and form the footprint of the former SCD/Metachem manufacturing
facility (facility). The facility area is strewn with a great  deal of concrete and  other debris
including remnants of containment structures and portions of the former facility's wastewater
treatment plant (WWTP).  The land between the former  facility and the Red  Lion Creek
remains undeveloped with the exception of gravel roads (single lane), a sedimentation basin,
                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

the temporary soil storage area (TSSA),  IGR components, and other features constructed as
part of past remedial and monitoring activities.  This area was wooded until the construction of
the containment barrier, when the area was bulldozed by the subcontractor who constructed the
containment barrier. Consequently,  only  the area  outside the the containment barrier and a
small area around the waste sedimentation basin remain wooded.

OPERABLE UNIT 3 DESCRIPTION

Operable Unit 3,  as covered by this  FS, includes  the vadose zone soil  and soil gas in the
following areas:
    •   On Facility area including the portion of the  site within the former facility fence line.
    •   Northern Area located  between  the former  facility's northern  fence line and the
       southern side of the sedimentation pond.

On Facility Area
The On Facility area encompasses approximately 25 acres and includes the following features
that have been identified through sampling or historical knowledge as known or suspected "hot
spots" of contamination:
    •   Polychlorinated biphenyl (PCB) concentration area (where off-specification  product was
       handled)
    •   Catch basin #1
    •   Former rail siding and loading area
    •   Warehouse  and the area to the north of the warehouse
    •   1986 tank collapse area
    •   Facility storm drains
    •   Drum cleaning area
    •   Northern end of eastern drainage ditch
    •   Northeast tank farm
    •   Former WWTP
    •   Process area

Northern Area
Most of the sampling conducted outside of the facility fence line included  areas not addressed
by this FS. Therefore, there  are limited data available to characterize the nature and extent of
contamination found in  the Northern  Area.  Drum remnants  and  solidified  puddles  of
chlorobenzenes  were  found  near  the  northern  border  of  the  On Facility   area  during
construction of the Western  Stormwater  Basin.  Because the contamination related to these
discoveries was not delineated during these construction activities, there is a concern that this
apparent dumping area might extend northward beyond the former facility fence line.

During  the 2004 RI,  soil was sampled  from multiple depths at three locations within the
Northern Area.  Six chlorobenzene compounds were detected  at relatively low concentrations
(total concentration  of 2.06  mg/kg) in a  surface  sample collected from one  of the three
locations (NESB-28) in this area.  Benzene was detected (at concentrations of 140 /tg/kg and
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware

33 /tg/kg) in two samples collected from depths of 50 ft or more below ground surface (bgs).
No other contaminants of concern (COCs) were detected in any samples collected from these
locations.  No dioxin or active soil gas samples were collected from this area. Passive soil gas
samplers that were deployed in this area exhibited no or relatively low levels of contaminants.

REMEDIAL ACTION OBJECTIVES AND ARARs

The Comprehensive  Environmental  Response, Compensation, and Liability Act (CERCLA)
requires that selected remedial actions attain a degree of cleanup that ensures the protection of
human health and the environment.  Selected remedies must  also comply with the substantive
requirements of all  applicable  or relevant  and  appropriate requirements (ARARs).   The
following  Remedial Action Objectives (RAOs) for the soil and soil gas at the SCD site are
generic goals that have been  developed to achieve protection of human health and  the
environment:

RAOs for Human Health;
    •   Prevent  exposure to non-carcinogens in the  soil and soil gas  at concentrations that
       would result in a target  organ HI greater  than 1 via the potential exposure routes of
       inhalation, ingestion and  dermal contact.
    •   Prevent  exposure to carcinogens at concentrations  that would  result in  a cumulative
       cancer risk in excess of  IxlO"5 (1E-05) via the potential exposure routes of inhalation,
       ingestion, and dermal contact.

RAOs for Environmental Protection;
    •   Prevent  risks  to ecological  communities  exposed  directly  to the  soil COCs and
       indirectly via bioaccumulation of soil COCs in plants and earthworms.

RAOs for Limiting Further Migration of Contaminants;
    •   Minimize the  further spread of contamination via any  of the following major migration
       pathways:
       0   Soil to groundwater
       0   Soil to surface water
       0   Soil to sediment
       0   Soil to air.

To ensure that the selected remedy  would also meet the requirements of federal and  state
regulations  and  guidance,  a  comprehensive review  of these documents  was performed  to
identify ARARs for OU-3.   These ARARs were used in the development of the Preliminary
Remedial  Goals  (PRGs)   and  in the  development  and screening  of potential  remedial
alternatives for OU-3.

PRELIMINARY REMEDIAL  GOALS

PRGs protective of both human health and environment were developed for all  COCs in the
soil and soil gas (those chemicals that were determined to pose unacceptable human health or

                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
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ecological risks in the BLRA). Separate PRGs were calculated for the On Facility area and the
area outside the facility fence line. The  lowest of the ecological and human health risk PRGs
was retained as  the final PRO for each COC in each medium in each area.

PRGs based  on human health risk were calculated for each medium of concern and COC
identified  in the BLRA  and RI.  The site  receptors considered  were  trespasser/visitor,
residential, industrial worker, and construction worker.   Media  were combined for a total
target risk when one  receptor would be exposed to both media (soil  and  soil  gas). For
carcinogens,  PRGs  were calculated for  two  target cancer  risks.   The first target cancer risk
was 10~6 for each COC.  The second target risk was developed to result in a total cancer risk of
10~5 across all COCs and all media.   For this  calculation, the target risk for each COC was
determined by dividing  10~5 by the number of carcinogenic COCs within  each medium.  The
10~5 target total  risk was used as a maximum allowable total risk level in  accordance  with the
DRGHSC.

For non-carcinogens, the target hazard index  (HI) of 1 was  divided by the number of chemicals
in soil and soil  gas that affected the same target organ to determine  the target hazard  quotient
(HQ) for the individual COCs.

Once the target risks and HQs were calculated for the COCs,  PRGs were derived from the
exposure point concentrations (EPCs) for each chemical and corresponding site risks presented
in the BLRA  by solving the following equation for the PRG:

                  EPCI (Site Risk or HQ)  =  PRG I (Target Risk or HQ)

The PRG calculated using the carcinogenic 10~6 risk level was compared to the  PRG for an HI
of 1, and the lower of these two PRGs was selected as the minimum end of the PRG range for
that chemical, medium, and receptor.  Similarly, the  PRG calculated using the  carcinogenic
10~5 risk level was compared to the PRG at the HI of 1, and the lower of the  two became the
maximum end of the PRG range for that  chemical, medium, and receptor.

To develop PRGs for ecological risk, the risks and routes of exposure outlined in the BLRA
were used as a  starting point.  For OU-3, the only pertinent  receptors are terrestrial receptors
because this OU does not include any aquatic habitat.  To develop ecological PRGs for surface
soil that are protective of terrestrial  receptors  the following assessment endpoints (AEs) and
measurement endpoints (MEs) from the BLRA were considered.
   •  AES - Protection of nutrient cycling and terrestrial invertebrates
   •  AE4 - Protection of herbivorous wildlife
   •  AE6 - Protection of terrestrial vermivorous wildlife
   •  ME3.1  - Compare surface soil concentrations  to those  known  to adversely  affect
      nutrient  cycling and terrestrial invertebrates
   •  ME4.1 - Estimate food chain exposure for terrestrial herbivores  and  compare to no
      observed adverse effects  level (NOAEL)  and lowest observed adverse  effects level
      (LOAEL) toxicity reference values
                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                       Delaware

   •   ME6.1 -  Estimate  food  chain  exposure for terrestrial vermivores and compare to
       toxicity reference values (NOAELs and LOAELs).

To evaluate potential effects to nutrient cycling and terrestrial invertebrates, maximum detected
concentrations of the chemicals  identified in the BLRA as  posing  a potential  risk  were
compared to the Ecological Soil Screening  Level (Eco-SSL) for terrestrial invertebrates, the
Eco-SSL  for plants,  the  Oak  Ridge  National  Laboratory  (ORNL)  benchmark  value for
earthworms, the ORNL benchmark value for soil microorganisms/microbial processes, and the
ORNL benchmark value for plants. No quantitative evaluations were performed, and no PRGs
developed, for benzene, DDD, DDE, DDT, 2-methylphenol,  and thallium due to the lack of
benchmark values.

For terrestrial herbivores  and vermivores,  the  food chain model, toxicity reference values
(TRVs), and biotransfer factors (BTFs)  presented in the BLRA were used to calculate the soil
concentration that would result in an HQ of 1 for the NOAEL and LOAEL.  The NOAELs
were then selected as the PRGs for these receptors.

These analyses were based primarily on OU-3 soil and soil gas data and information presented
in the August 2007  RI Report, 2003 Soil/Sediment Design Comparison Study,  and the August
2007 Baseline Risk Assessment (BLRA) Report.  It should be noted that  PRGs for  the Northern
Area were developed using Off Facility data from the RI.   While these Off  Facility data
include samples from the Northern Area, additional samples  from other portions  of the site
also are included.  It is  expected that these  PRGs will be protective of human health and the
environment  in the Northern Area.  However,  if delineation  sampling  conducted in the
Northern Area as part of an RD for  the site indicates  otherwise, these PRGs will need to be
revisited.

SOIL VOLUME  CALCULATION

To determine the volume of soil requiring remediation, concentrations of COCs in soil and soil
gas samples in the  RI Report (Black & Veatch, 2007) were compared to the corresponding
PRGs developed as part  of this FS. Locations where COCs were detected at concentrations in
excess  of the PRGs were included  in the area requiring remediation.

In determining  the  volumes  of soil  requiring remediation to  address  soil risks,  data  from
samples collected  from the top 12 feet bgs (the maximum depth to which construction  activities
would  be expected to proceed) were compared to the human-health related PRGs.  Data from
samples collected in the 0  to 2 ft bgs depth interval  were compared  to ecologically driven
PRGs and human-health related PRGs.  For purposes of the soil volume calculation only, the
vertical depth of the soil contamination in excess of PRGs was therefore limited to 12 feet bgs
for human health driven PRGs  and 2 ft bgs  for ecologically driven PRGs.   Locations with
samples where contamination levels exceeded the respective PRGs were assumed to require
remediation to the relevant depth to address  soil-related risks.   In instances where only surface
soil samples were available and the  data from  those samples exceeded at least one human-
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health PRO, the full 12 ft depth of soil was conservatively assumed to require remediation to
address soil risks.  Using this  approach it was determined that any remedy would need to
address the entire portion of the facility area that lies within the containment barrier (22.8
acres) to depths of between 2 and 12 ft bgs.  This equates to 351,060 cubic yards of site soils.

When determining soil volumes contributing to soil gas risks,  all soils associated with each of
the "hot spots" (with the exception of the warehouse) were assumed to require remediation to a
total vadose zone depth of 50 ft. Approximately half of the soils underlying the warehouse and
its surrounding area were assumed to be contaminated.  This approach yielded a soil volume of
464,650 cubic yards.  When combined with the volume of soil  requiring remediation to address
soil risk, a total remedial soil volume of 815,710  cubic yards is expected for the On Facility
area.

Using a worst case scenario for risks from soil in the  Northern Area portion of OU-3,  it is
estimated that an additional 1.4 acres of soils  (beyond those found within the former facility
fence line)  will need to be addressed to a depth of 12 ft.  Inclusion of the Northern Area  thus
adds 26,700 cubic yards  to the volume requiring remediation for soil risks.  Similarly, a worst
case scenario wherein all of the soils in the 1.4-acre Northern Area portion  of OU-3 would
need to be  remediated to address risks from soil gas yields  a total of 111,000 cubic yards of
soil from the area that would require treatment. Based on the available soil data and passive
soil gas sampler  data from the Northern Area, it is  unlikely that such worst case scenarios
would be observed.  For this reason, the volumes related to  remedial measures necessary to
address soil and soil gas risks from the Northern Area portion of OU-3 have been broken out
separately.

To develop an estimate of the volume of soil that might require additional treatment or special
handling because of dioxin contamination in excess of the PRO, the area of each "hot spot"
was multiplied by a depth of 12 ft.  This approach was selected because of the overlap between
the "hot spot" areas and dioxin samples with results greater than the dioxin PRO.

TECHNOLOGY PROCESS SCREENING AND DEVELOPMENT OF ALTERNATIVES

Technology Process  Options (TPOs) representing  a  range  of  technology  types  with the
potential to address at least some portion of OU-3 contamination were identified. These TPOs
were then screened based on their ability to  treat OU-3 wastes, feasibility for implementation,
and relative costs of implementation.

Those TPOs that were retained were assembled into remedial alternatives that could potentially
meet the RAOs for the site.  The assembled alternatives were screened  qualitatively based on
their effectiveness,  implementability, and  cost.  Alternatives that were  retained  after the
screening underwent a detailed evaluation based on the following seven criteria specified in the
RI/FS Guidance and consistent with the NCP:
    1)  Overall protection of human health and  the environment
   2)  Compliance with ARARs
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   3)  Long-term effectiveness and permanence
   4)  Reduction of toxicity, mobility or volume
   5)  Short-term effectiveness
   6)  Implementability
   7)  Cost

The four alternatives selected for the detailed evaluation are:

Alternative  1A; No  Action-The no  action alternative is included as  a baseline in the
comparison  of  other  alternatives,  as  required  by  the NCP.  No  remedial activities  or
institutional controls would be  implemented under this alternative,  although  some  level of
natural attenuation might occur.

Alternative 2A; Surface Cap-This alternative includes construction of a concrete, asphalt, or
multilayer surface cap  (such as RCRA Subtitle C cap) over 22.8 acres of the On Facility area.
The cap would be tied  into the previously constructed vertical groundwater containment barrier
on the west, south, and east sides of the On Facility Area. On the north side,  the cap border
will be the southern boundary of the Northern Area. If it is determined that some or all of the
Northern Area is contaminated at levels greater than the off facility PRGs, the northern end of
the cap will be  extended to incorporate those areas.  Alternative 2A  would also  incorporate
Institutional Controls (ICs) to restrict land use to commercial, light industrial, or parkland use,
prevent groundwater use, and require that any  construction  activities  minimize the impact on
and repair any damage to the cap.  These ICs could be implemented through, for example,
zoning  ordinances, restrictive covenants and  access  agreements,  in combination with  air
monitoring program and continued use and maintenance of the existing site fence and warning
signs to restrict unauthorized access to the Site. Additional site preparation would  be  required
for cap construction because  of the remaining subsurface and surface structures and debris
located  in  the On Facility area. Care must be taken during construction activities to avoid
damaging the previously  installed containment barrier and other IGR components (including
piezometers, monitoring wells, and extraction wells).  Compliance  with  air emissions limits and
with stormwater and sediment controls would be required.

Alternative 2B;  Surface  Cap  with Soil Vapor Extraction (SVE)-In this alternative, the
surface  cap and ICs in Alternative 2A would be supplemented with  an in-situ SVE system.
SVE wells would be placed at some or  all of the identified  "hot spots"  and operated to treat
VOCs under the  cap until no  significant VOC removal is being achieved.  It is expected that
the SVE system  would consist  of several hundred air extraction and inlet wells  installed to
depths of approximately 50 feet  bgs.  Off-gas from the SVE system would likely need  to be
treated before it is discharged to the atmosphere, most likely with a vapor phase activated
carbon adsorption system.  Therefore the extraction wells would be manifolded to  conveyance
piping  running to the off-gas  treatment system.  To  preserve surface cap integrity, the  wells
would  likely be installed before  the cap  is constructed with conveyance piping being laid in
trenches installed in the  ground  surface that would then be capped.   Spent carbon would be
regenerated (either on site or off site)  for  reuse or disposed of off site.  More extensive
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sampling would likely  be  performed  to  further delineate the contaminated  areas  requiring
treatment.  Pilot  studies would  be required  before  this  alternative  could  be effectively
implemented.

Alternative 2C;  Surface  Cap  with In  Situ  Thermal Desorption (ISTD)-Alternative 2C
includes many of the elements of Alternative 2B (ICs, surface cap, including further sampling,
pilot studies and  vapor treatment). The  main difference for Alternative 2C is that the "hot
spot" soil areas more than  10 feet away from the soil bentonite containment barrier  would be
heated to facilitate volatilization and removal of SVOCs, PCBs, and dioxins.  The "hot spot"
areas within 10 feet from the containment barriers would be treated with  un-enhanced SVE.
Based  on discussions  with ISTD vendors, it  is  estimated that approximately 2,800  ISTD
heaters and 1,400 heated vapor extraction wells would be placed between 8  and 12 ft apart
over the 330,000 square feet area that comprises the "hot spots"  in the site. In the event that
the Northern Area is determined to be a "hot spot" in need of treatment in addition to capping,
approximately 500 additional heaters  and 250  additional heated  extraction wells would be
installed to address the 60,000 square feet area. The heaters and extraction wells would extend
through the 50 ft vadose zone and would heat  the soil to temperatures close to or above the
boiling points of the  soil  contaminants.   Soil heating for ISTD  can be achieved by several
methods, including hot air or  steam injection,  radio-frequency heating, electrical resistance
heating, and thermal  conduction heating.  Because  temperatures  in excess of 570  to  650°F
would likely be required to facilitate volatilization of most of the SCO site organic compounds
it  is unlikely  that hot  air  or steam injection  approaches would be used.   The volatilized
organics would then be extracted through the heated extraction wells described above. Because
of the number of wells, the potential impacts of heating on cap materials, the high costs of
materials required to construct heat resistant wells, and the amount of wiring required for the
system, ISTD treatment would likely be performed prior to the installation  of the surface cap.
The ISTD wells would then be removed or abandoned to ease cap construction activities.

EVALUATION OF ALTERNATIVES

The  major findings  of the detailed evaluation  of the four alternatives based on the  seven
evaluation criteria are summarized below:

Overall Protection of Human Health and the Environment
Alternatives 2A, 2B, and 2C would all reduce human health  and ecological  risks from soil and
soil gas to  the target levels developed in  this  FS Report by containing, and preventing contact
with, contamination through the use of a surface cap.  Alternative 2C would  improve on the
level  of human  health  protection (specifically  the health of future  construction  workers or
others performing intrusive site work) afforded by  the surface cap by removing almost all
organic contamination from vadose zone soils in the "hot spot" areas.  Alternative 2B would
also  provide some measure  of  added protection,  but would  only remove VOCs and some
SVOCs from  vadose  zone  "hot spot"  soils.  Alternative 1A (No  Action)  would not provide
protection of the environment or human health.
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Compliance with ARARs
While Alternative 1A (no action) would not meet the ARARs, Alternatives 2A, 2B, and 2C can
all be designed and implemented to comply with the identified ARARs with the exception of
the requirement to construct a liner system beneath the waste. The requirement to construct a
liner system will not be met. Instead, any cap will be tied into the soil bentonite containment
barrier that was installed as part of the IGR.  This barrier is keyed into a low permeability layer
that  lies between  the  contaminated soils  of the Columbia  Formation and the underlying
drinking water aquifer  (the  Potomac).    This  method  of construction will  isolate  any
contaminated OU-3 soils left under the  cap from surrounding uncontaminated  areas.  As a
result,  the capping alternative will  attain a  standard of performance that is equivalent to the
standard that would be attained  through  the construction  of a liner  system.  As  a result,  this
ARAR is waived pursuant to 40 CFR Section 300.430 (f)(l)(ii)(C)(4).

Long-term Effectiveness and Permanence
Alternative 1A (No Action) will not reduce the risks from,  or the potential migration of,  site
contaminants.  As a result, Alternative 1A will not be effective over the long term.

Alternative 2A would provide effective containment of all  contaminants located in the soil  and
soil gas of OU-3.  This would substantially  reduce the risks related to, and the potential spread
of,  site  contaminants.    To  remain effective  over the  long term,  maintenance  activities,
including management  of vegetation and burrowing animals and repairs of crack  and erosional
features, would be required into perpetuity.

Alternatives 2B (SVE plus surface cap) and  2C (ISTD plus surface cap) would improve on the
effectiveness of Alternative 2A by reducing  or eliminating organic contaminants  in the vadose
zone of the  previously identified "hot spot" areas. Because SVE would only address VOCs
and ISTD would reduce or eliminate all of the organic contaminants in vadose  zone soils in
these areas, Alternative 2C  would be the most effective over the long term.

Reduction of Toxicity, Mobility or Volume
Alternative  1A (No Action) would not reduce  the toxicity, mobility  or volume  of  OU-3
contaminants.

Alternatives 2A, 2B, and 2C will all reduce the mobility of the contaminants through the use of
a surface cap  to reduce infiltration (reducing the soil to  groundwater pathway),  eliminate
contact of contaminated materials with stormwater (eliminating the soil to sediment pathway),
and containing soil gas (eliminating the  soil to  air pathway).  Alternatives 2B and 2C also
include  treatment technologies (SVE and ISTD,  respectively) that would  reduce the volume
and toxicity  of OU-3 contaminants.  The greatest reduction of contaminant toxicity and volume
is  expected  from  Alternative 2C (combination  of the  surface cap  and ISTD),  as it would
remove VOCs, SVOCs, PCBs,  and dioxins from vadose  zone soils in the "hot spot" areas.
Alternative 2B (surface cap with SVE) would remove VOCs and  some SVOCs from the "hot
spot"  areas  but would not address dioxins, pesticides,  and other less volatile contaminants.
Until pilot-scale studies can be  performed  for the SVE and ISTD technologies, no  accurate
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quantitative measure of potential contaminant reduction  can be made for Alternatives 2B or
2C.  Alternative 2A (surface cap alone) would not reduce the toxicity or volume of the OU-3
contaminants.

Short-Term Effectiveness
Alternative  1A (no action)  would have the highest short-term effectiveness (lowest short-term
risk). Although risks from the current site conditions would continue, no disturbance of OU-3
soils (and therefore soil contaminants) would occur.

Short-term risks to construction workers, surrounding communities and the environment are
expected to occur  from the implementation  of  Alternatives 2A,  2B,  and  2C. These  risks
include exposure to dust and vapor during cap construction activities, as well as continued risks
from the current site conditions before the alternatives are fully implemented. Alternatives 2B
and 2C would be somewhat less effective than Alternative 2A in the short term because of the
increased site  activities (well construction, trenching, wiring and piping installation) required
to construct the SVE  and  ISTD systems. Additionally, the  SVE  and ISTD systems would
increase the mobility of organic contaminants over the short term.  Short term risks associated
with Alternatives 2A, 2B, and 2C can be managed by a  combination of institutional controls,
Personal Protective Equipment  (PPE),   and  vapor  and dust  suppression  measures to  be
employed during  construction activities.   Vapor capture and treatment systems would  address
any increase in the off-gassing of contaminants under Alternatives 2A, 2B, and 2C.

Implementability
Alternative 1A requires no action and is therefore the most easily implemented.

Of the remaining  alternatives, construction of a surface cap by itself  would be  most easily
implemented. Although the potable water line to the treatment building would be rerouted so it
does  not pass under the  cap,  this could  be  accomplished  using  standard  construction
equipment, materials, and methods.  Care would  also have to be taken to  avoid damage to the
existing GETS, piezometers,  and monitoring  wells, but the overall cap construction could
similarly be performed using standard construction equipment and methods.  Additionally, no
further delineation (aside from possibly in the Northern Area) or pilot studies would be needed
before construction of a  surface cap covering all of OU-3.  Activities to maintain the  surface
cap would be similar under Alternatives 2A, 2B, and 2C.

The   proposed   treatment  technologies  (SVE  and  ISTD)  would  require  additional
characterization sampling to further  delineate  the "hot spot areas"  and the  Northern Area as
well as pilot studies to optimize well placement, blower and pipe sizing, and, in the  case of
ISTD, the temperatures that will be  required to achieve treatment of the  OU-3 contaminants.
The  time required to construct Alternatives 2B and 2C would also be greater than that needed
to complete the surface cap alone. The SVE and ISTD systems would also require controls to
limit the off-gas discharge into the air and would have to meet the substantive provisions of air
discharge permit  requirements.  These systems would also require  the installation of several
hundred  wells  (in the case of SVE) to  over 4,000 wells (in  the case  of ISTD), whereas
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Alternative  2A would require  installation  only  of a  small  number  of monitoring  wells.
Alternative 2A might also require a vapor treatment system to  meet the substantive provisions
of air discharge permit requirements off-gas  from the cap soil gas capture system.  While SVE
could be implemented using the utilities already available on site, it is possible that a higher
voltage electrical supply and a natural gas supply will need to  be routed to the site if ISTD is
selected as part of the site remedy.

Cost
Alternative  1 requires no action and therefore has no associated project costs. The order-of-
magnitude level estimates for total project costs (shown as present value estimates taken over
30 years at a discount rate of 5%) for the remaining alternatives are as follows:

Alternative 2A (Surface Cap)
Alternative 2B (Surface Cap + SVE)
Alternative 2C (Surface Cap + ISTD)


$18.5
$26.2
$99.8

$17.5
$25.2
$98.8

$11.5
$19.1
$92.8
NOTE: Because of the lack of definitive data showing that levels of contamination in the Northern Area
       portion of OU-3 require remediation, the costs associated with the  Northern Area are  not
       included in the above estimates.  If additional sampling shows that risks from soil and/or  soil
       gas will require remediation, additional  costs (up to  a  maximum of between $421,000  and
       $861,000 to cap the entire 1.4 acre Northern Area) would be incurred.

Alternative  2A  is the least expensive  of these alternatives, followed by Alternative 2B and
Alternative  2C.  For all containment alternatives,  asphalt would be the least expensive capping
material choice, followed by concrete and multilayer soil.

PREFERRED ALTERNATIVE

Based on evaluation of the four retained  alternatives using the seven  evaluation  criteria, it
appears that Alternative 2A (Surface Cap) would be the overall  best approach for  addressing
the risks  from the  soil and soil  gas  contamination that is present  in OU-3.   This  alternative
would be consistent with the identified ARARs and would provide  protection of human health
and  the  environment over  the  long term by eliminating the  soil and sediment exposure
pathways and substantially reducing the soil  gas exposure pathway.   ICs would be used to
restrict land use, prevent the use of site groundwater,  require the inclusion of vapor intrusion
protection in  future building construction, ensure  that  remedial  measures  remain  in good
functional condition, and require that any  construction activities minimize the impact on and
repair any damage to the cap, and keep the public informed of site developments and  hazards.
These controls could be implemented through zoning ordinances, access agreements, restrictive
covenants, and public awareness efforts.  These ICs would be required to increase the level of
protection and ensure  that the  surface  cap  continues to  be  effective over  the  long  term.
Alternatives 2B and 2C  would offer  some  increased protection of human health during future
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intrusive  activities  (e.g.,  construction,   well  installation,  and   cap  repair)  by  reducing
contaminant  levels in "hot spot"  soils and  soil gas, but any  increased risk associated with
Alternative 2A  could be managed through the use of personal protective equipment (PPE),
vapor and dust suppression, worker training and other precautions.

Although installation of a surface cap would not reduce the toxicity or volume of the  OU-3
contaminants,  it would  reduce the  mobility of the  contaminants by reducing/eliminating
precipitation  infiltration, preventing stormwater contact with contaminated soils, preventing the
airborne transport of contaminated soil particles,  and minimizing  the potential off-gassing of
soil  gases.    While  each  of  the containment alternatives could be readily  constructed,
implementation  of Alternative 2A would be the easiest of the three and could be accomplished
in the shortest period of time for the lowest overall cost.

Although asphalt would be the least expensive option and would provide protection  that should
be (if properly maintained)  equal to that offered by the concrete and multilayer soil options, a
choice must  be  made as to the  possible future uses  of the capped  area  and the importance of
site appearance. While the concrete and asphalt caps would be  preferable if redevelopment of
the site for some low occupancy business  purpose is envisioned, a multilayer  soil cap would
likely be more visually appealing and more amenable to conversion of the land to park space or
naturalized open space.
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                        FEASIBILITY STUDY REPORT
               STANDARD CHLORINE OF DELAWARE SITE
                          OPERABLE UNIT 3 (OU-3)
                    NEW CASTLE COUNTY,  DELAWARE
1.0    INTRODUCTION

This Feasibility Study (FS) Report has  been developed  for Operable Unit 3 (OU-3) of the
Standard Chlorine of Delaware (SCD) Site (Figure 1.1).  This FS Report has been prepared by
HydroGeoLogic, Inc. (HGL) under Contract Number EP-S3-07-05 with Region 3 of the U.S.
Environmental Protection Agency  (EPA), in accordance with  Task 12 of Work Assignment
002RICO03H6.

1.1 PURPOSE AND ORGANIZATION OF THE REPORT

The purpose of this FS Report is  to develop and evaluate remedial alternatives that may be
feasible for  addressing potential risks to the human health and the  environment posed by
contaminated soils and soil gas at the SCD site.  The scope of this FS is based on discussions
with the EPA,  information obtained during the Remedial  Investigation (RI),  and the results of
the baseline risk assessment (BLRA).

This document has been prepared in accordance with the requirements of the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, regulations for
implementing the  Comprehensive Environmental  Response,  Compensation,  and  Liability Act
(CERCLA),  as well as the guidance provided by the EPA in the Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (EPA, 1988).  The FS Report
is organized  as follows:
   •   The subsequent subsections  of Section 1 summarize site history and setting, as well as
       current  site characteristics. These  topics are discussed in more detail in the August 2007
       RI Report (Black and Veatch, 2007a).
   •   Section 2 discusses  remedial action objectives, including identification of applicable or
       relevant and appropriate requirements (ARARs) for contaminants of concern (COCs) in
       soil and soil gas at the site and for potential remedial actions. Site-specific Preliminary
       Remedial Goals (PRGs) are developed, and  the areas  and volumes of soil requiring
       remediation are estimated.
   •   In Section 3,  technologies with the potential to remediate soil and soil gas at the site are
       identified and screened.
   •   In Section 4, the  technologies retained  after the initial screening  in Section  3 are
       assembled  into remedial  alternatives, which  are  then evaluated to  identify the  most
       promising alternatives for the site  contamination.
   •   Section 5 provides a detailed analysis of the remedial alternatives retained in Section 4.
   •   In Section 6,  remedial alternatives retained for the detailed analysis are summarized and
       compared.
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1.2 SITE BACKGROUND

Background information on the SCD site  is  summarized below.  Additional  background
material can be found in the August 2007 RI Report prepared by Black &  Veatch (Black &
Veatch, 2007a).

OU-3 encompasses the following areas and media:
    •   Area within the former facility fence line: soil and soil gas.
    •   Area to the north of the  former  facility fence line: soil and soil gas between the former
       facility's northern fence  line and south of the sedimentation pond.

Pertinent site features are shown on Figure 1.2, and OU-3 is highlighted on Figure 1.3.  For
the purposes of this FS, OU-3 is subdivided into the On Facility Area and the Northern Area.
The On Facility area encompasses those portions of the site that lie within the former facility
fence line. The Northern Area consists of the area between the northern leg of  the facility
fence line  and the southern  edge of the  waste sedimentation  pond.  Groundwater, surface
water,  sediment, and soils from other areas located beyond the facility fence line are addressed
under other operable units. Columbia Aquifer groundwater (OU-1) is being  addressed  by the
Interim Groundwater Remedy (IGR) which was constructed in  2006 and 2007 and includes a
groundwater containment barrier and a groundwater extraction  and treatment system (GETS).
Off facility soils and sediments  along the 1986 spill pathways will be covered under OU-2, and
OU-4 will cover remaining off facility areas that have been impacted by site contamination.

1.2.1   Site Location and Description

The SCD  Site is  located on Governor Lea Road  near the  intersection with  River  Road,
approximately three miles northwest of  Delaware  City in New Castle County, Delaware
(Figure 1.1).   The area is  a  mixture of industrial  facilities,  farm land,  and  undeveloped
properties, although there are residential and commercial properties located to the north and
west within one mile  of the facility.  Approximately 152,000 people (from residences and
businesses) obtain potable water from public and private wells within a three-mile radius of the
site (Black & Veatch, 2007a).

The SCD Site extends from Governor Lea Rd. in the south to the Red Lion Creek in the north.
Land owned  by  Occidental Chemical Company (formerly  Diamond Shamrock and Diamond
Alkali) lies immediately to the east of the  SCD Site while an Air Products, Inc. hydrogen
processing facility  abuts the western fence line.  Across Governor Lea Road  lies  property that
is  the site of buildings that were  previously used as offices and a change house  by SCD and
Metachem.  This property and these buildings are now owned by Ion Power, Inc..  Farther to
the south is  a refinery that is currently owned by Valero Corporation (Valero)  and was
previously  owned  by  Motiva  Enterprises,  LLC,  Premcor, Inc., Star Enterprises, and  the
Tidewater Refining Company.

Of the  approximately 65 acres  that make  up  the  SCD  Site, approximately 25 acres  are
surrounded by a fence and  form the footprint of the former  SCD/Metachem manufacturing
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facility  (facility).  As the  result of remedial,  removal, and demolition activities that have
occurred since the potentially responsible party's (PRP's) abandonment of the site, the facility
area is strewn with a great deal of concrete and other debris. This debris includes remnants of
multiple containment structures and portions of the former facility's wastewater treatment plant
(WWTP).  The land between the former facility and the Red Lion Creek remains undeveloped
with the exception of gravel  roads (single lane), a sedimentation basin, the temporary soil
storage  area (TSSA), IGR components, and other features constructed  as part of past remedial
and monitoring activities. This area was wooded until  the construction of the IGR, when the
area  was  bulldozed  by  the  subcontractor  who constructed  the containment  barrier.
Consequently, only the area outside of the containment barrier  and a small area around the
waste sedimentation basin remain wooded.

The facility area and the upland areas within the containment barrier alignment to the north of
the former facility are relatively  flat and lack significant vegetation.  Near the Red  Lion Creek
and its unnamed tributary located to the west of Air Products and the undeveloped area to the
north of the facility (the unnamed tributary), the terrain slopes sharply downward to wetland
areas surrounding these two water bodies.

1.2.2   Site Operational History

The SCD  facility was built in 1965 on approximately 46 acres of farmland purchased from the
Diamond Alkali Company.  The  following year, SCD began production of chlorinated benzene
compounds.  These compounds were manufactured at the SCD facility  until its closure in May
2002. SCD, and later  Metachem, used chlorine piped from the  Occidental  Chemical facility
and benzene  (obtained primarily from the refinery located south of  the facility)  to  produce
chlorinated benzene compounds.  Following another expansion in the early 1970s,  SCD added
chlorinated nitrobenzene to  its  product  line and  increased production of chlorobenzene,
dichlorobenzene, and trichlorobenzene.   SCD ended chlorinated nitrobenzene production in the
late  1970s, and  the  related  capacity  was  switched  to  the production of chlorobenzene.
Following  an expansion  in  the  late  1970s,  the  SCD  facility produced chlorobenzene,
paradichlorobenzene, various isomers of trichlorobenzene,  and chlorobenzene-based insulating
fluids (Weston, 1993).

In December of  1998, SCD  was  sold to Charter Oak Partners which reorganized the company
as Metachem Products,  LLC (Metachem).   Metachem purchased all of  the land  located
between the facility fence line and the Red Lion Creek that was known to have been impacted
by SCO's releases.  SCD and Metachem have been identified as PRPs.

On April  30,  2002,  Metachem  announced that the bankruptcy  of one of its  customers had
resulted in a decision to close the SCD  facility.  Metachem  closed the  facility on May 4, 2002
and declared bankruptcy six days later (May 10, 2002).  Metachem abandoned the SCD Site on
May  14,  2002, and the EPA  and the  Delaware  Department of Natural Resources  and
Environmental Control (DNREC) have been  cooperating since then to implement emergency
cleanup and remedial actions while developing an approach for the long-term rehabilitation of
the SCD Site.
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1.3 ENVIRONMENTAL SETTING

1.3.1   Site Topography and Surface Drainage

The majority of the SCD Site is generally flat and is bounded by Red Lion Creek to the north,
the unnamed tributary to the west and  topographic highs to the south and east.  The formerly
wooded area to  the north of the former facility decreases in elevation from  about  50 ft above
mean sea level (amsl) along the containment barrier alignment to near sea level at the Red Lion
Creek and its unnamed tributary. The site exhibits a north-south trending  surface water divide
that traverses the  approximate center of the facility and the formerly  wooded area (Weston,
1993).

Surface drainage is controlled  by topographic highs toward the southern end of the site and
flows in a dendritic pattern toward  the dominant drainage feature of Red  Lion  Creek.  The
surface  water divide  on the facility portion of the  site previously  directed drainage to  the
eastern drainage ditch - a shallow (approximately one to four feet deep) drainage ditch  that  ran
through the  eastern portion of the facility -  and a shallower drainage ditch  that ran along  the
facility's western boundary.  These  drainage  features captured  and  directed stormwater to two
weirs that  were  located  in the  northeastern  and  northwestern corners of the   facility,
respectively. The  weirs discharged  stormwater off site  under a National Pollutant Discharge
Elimination  System (NPDES) permit. The western weir discharged to the Red Lion Creek via
a drainage gully that leads to the unnamed tributary, while the outflow from the eastern weir
traveled overland to  the Red Lion Creek. Both weirs were  removed  during construction
activities associated with the IGR and replaced with stormwater/sediment  basins located at the
northeast and northwest corners of  the former  facility.  The western drainage feature  was
destroyed during  these construction activities and  has been  replaced  with a  swale  located
approximately 30 feet inside  the  western  leg  of  the containment barrier  alignment.  The
southern portion of the eastern drainage ditch was also filled in during demolition/construction
activities,  and a separate drainage  swale was installed to the  east  side  of the asphalt road
installed as part  of the  IGR. The area to the east of this new swale is rutted with tire marks and
drainage is  inadequate. The northern portion of the eastern drainage ditch was excavated to
remove contaminated  surface  soils  and the  section  reconstructed to  flow to  the  eastern
stormwater/sediment basin.

The IGR construction activities  have  resulted  in a generally  flatter topography  that is  less
conducive to the  shedding  of water from certain areas.   In  the  formerly  wooded area,  the
relatively  flat grade has resulted in substantial  areas  of ponding.  In the facility  area,  the
demolition  and deactivation  of numerous facility storm drains (performed during emergency
removal activities and salvage operations)  has resulted in areas of ponding in the southern
portion of the site.

1.3.2   Geology

Subsurface  investigations conducted during  and before the RI indicate  the presence of  the
following subsurface strata at the SCD Facility, in descending order:
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   •   Fill and Recent Deposits (Native Soils)-The fill consists of gray clay from dredge
       spoils or orange to brown sands from local sources.  The recent deposits  consist of
       sandy and clayey marsh deposits including peat.
   •   Columbia Formation  (Quaternary)-As described in the CRA intermediate Remedial
       Design  Report  (CRA,  2000), the Columbia Formation occurs  in  channel  fillings in
       northern Delaware and in broad  sheets created by coalesced braided stream channels
       across central Delaware.  Jordan  and Talley (1976) hypothesize that  the Pleistocene
       sediments were deposited by the discharge of large quantities of water and detritus from
       southerly flowing streams originating within the glaciated area to the north of Delaware
       City.  Spoljaric (1967) studied the channel filling nature of the Columbia Formation in
       New Castle County and  recognized  a major, north-south trending  Pleistocene fluvial
       channel system that appears to  occur near  the general  area located  north of Delaware
       City.  Within these channels, the Columbia Formation directly overlies the Potomac
       Formation  where  the  Merchantville  Formation  has   been  incised.  The  Columbia
       Formation consists largely of fine sand to coarse sand with varying  amounts of gravel.
       It typically has  distinct orange to  yellow color.  A basal sand and gravel layer  is a key
       marker  bed indicating  the bottom of the formation.  Small lenses or stringers of silty
       clay or  clayey silt occur scattered throughout the formation. In the  FS study area, the
       thickness of the Columbia Formation ranges from 55 to 74 ft, with a general decrease
       in thickness to the north.
   •   Merchantville Formation (Cretaceous)-In the western portions of the SCO  facility,
       the  Columbia Formation  is underlain by the marine  sediments of the Merchantville
       Formation and is predominantly composed of material ranging  from gray to green gray
       glauconitic, micaceous  clay to silty/sandy clay. The Merchantville Formation has  been
       eroded by a north-south paleochannel in the central and eastern sections of the site. The
       lowest area of the paleochannel is located in the eastern portion of the SCO Site with a
       longitudinal axis that trends  in a general  north-south  direction.   In these  areas, the
       Merchantville Formation is absent and the Columbia  Formation is underlain by the
       Potomac Formation.  The  Merchantville Formation on-site averages  10.2 feet thick and
       where present, has a maximum thickness of 22 feet (Black and Veatch, 2007a).
   •   Potomac  Formation (Cretaceous)-The Potomac Formation underlies areas of the
       Columbia and Merchantville  Formations. The Potomac  consists largely of variegated
       red, gray, purple,  yellow and  white  clays and silts interbedded with  three relatively
       thick silty sand units. The  upper portion of the Potomac Formation in the FS  study area
       is comprised of interbeds of clay, silt,  and sand.    The lateral extent of these  upper
       clays  and/or silts as well as their ability to  restrict  vertical  groundwater flow  and
       contaminant migration  is currently being investigated (Brayton, 2009).  Lithologic data
       from the northern end of the site indicates an absence of clays thus allowing a hydraulic
       connection between the Columbia and Potomac  sands in some  areas near the Red Lion
       Creek (Black & Veatch, 2005; Brayton,  2009).

1.3.3   Hydrogeology

The Columbia  Aquifer is the upper-most aquifer in the region and  is  associated  with very
productive sands and gravels of the Columbia Formation. The surface of the groundwater table
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forms the upper boundary of the Columbia Aquifer  and generally occurs at depths ranging
from near ground surface  (near the wetlands at Red Lion Creek) to approximately 45 feet bgs
at the upland  area near the facility (Black & Veatch, 2007a).   A  portion of the  Columbia
Aquifer underlying the SCD Site includes a part of a north-south trending paleochannel filled
with unconsolidated sand and gravel and pockets of silts and clays

The  Columbia Aquifer is unconfined at  the  site, and groundwater flow generally mimics
topographic elevations, with flow towards Red Lion Creek, an unnamed tributary to the west
and northwest, and the marsh area surrounding the northern portion of the site.  The saturated
thickness of the Columbia Aquifer at the site varies  between approximately 10 and 40 feet.
The  average groundwater hydraulic gradient  in the Columbia Aquifer  ranges  from  0.003
feet/foot to 0.007 feet/foot to the north-northwest (Black & Veatch, 2007a).  Although the site
water levels may slightly  fluctuate due to seasonal precipitation changes, no tidal  influences
were observed during the RI (Black & Veatch,  2007a).

The Columbia Aquifer hydraulic conductivity  is estimated to range  from 5 to 134 feet per day,
but has been observed as high as 184 to 441 feet per day (Black & Veatch, 2007a). The RI also
noted that the water  level  in Red Lion Creek  is lower than the adjacent groundwater table in
the Columbia Aquifer  (4 feet  amsl) indicating that there is flow from the Columbia Aquifer
into Red Lion Creek and the unnamed tributary (Black & Veatch, 2007a).

Before the  installation of the IGR containment barrier (see Section 1.4.8 of this Report), site
groundwater elevations in the Columbia ranged from approximately 16.5 feet amsl in the south
to approximately 3 feet amsl in areas adjacent to Red Lion Creek.  As expected, the pumping
associated  with the  GETS  is  lowering  the average  groundwater  elevations within  the
containment area.  The water  levels measured in March 2009 indicate that the groundwater
elevations within the containment area ranged  from approximately 10.7 to 11.7 feet amsl at the
southern end to approximately  6 to 7  feet amsl at the  northern  end.   This compares to  a
containment area  groundwater  elevations  ranging from  a maximum of  16.5  feet  amsl to
minimums  of 5.4 to 5.9 feet  amsl in this area before the containment barrier was  installed.
Localized groundwater depressions (with a minimum elevation of approximately 2.3  feet amsl)
are formed in the areas surrounding extraction wells associated with  the GETS.  To  the north
of the containment barrier, average groundwater elevations  in the wells located  along the
southern edge of Red  Lion Creek have dropped from 2.6 feet amsl before the  containment
barrier installation to approximately  1.7 feet  amsl in March  2009.  This drop is most likely
caused by  the reduction of groundwater flow into this  area by the upgradient  containment
barrier.   The containment barrier diverts groundwater flow around the  facility  portion of the
site so that the water flows toward the east and west  before resuming a more northerly route
toward Red Lion Creek.

The Merchantville Formation  consists of dark gray to black  micaceous clays and silty-clays.
Regionally, the Merchantville acts as a confining  unit separating the Columbia and Potomac
aquifers. Based on  investigations conducted  as part of the  RI  as well as   more recent
investigations discussed below, the Merchantville Formation is absent in some areas  along the
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northern portion of the site.  In these areas, the Columbia Aquifer is underlain by either clayey
sediments of the Potomac Formation or by silty-sand material where the upper clays have been
eroded by the paleochannels. Below these upper units, there is a sequence of interbedded clays,
silts, and sands that eventually form the Potomac Upper Hydraulic Zone (UHZ).  It is believed
that within the containment area at the SCD Site, the clay/silty-clay layer associated with the
Merchantville  and/or the Upper Potomac formations  generally act as an aquitard to restrict
groundwater flow between the Columbia and Potomac UHZ Aquifer.

In August 2005, the U.S. Geological Survey  began investigating the hydraulic  connection
between the Columbia (unconfined) aquifer  and the  Potomac (confined) aquifers (Brayton,
2009).  A pump test conducted in 1990 showed a good hydraulic  connection within the upper
Potomac sands, but no  apparent  connection between the  Columbia and Potomac aquifers
(Brayton,  2009). Three Potomac wells were installed in 2003 and 2004 with subsequent water-
quality monitoring. As of 2009, with the exception of well PW-01, contamination has not been
detected at  any  of these wells (Brayton,  2009).  The contamination detected in PW-01  was
suspected  of  originating from a former  waste  pipeline,  and  concerns  regarding  well
construction led to eventual abandonment in May 2007.

Additional wells screened within the Potomac Aquifer were installed in  2007.  Gamma  logs
and vertical water-quality profiling were conducted on selected wells (Brayton, 2009). At two
of the  locations,  the wells  were installed with  a screened  interval   set below existing
Merchantville  clay, but above  Potomac clay. This thin discontinuous sand zone has been found
to be similar in water chemistry to the unconfined Columbia aquifer, and water levels have
behaved similar to  Columbia wells, indicating  that the Merchantville   is  not an  effective
confining  unit (Brayton,  2009).  Several of the additional wells were completed in  Potomac
sand, approximately 140  feet below  land surface  and  have  exhibited a similar water-level
behavior to  previously installed Potomac wells. Brayton (2009) notes that wells north of Red
Lion Creek show continuous vertical hydraulic connection with  no confining units present
(Merchantville or Potomac  clay).  Two  wells  placed northwest  of the  site,  show vertical
hydraulic connection below a confining Potomac clay; both wells are screened in a continuous
sand. One of the two wells  is  screened in a silty sand below  several  thick sequences  of
Potomac clay, overlain by Merchantville clay.

Although  the  aforementioned clay/silty-clay layer reduces  groundwater flow  between  the
Columbia and Potomac UHZ Aquifers  throughout  much of the SCD Site,  recent detections
(over the  past two  years) of  site-related contaminants in one well screened in the  Potomac
Aquifer as well as  the observation of dense non-aqueous phase  liquid (DNAPL)  during the
Remedial  Design Investigation  at  a depth  of 150 feet indicate  that some transmission is
occurring.  The origin (and transport pathway) of this contamination and location of gaps in the
confining clay(s) are an ongoing focus of the USGS Potomac Aquifer Study.

The  Potomac  Aquifer is a  source of potable groundwater and is  capable of producing
significant quantities  of  quality water out  of  the  Potomac  UHZ. Based upon water-level
measurements and the distribution of VOC contamination, groundwater flow in the  Potomac
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Aquifer is believed to follow an east-southeast direction in the area of the site.

There is still some debate as to whether this transmission is occurring in the northern and/or
northwestern portions  of the site,  is  associated with  releases from the former  facility
wastewater discharge line (located to  the east of the facility), or is related to some gaps in the
aforementioned clay layer  within the  containment  area.  Data  obtained  during  quarterly
sampling of a number of Potomac-screened wells (conducted over the past 18 months) has not
indicated  any additional contamination in the Potomac.  Additional testing,  including  the
installation and  sampling of  double-cased monitoring  wells  screened  in  the Potomac,  is
scheduled for the summer of 2009.

1.4 PREVIOUS SITE INVESTIGATIONS AND REMEDIAL RESPONSES

1.4.1   Introduction

During the three years following the discovery of the  1981 spill, EPA conducted an initial site
inspection and a Preliminary Assessment of the SCO Site. The results of these investigations
were then used to assemble a Hazard  Ranking System (HRS) package that resulted in proposal
of the SCD Site to the  National Priorities  List (NPL) on September 18,  1985.  The  SCD Site
was formally added to the NPL on July 22, 1987.  The SCD Site has been assigned CERCLIS
number DED041212473.

A Consent Order between DNREC and SCD  covering  the performance of a  Remedial
Investigation and Feasibility Study (RI/FS) at the  SCD Site was  signed on January 12,  1988
and amended on November 14,  1988.  The RI/FS  for this Consent Order was conducted
between  1991 and  1993. A  Record of Decision (ROD) for the SCD Site spill pathway was
completed  by EPA  on  March  9,  1995, but this  ROD  did not  cover  the bulk of  the
manufacturing facility which was, at the  time, still  operating. A Unilateral Administrative
Order for remedial design (RD) and remedial action (RA) was issued by EPA to SCD on May
30, 1996.

A design stage  investigation conducted in  2002 and 2003 indicated that contamination in the
tributary wetlands located west of the site's upland portion was more widespread, particularly
with regard to depth, than was indicated in the PRP's RI Report. The  RD  investigation was
followed by an RI that  included,  among other areas, the former  facility portion of the  site.
The EPA also undertook bench-scale  and pilot-scale tests of in situ chemical  oxidation (ISCO)
as part of a focused feasibility  study  (FFS) to determine whether ISCO could be a more cost-
effective approach for  remediating the impacted wetlands than the  low temperature  thermal
desorption  (LTTD) approach specified in the 1995 ROD.  The  results of this pilot study were
presented in the Wetlands Remedial Approach and  Pilot  Study  Summary  Report for  The
Standard Chlorine of Delaware Site -  New  Castle,  Delaware  (HGL, 2009).

Observations made  during work performed  (in early 2008) by the U.S. Geological Survey
(USGS) indicate that site related contamination is likely present in the wetlands  located east of
the undeveloped upland portion of the site. These observations included strong odors from a
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groundwater seep and surrounding portions of the eastern wetlands.
The major sampling and remedial activities related to OU-3 are detailed below.

1.4.2   Catch Basin 1 Release and Related Remedial Activities

In March 1976, SCD determined  that Catch Basin 1 (part of the facility's WWTP) had been
leaking into the subsurface.  Catch Basin 1 was a settling basin used to recover product from
the facility's wastewater.   According to the  1992 RI Report, the catch basin was repaired at
that time, but the contaminated soil  surrounding  the catch basin  was left in place (Weston,
1993).  Releases from Catch Basin 1  are believed to be the main  source of the more highly
chlorinated contamination [i.e., tetrachlorobenzenes, pentachlorobenzene, hexachlorobenzene,
polychlorinated biphenyls (PCBs)]  that is present in the subsurface and groundwater.

1.4.3   1981 Release and Related  Remedial Activities

In September 1981, an accident that occurred during the loading of a railroad tank car resulted
in the release of approximately 5,000 gallons of chlorobenzene. This release occurred on the
rail siding that was located along the western boundary of the SCD Site.  Chemicals from this
release  flowed  into the drainage ditch that ran north and south along the rail  siding.   The
spilled materials then flowed into the drainage ditch that runs in  front of Air Products and
discharges into  the unnamed tributary.   As part of their response action,  SCD collected a
portion of the spilled chemicals and removed surface soils from the spill area and the drainage
ditch located in  front of Air Products.  The  excavated  soil was disposed of at a permitted off-
site disposal facility.  This removal action was performed under the supervision of DNREC.
As stated in the 1992 RI Report, SCD also conducted a limited subsurface investigation in the
area of the release to determine the potential for migration of the spilled chlorobenzene  into the
underlying groundwater.   Based  on the results of  this investigation,  SCD  and DNREC
concluded that the potential existed for groundwater contamination to occur (Weston,  1992).

As a  follow-up to  the soil clean up and  sampling efforts, SCD installed  groundwater
monitoring wells at various locations on the SCD property.  Analysis of the samples collected
from  these  wells  revealed that the groundwater was contaminated with multiple types of
chlorinated benzenes. Based on these analyses, it was determined that the primary source for
the more chlorinated  benzene compounds in the groundwater was the  aforementioned Catch
Basin 1 leak that SCD detected in March 1976 (Weston, 1992).

To address the groundwater contamination,  SCD installed  a series of recovery wells and
modified their existing WWTP to  include an air stripper.  An additional clarifier and  tertiary
sand filter were added  to  address the increased  flow.  A modified NPDES  permit  for  the
facility was issued by DNREC on January 21,  1985 and the modified system was brought on-
line in  1986.   At some  point following their  installation, the recovery wells and associated
piping fell into  disrepair (largely due  to corrosion issues) and suffered repeated shut  downs.
According to the EPA Emergency Removal Team (ERT), the wells were shut off permanently
on April 3, 2003 (Black & Veatch, 2005).
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1.4.4   1986 Release and Related Remedial Activities

In January 1986, a 375,000-gallon tank located  near  the western boundary of the  SCD Site
collapsed  and damaged  three  nearby tanks.   The tank failures resulted in  the  release  of
approximately 569,000  gallons  of  various  volatile organic compounds (VOCs)  including
paradichlorobenzene and trichlorobenzene  compounds.  As the  spilled materials (which were
normally heated so that they would  remain in a liquid state)  cooled, some of the material
solidified on the ground.  This allowed SCD to recover  and reprocess  some  of the  spilled
chemicals.

A portion of the spilled chemicals traveled  northward to the northwest corner of the SCD
facility and flowed down a drainage gully into the wetlands  surrounding the unnamed tributary.
Chemicals  also  flowed  eastward across  the  SCD property and  into the  facility's  eastern
drainage ditch.  These chemicals then traveled northward to the facility's eastern weir.   No
historical data pertaining to the northeastern spill pathway outside the fence line are  available,
but a recent sampling  event did address  the eastern wetlands at the  facility's stormwater
discharge point.  Data from this event were not available at  the time of FS preparation.

In an attempt to  minimize the spread of contaminants from  the western wetlands into Red Lion
Creek, SCD constructed a berm  and a silt fence across the  mouth of the  wetlands.  The silt
fence has  deteriorated  and  is no longer functional.   Contaminated sediments  were  also
excavated from  the wetlands  area to the north of the  silt fence and  placed in  the lined
sedimentation pond that is located to the north of facility fence line.  Soils that were heavily
contaminated as a result of  the spill were placed in  soil  piles constructed  northwest of the
sedimentation pond (Weston,  1992).

As part of their  RI activities, the  PRP collected water samples from between the two layers of
the sedimentation pond liner and found that contaminants had permeated at least  the upper
layer.   Based on  the age of the liner system and the detected  contamination, it has been
suggested that contamination  has  migrated  from  the  basin  into  the  underlying soil  and
groundwater (Weston, 1992).

1.4.5   1991-1992 Remedial Investigation and Feasibility  Study

The  initial  RI  and FS  conducted  by  SCD to  address the spill  pathways and  off-site
contamination were completed in 1992 and 1993, respectively. The spill RI and the FS  are
discussed and summarized in reports assembled  by the PRP's contractor  (Weston,  1992 and
1993).   As part of this RI,  sampling of the soil, surface water, groundwater,  and  sediments
located in and around the SCD site was conducted.  This sampling effort concentrated on the
1981 and 1986  spill pathways and  off  facility  areas because  the SCD  facility was still  in
operation.  Sampling activities related to chemical characterization of OU-3 soil and soil gas
are briefly  discussed below.  Complete details of the  RI sampling  effort  are presented in the
1992 RI Report.
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1.4.5.1    1981 Release Pathway Sampling

Thirty-five soil  samples were collected from 16 locations  along the path traveled by the
chlorobenzene spilled in 1981.   At each location, samples were collected from the 0 to 6 inch
and  12 to 18 inch depth  intervals.   Site  contaminants  were  detected  in  one  sample at
concentrations of 8,901 mg/kg (0 to 6 inch interval) and 311 mg/kg (12 to 18  inch interval).
The remainder of the shallow/surface soil sample results revealed  COC concentrations ranging
from 0.04 mg/kg to 34.1 mg/kg.   Three subsurface samples were collected [from depths of 5-
7 feet, 15-17 feet and 25-27 feet below ground surface (bgs)] from the location where elevated
contaminant concentrations  were  detected.   Analysis of  subsurface  samples  showed  COC
concentrations ranging from 3,049 mg/kg to 8,324 mg/kg.

Testing conducted on two  samples (one shallow/surface soil sample and one subsurface  soil
sample) from this area did not  indicate the presence  of polychlorinated biphenyls (PCBs)
(Weston, 1992).

1.4.5.2    1986 Release Pathway Sampling

Eighty soil samples were collected from 29 locations along the  1986 spill's northern flow path
(including the rail  siding and western drainage gully) and the eastern flow path (including the
eastern drainage ditch  and along the eastern fence line).  Surface soil and shallow  subsurface
soil samples were collected from 0 to  6 inches bgs  and  12 to 18 inches  bgs  at all but  one
location.  A total of 25 deeper subsurface soil samples were collected from two locations in
the rail siding area, two locations  in the western drainage gully, and three locations in the
eastern drainage ditch.  Contamination was  widespread in these samples with the shallower
samples generally  more contaminated  then those  from deeper intervals.   No  PCB data are
available for any of these samples.

Northern Flow  Path-A median COC concentration  of 2,883 mg/kg was observed  in surface
and shallow subsurface samples collected from along the northern portion of the facility's rail
siding.   COC concentrations in deeper subsurface  samples collected from  this  area were
generally lower (ranging from 0.43 mg/kg to 837 mg/kg).

Significant contamination was  also found in samples collected from the western drainage gully.
In surface and shallow subsurface soil samples collected from the western drainage gully, COC
concentrations ranged from 3.5 mg/kg to 103,525 mg/kg with a median concentration of 4,402
mg/kg. COC concentrations found in the deeper subsurface soil samples were  lower (median
concentration of 1,302 mg/kg) than those found in samples from the shallower intervals.

Eastern Flow Path-Most of the surface and shallow subsurface samples collected from the
eastern drainage ditch had elevated concentrations of COCs with  concentrations ranging from
1.3 mg/kg to 42,179  mg/kg  (median of 2,250  mg/kg).   In  contrast, only four  of the  15
subsurface samples collected from the drainage ditch area had COC concentrations greater than
100 mg/kg.   None of the 10 samples collected along  the eastern  facility fence line  had
substantially elevated COC concentrations (Weston, 1992).
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1.4.5.3    Catch Basin Number 1

Fourteen subsurface samples were collected at depths ranging from 3  feet bgs to 32 feet bgs
from a total of four locations surrounding Catch Basin 1.   The median COC concentration in
these  samples was 3,185 mg/kg with  individual sample  concentrations ranging from 10.5
mg/kg to 24,699 mg/kg (Weston, 1992).

1.4.6   1999 Initial PRP Remedial Design Sampling

To  fulfill a condition  specified  in the 1995  ROD, the PRP performed "hot spot"  sampling
during which 17 surface soil samples  were collected from areas with a high potential for
elevated  levels of contamination. Total  COC concentrations in these  samples  ranged from 4
mg/kg to 210 mg/kg with a median result of 27 mg/kg.

The PRP also collected 15 samples from soil  borings installed to the north of the facility fence
line.  Five more subsurface soil samples were collected as  part of monitoring well installation
activities along the southern and northern edges of the Red Lion Creek,  and one subsurface soil
sample was collected during installation of a monitoring well on the Air Products property
located west of the  facility  fence line.   COCs were detected in all of these  samples with a
maximum detected concentration of 40.56 mg/kg (Conestoga Rovers and Associates, 2000).

1.4.7   2002-2004 Remedial Design and Remedial Investigation Activities

The field  activities conducted  during  the  2002  -  2003 RD  and  the  2004  RI/FS  field
investigation are described in  the  2007  Final  RI Report (Black &  Veatch,  2007a)  and
summarized below.  The RD investigation efforts  occurred from October 2002 through May
2003 and focused largely on the spill pathways associated with major documented releases that
occurred at the  site and the  surrounding  wetlands.  The RD sampling  activities included
sampling of soil, sediment and surface water.

The facility-wide  RI field  sampling  activities occurred from June to  December  2004  and
focused  primarily  on  characterizing  the  horizontal  and  vertical   nature  and  extent of
contamination, evaluating  risks from the  site to human  health  and the environment,  and
providing data to assist with remedy selection. Groundwater, surface and subsurface soil, soil
gas, sediment, and  surface water were sampled during the  RI. The risk assessment  evaluation
focused on the following areas (presented in Figure 1.2), which were known or suspected to
have maximum concentrations of contamination at the site:
    •   PCB concentration area (where off-specification product was handled);
    •   Catch Basin #1;
    •   Rail Siding;
    •   Warehouse;
    •   Drum cleaning area;
    •   Northern end of eastern drainage ditch;
    •   Loading area;
    •   WWTP;
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    •   Process Area;
    •   Western drainage gully; and
    •   Air Products  drainage ditch.

The RI field investigation also included limited sample collection in the following off-site areas
to determine the potential impacts from the site:
    •   Wooded area to the north of the facility;
    •   Drainage pathways to the east and northeast of the facility;
    •   Suspect barren area to the northeast of the SCD facility;
    •   Sediment and surface water in Red Lion Creek and its unnamed tributary; and
    •   Groundwater in the Columbia and Potomac aquifers.

A Baseline Risk Assessment (BLRA) was performed based on the data collected in the RI.  The
conclusions of the BLRA are further discussed in Section  1.6 of this FS Report. Soil and soil
gas sampling activities in the areas covered by this FS  are discussed in more detail below.  Soil
and soil  gas  data  collected during  the RD and RI activities and described in the  RI Report
(Black and Veatch, 2007a) served as the basis for the analysis in this FS Report.

1.4.7.1     Surface Soil Sampling

Approximately 100  surface soil  samples (including duplicates)  were collected during the RD
and RI investigations. Of these, 53 samples (including duplicates)  were collected from On
Facility  areas  and Off  Facility areas covered by  this FS Report.   Surface soil sampling
locations are presented  on Figure   1.4. The samples  were analyzed for  all or some of the
following target constituents:  Target Compound List  (TCL) VOCs  and semivolatile organic
compounds (SVOCs), TCL pesticides/PCBs, Target Analyte List (TAL) inorganics (including
cyanide), dioxin/furans,  total  organic carbon  (TOC), specific  gravity,  percent moisture
content,  as well  as  the following flex clause constituents:   1,2,3-trichlorobenzene, 1,3,5-
trichlorobenzene,      1,2,3,4-tetrachlorobenzene,      1,2,4,5-tetrachlorobenzene,      and
pentachlorobenzene.

1.4.7.2     Subsurface Soil Sampling

Approximately 450  of the  approximately  700 subsurface  soil  samples (including duplicates)
collected during the  RI and RD were  collected  from the areas covered under this  FS Report.
Subsurface soil sampling locations are  presented on Figure 1.4.   These samples were collected
from depths  of 0.5  to 75 ft bgs,  and with the exception of ten  samples analyzed for only
dioxins and furans, they were analyzed for  the same constituents as the surface soil samples.

1.4.7.3     Soil Gas Sampling

During the RI, 34 soil gas samples (including four duplicates) were  collected from  16 soil
borings.  These samples were collected using Summa®  canisters at two depth intervals:  surface
(0-  to 6-inches bgs) and  subsurface (6-inches to 4-ft bgs).  Of these 34 samples, 24 (including
all  of  the  duplicates)  were collected  from  areas covered under this FS  Report.   Soil gas
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sampling locations are presented on Figure 1.4.  The soil gas samples collected during the RI
in September 2004  were analyzed for TCL VOCs,  as  well  as the following  flex clause
constituents:   1,2,3-trichlorobenzene;   1,3,5-trichlorobenzene;   1,2,3,4-tetrachlorobenzene;
1,2,4,5-tetrachlorobenzene; and pentachlorobenzene.

An additional 226 passive soil gas samples were collected and analyzed for TCL VOCs during
the RI  to  screen  for  subsurface  contaminants  and optimize placement  of subsurface  soil
borings.  These samples show areas that have comparatively high contaminant concentrations,
but they do not provide  soil gas concentration data and provide data  only  for  VOCs.
Consequently, the results from these samples cannot be compared to the PRGs and were not be
used to delineate the affected areas.

1.4.8   Interim Groundwater Remedy

Previous investigations  determined that contaminated  groundwater from  the  portion of the
Columbia Aquifer that underlies the SCD Site was impacting Red Lion Creek, located north of
the SCD Site, and, potentially, the underlying Potomac Aquifer. The IGR for the Columbia
Aquifer was constructed under OU-1. The IGR included construction of a subsurface bentonite
barrier wall, and a Groundwater Extraction and Treatment System (GETS).  As part of the
IGR  construction activities, the two contaminated soil piles from the 1986  spill were placed,
along with  the more heavily contaminated spoils from the containment barrier installation, into
in a lined and capped temporary soil storage area (TSSA) located in the northern portion of the
SCD Site (Figure 1.2).

1.4.8.1    Groundwater Containment Barrier Wall

The subsurface soil-bentonite slurry wall (containment barrier) and the associated GETS were
constructed as part of the SCD IGR under OU-1.  The IGR was implemented to  prevent the
migration of site related groundwater contamination within the Columbia Aquifer and from the
Columbia Aquifer to the Potomac Aquifer. Installed in 2006/2007, the containment barrier is
5,290 feet  long, surrounds  approximately  35  acres, and extends to an average depth of 70 ft
(Figure 1.2).  Where feasible,  spoils  from the barrier construction trench were incorporated
into the soil-bentonite slurry. Where contaminant levels in the trench spoils precluded their use
in the slurry, the spoils were stored in the TSSA.

1.4.8.2    Groundwater Extraction and Treatment System

The GETS  was completed in June 2007 and is being used to lower the groundwater elevation
within the  area surrounded  by  the  barrier wall  and reduce  the  potential  for additional
contamination in the Columbia Aquifer  to  spread  to the Potomac Aquifer.  Additionally,
approximately 450,000 gallons of contaminated water from the lined sedimentation basin has
been pumped to the GETS for treatment.

The  GETS includes  six extraction wells,  six  piezometers,  a  treatment  system building,
conveyance piping  and  a  groundwater  treatment  system  as  specified in the IGR design
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documents (Black & Veatch, 2005). The GETS withdraws contaminated groundwater from the
portion of the Columbia Aquifer that lies within the containment barrier and treats extracted
groundwater through the use of an  air stripper, green  sand  filtration, and two 2,500-pound
granular  activated carbon (GAC)  filters.  Off-gas from the air  stripper is  treated using two
10,000-pound GAC vessels before being discharged to the atmosphere.  Treated groundwater
is  discharged outside the  barrier and  flows  to  Red Lion Creek under an NPDES permit
equivalence.

The IGR also provides for the removal of DNAPL from the Columbia Aquifer.   Specialized
DNAPL  recovery pumps are present on site and have been used to help with this recovery,
however  the distributed nature  of the DNAPL and extremely slow rates of recharge at the
identified accumulation points has hampered  recovery efforts.

1.4.9  Ongoing Sampling Activities

In addition to the remedial activities described above, the following routine sampling activities
related to OU-3 are conducted at the SCD site (HGL, 2008):
   •  Quarterly Groundwater Sampling - samples are  collected from 18 of the groundwater
      monitoring  wells  and  analyzed  for TAL  metals, TCL VOCs, TCL SVOCs,  the
      aforementioned flex clause constituents,  and water quality parameters.
   •  Semiannual Stormwater Sampling - one aqueous sample  is collected from the eastern
      stormwater outfall and one from the western stormwater outfall.   These samples are
      analyzed for PCBs using the congener-specific 1668A  method (or Contract Laboratory
      Program (CLP) equivalent).  Once a  year, in  addition  to  the  PCB congeners,  the
      stormwater outfall samples are analyzed for TCL VOCs,  TCL SVOCs, the flex clause
      constituents, iron, lead, copper, zinc, and hardness.
   •  GETS Performance Monitoring - monthly samples of treated effluent and off gas are
      collected to characterize performance of the GETS.

1.5 NATURE AND EXTENT OF CONTAMINATION

The analysis in  this FS Report is based on the soil and soil gas data for OU-3 presented in the
August 2007 RI Report. The RI Report covers samples that were  collected as a part of RI field
activities from August to November 2004 and  RD investigations from November 2002 to May
2003.  The nature  and extent of contamination for each of the areas of concern  (On Facility
and Northern Area) are briefly summarized in this section. Sample locations are presented  on
Figure 1.4 of this FS Report. Data collected during the 2002-2003 and 2004 investigation for
the other OUs are not discussed in this FS.  A more complete discussion of site contamination
can be found in the RI Report (Black & Veatch 2007a).

1.5.1  On Facility Contamination

The  On  Facility portion of the SCD Site  incorporates all  areas  located within the former
facility fence line.   The On Facility area encompasses  25 acres and includes the following
features  that  have been identified through  sampling or historical  knowledge as  known  or
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suspected "hot spots" of contamination:
    •   PCB concentration area (where off-specification product was handled)
    •   Catch basin #1
    •   Former rail siding and loading area
    •   Warehouse and the area to the north of the warehouse
    •   1986 tank collapse area
    •   Facility storm drains
    •   Drum cleaning area
    •   Northern end of eastern drainage ditch
    •   Northeast tank farm
    •   Former WWTP
    •   Process area

1.5.1.1    Surface and Subsurface Soil Contamination

Fifty-three surface  soil samples and  approximately 450 subsurface  soil samples  (including
duplicates and quality controls) were collected from locations in the On Facility area during the
RI and RD sampling  events. The analytical results and summary statistics for the surface soil
and subsurface soil samples are presented in Tables 4-6, 4-7, 4-8, and 4-9 of the  RI Report
(Black & Veatch, 2007a).  The samples were analyzed for  one  or more of the following
constituents:
    •   TCL volatile and semivolatile organics;
    •   TAL inorganic constituents (including cyanide);
    •   The following flex clause constituents:  1,2,3-trichlorobenzene, 1,3,5-trichlorobenzene,
       1,2,3,4-tetrachlorobenzene,  1,2,4,5-tetrachlorobenzene, and pentachlorobenzene;
    •   TOC; specific gravity; and percent moisture content;
    •   CLP TCL pesticide/PCBs;
    •   Dioxin/furans

Overall, the highest levels of contamination were observed in the On Facility area.

VOCs
The VOCs detected most frequently and at the highest concentrations in the  On Facility area
soil  included   benzene,  chlorobenzene,   1,2-dichlorobenzene,   1,4-dichlorobenzene,  1,3-
dichlorobenzene, 1,2,3-trichlorobenzene, and 1,2,4-tichlorobenzene. The following On Facility
soil sample locations were  identified  with  elevated concentrations of these VOCs (Black &
Veatch 2007a):
    •   1,2,3-Trichlorbenzene: RD surface soil samples SS-01-F  (1,300 mg/kg) and SS-05-F (410
       mg/kg); and RI samples NESB-13A (45 mg/kg), NESB-16A (25 mg/kg), and RAS-10A
       (23 mg/kg).
    •   1,2,4-Trichlorbenzene: RD  surface  soil samples  SS-05-F  (1,100 mg/kg),  LT-5  (26
       mg/kg), LT-3  (38  mg/kg), LT-8 (91 mg/kg) and SS-01-F (980 mg/kg); and RI samples
       NESB-40A (90 mg/kg), RAS-10A (88 mg/kg).
    •   1,2-dichlorobenzene, 1,4-dichlorobenzene,  and  1,3-dichlorobenzene   showed  similar
       spatial patterns in  their  distribution..  Sample SS-01-F, collected along the  rail  siding
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       area  during  the RD,  contained  the  highest  site-wide  concentrations  of   1,2-
       dichlorobenzene  (570  mg/kg),   1,4-dichlorobenzene  (1,300  mg/kg),  and   1,3-
       dichlorobenzene  (250 mg/kg).  Sample NESB-13A, collected near the WWTP during
       the RI,  also  contained the highest  site-wide concentration (570  J  mg/kg)  of  1,2-
       dichlorobenzene.    1,2,4-trichlorbenzene,  1,2-dichlorobenzene,  1,4-dichlorobenzene,
       and 1,3-dichlorobenzene were  similar in  their distribution and  showed substantially
       higher concentrations in RI soil boring sample NESB-11, shallow subsurface sample
       RAS-10B (2 to 4 ft bgs),  and  RD samples  SB-02 through SB-05  and SB-08 than in
       other subsurface surface soil samples collected from the On Facility area.
   •   Chlorobenzene was generally not-detected or detected at low  concentrations in  most
       surface soil samples in  the On Facility area.  Exceptions included samples NESB-20
       (2.0 mg/kg), NESB-13 (13 J mg/kg), and RD samples LT-7 (2.9 mg/kg),  SS-07-F (3.0
       mg/kg),  which contained  substantially  higher concentrations  of  chlorobenzene.   In
       subsurface soils,  soil borings with elevated  concentrations of chlorobenzene included
       NESB-11, NESB-02,  NESB-06, NESB-07, NESB-09, NESB-12, NESB-13, NESB-19,
       NESB-23, NESB-24; samples  collected in the area of Catch Basin 1 (SB-02, SB-04,
       SB-05); and sample SB-08.
   •   Benzene was  generally  not-detected or detected at low  concentration in most of the
       surface soil samples collected  in the On Facility area. Soil boring samples NESB-06
       NESB-11,  NESB-12,  NESB-13,  NESB-23,  NESB-24,  NESB-25,  and  NESB-40
       contained elevated concentrations of benzene  in several depth intervals.

SVOCs
Generally, SVOCs were detected infrequently  or at low concentrations in most surface and
subsurface   soil  samples  from  the  On  Facility  area.  Exceptions  include  1,2,3,4-
tetrachlorobenzene,  1,2,4,5-tetrachlorobenzene, hexachlorobenzene,  pentachlorobenzene, and
bis(2-ethylhexyl)phthalate  which  were   detected  most  frequently   and  at  the  highest
concentrations.    In  addition,  elevated concentrations of di-n-butylphthalate, fluoranthene,
phenanthrene, and pyrene were detected in some surface soil samples.

Surface soil samples from the On  Facility area with elevated concentrations of SVOCs included
RI samples  NESB-10,  NESB-12, NESB-15,  NESB-20,  NESB-26,  RAS-1A, RAS-6A,  and
RAS-10A, and RD samples LT-1, LT-2,  LT-3, LT-5, LT-6, LT-7, LT-8, LT-12, LT-13, SS-
05-F, SS-06-F,  and SS-07-F. The most frequently detected polycyclic aromatic hydrocarbons
(PAHs) in surface soil  samples  collected from the On Facility area included fluoranthene,
phenanthrene,  and  pyrene.    Surface soil  samples that contained  substantially  elevated
concentrations of these PAHs included RI samples  NESB-12, NESB15, NESB-20, NESB-26
and RAS-6A, and RD samples LT-1, LT-2, LT-6, LT-7, LT-12,  SS-06-F, and SS07-F.

Subsurface soil  samples  that contained substantially  higher concentrations of SVOCs included
RI boring samples NESB-02, NESB-05, NESB-06, NESB-07, NESB-08, NESB-09, NESB-11,
NESB-12, NESB-13, NESB-16, NESB-24, and NESB-25; shallow subsurface samples RAS-
1B, RAS-3B  and RAS-10B;  and  RD  samples SB-02 and SB-03.  The spatial distribution of
these  sample locations  was  generally  widespread across the  facility,  and the contamination
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occurred at several varied depth intervals.

Pesticides and PCBs
Selected  soil samples collected during the RD and RI were analyzed for pesticides and PCBs.
Pesticides and PCBs were generally not-detected or detected at low concentrations in most soil
samples collected from the On Facility area.

The  samples  with elevated concentrations  of one or more pesticides in surface soil included
sample RAS-4A behind the warehouse, sample RAS-6A behind the tank farm near the eastern
drainage ditch,  and  sample LT-5  in the  former PCB concentration  area. In addition, RD
sample SB-02 contained elevated concentrations of alpha-BHC, endosulfan, and heptachlor in
subsurface soil.

PCBs were generally not-detected (using  EPA Method  8081) with the  exceptions of a few
sporadic  detections of Aroclor 1248 (0.084 mg/kg in RAS-6B and 0.085L mg/kg in RAS-10B),
Aroclor 1254 (0.040J mg/kg in RAS-9B),  and  Aroclor 1260 (0.130J mg/kg in RAS-1B).   In
addition, elevated concentrations of Aroclor-1242 were detected in RD samples SS-07-F, SS-
08-F, SS-06-F,  SS-01-F, and SS-05-F.

EPA  Method 8081  (employed in  the analysis of  OU-3  soil  samples) determines PCB
concentrations by matching groups of PCB congeners (species) to the  groupings that were
found in commercial PCBs (i.e.,  Aroclors).  EPA Method 1668A detects and  reports the
concentrations of all 209 individual  PCB congeners, is less likely to  be impacted by  matrix
interferences, and is more sensitive than Method 8081.  Analyses of wetlands materials and site
groundwater using EPA Method 1668A showed significant PCB contamination in areas where
previous analyses using  EPA Method 8081 had failed  to detect any.  The  lack of OU-3 PCB
data generated  using  method 1668A represents  a possible data gap  that  would  have to  be
addressed before a definitive determination of site risks  related to  these compounds can  be
made.

Inorganics
With the exception of cadmium, cyanide,  selenium,  and thallium, all TAL inorganics were
detected  in almost every surface soil sample.  All TAL inorganics  (including  cyanide) were
detected in at least one subsurface soil sample collected from the On Facility area.  Most of the
samples  collected  from the On  Facility  area contained concentrations  of inorganics  that
exceeded  twice the  calculated background/reference  concentrations,  indicating  that  the
observed  concentrations of inorganics could be  site-related  (Black  & Veatch, 2007a).
Following a statistical analysis  of  the  inorganic contaminant data (performed  as  part of the
BLRA), it was determined that only aluminum,  chromium, iron, and manganese concentrations
at the site could be attributed to background.

Antimony, beryllium,  selenium,  silver,  and  sodium showed  the  most  exceedances when
compared to  background/reference concentrations.  Samples RAS-6B,  NESB-3, NESB-13,
NESB-14, NESB-15, and  NESB-25 contained  the highest numbers of  exceedances when
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compared  to  background/reference  concentrations.  These  samples  are  located  in  the
northeastern corner of the site (RAS-6B  and NESB-25), near the WWTP and eastern boundary
of the site (NESB-13, NESB-14, NESB-15), and in the former process area (NESB-3).

Dioxins/furans
Total 2,3,7,8-tetrachlorodibenzodiozin (TCDD) toxic equivalents (TEQs) in surface  soil ranged
from 89 picograms per gram (pg/g) in RI sample  RAS-2A to 26,769 pg/g  in sample RAS-4A.
The  highest concentrations  were observed in RI samples RAS-4A, and RAS-6A,  and RD
sample DF. Samples DF and RAS-6A are located in close proximity to each other, behind the
tank farm near the eastern drainage ditch in the  northeast corner  of the facility, and sample
RAS-4A is located behind the warehouse (Black & Veatch, 2007a).

Total 2,3,7,8-TCDD TEQs  in subsurface  soil ranged from 11 pg/g  in RI sample  RAS-8B to
279 pg/g in RI sample RAS-7B.  Concentrations of dioxins/furans were substantially higher in
RI subsurface  soil  samples RAS-7B  (former loading area) and samples RAS-10B and RAS-01B
(process  areas) than  in other samples collected from the On Facility area (Black  &  Veatch,
2007a).

1.5.1.2    Soil Gas Contamination

Thirty-four soil  gas  samples (24 from On  Facility and 10 from Off Facility areas) were
collected from two depth intervals (0- to 6-inch and  6-inch to 4-foot) and  analyzed for VOCs
during the RI  investigations. Four samples (RAS-15A/B and RAS-16A/B) were collected from
off site locations to represent background/reference locations assumed to be unaffected by site
activities. The soil gas sample locations are presented in Figure 1.4. The analytical results and
summary statistics for soil gas  are presented  in Table 4-10 and Table 4-11 of the  RI  Report,
respectively (Black & Veatch, 2007a).

The  highest concentrations of detected chemicals  were generally from samples collected from
On Facility locations within the 6-inch to 4-foot depth interval.  The VOCs  detected most
frequently  and at the highest  concentrations included  benzene,  1,2-dichlorobenzene,  1,4-
dichlorobenzene,   and  1,3-dichlorobenzene,  1,2,3-trichlorobenzene,  1,2,4-trichlorobenzene,
carbon tetrachloride, chloroform,  tetrachloroethene, and  xylenes.   These  chemicals were
typically detected in  all of the soil gas samples collected at the site (both On Facility  and Off
Facility areas).

Soil  gas concentrations were highest for  all of the site-related VOCs in samples collected from
location RAS-10 in the former process area.  Soils collected from  this location also contained
elevated  concentrations  of VOCs,  SVOCs,  inorganics,  and dioxins/furans.  Samples from
locations  RAS-2  and  RAS-9  (which  are  located  in  the  vicinity of  RAS-10) also had
considerably higher concentrations of the  site-related VOCs when  compared to the other soil
gas samples (Black & Veatch, 2007a).
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1.5.2   Northern Area Contamination

Most of the off-facility sampling covered areas not addressed by this FS.  Therefore, there are
limited data  available to characterize the nature and  extent of contamination found in the
Northern Area. Drum segments and solidified puddles of chlorobenzenes  were found near the
northern border of the On Facility area during construction of the Western Stormwater Basin.
Because  the contamination  related to these discoveries was  not delineated during  these
construction  activities,  there is  a concern  that this apparent  dumping area  might extend
northward beyond the former facility fence line.

During the RI, soil was  sampled from  multiple depths at three locations  within the Northern
Area.  Six chlorobenzene compounds  were detected at relatively  low concentrations  (total
concentration of  2.06 mg/kg) in  a surface  sample collected from one of the  three locations
(NESB-28) in this area.  No other COCs were detected in any samples collected from these
locations.   No dioxin or active soil gas samples were collected from this area. All of the
passive soil gas samplers that were deployed in this area exhibited no  or  relatively low levels
of contaminants.

1.6 CONTAMINANT FATE AND TRANSPORT

The main sources of contamination at the site include:
   •   Contaminated  surface and subsurface soils at the SCO facility
   •   Contaminated groundwater under the SCD facility
   •   Contaminated wetland sediments in Red Lion Creek and its unnamed tributary
   •   Residual contaminants deposited  on the site during plant operations

This section summarizes  the fate and transport potential for site-related contamination with the
emphasis on the  potential spread of contamination  from and to  the OU-3  soil and soil gas.
Detailed discussion of contaminant fate  and  transport, including the chemical-specific fate and
transport characteristics of the  main COCs, can be found in the RI Report (Black & Veatch,
2007a)

The migration pathways  from the  source areas include air migration pathways, surface water
flow and sediment transport pathways, and groundwater flow pathways.  Each of the potential
migration pathways is briefly described  below. The RI Report (Black & Veatch,  2007a) can be
consulted for further details.

1.6.1   Air Migration

The principal COCs  for the air  migration pathway include chlorinated  benzenes, benzene,
dioxins, and PCBs.   Although  a  major portion  of the VOCs likely  volatilized  into  the
atmosphere shortly after they were spilled  or  leaked from their  containers, the presence of
VOCs and SVOCs in surface and subsurface soils indicates the potential for vapor intrusion
into the facility warehouse,  GETS building, or future buildings at the site, or volatilization
during excavation activities.  Dioxins and PCBs are not volatile.   However, these compounds
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adsorb strongly to organic matter on the soil particles and can  become airborne if these soil
particles become dust emissions either through wind erosion or construction activities.

The potential for dust migration from areas of the former  manufacturing facility that  are
covered by impervious surfaces or grass, brush, or ballast is minimal since there are no large
areas of bare earth susceptible to wind-blown redistribution.  The former  eastern bone yard
(located east  and southeast of the largest tank farm) and the northern bone yard (located to the
north of the warehouse) are mostly bare earth with minimal vegetation.  Construction activities
related to the IGR have covered portions of these areas with imported  fill,  but there is still a
potential for dust migration from these two areas.  In recent years, with the ongoing demolition
and GETS construction activities occurring at the site, there have been  small areas  of exposed
soil and  stockpiles that would be susceptible to wind-blown redistribution. Wind directions at
the site  are  highly  variable  depending  on the  season  and  local weather conditions, with
prevailing  winds from the west.   Based  on the prevailing  wind  direction, distribution and
settling of this contaminated dust would be expected to be more significant to the  east of the
site in the direction of the Occidental Chemical plant and the Delaware River.

1.6.2   Surface Runoff and Migration

The majority of site-related COCs available for migration via the surface water pathway are in
sediments of the wetlands bordering the Red Lion Creek and its  tributary as well as at the
bottom of Red Lion Creek itself.  With respect to the OU-3  area,  surface water migration of
COCs occurs primarily through the transport of surface soils  and sediments in  stormwater
runoff.

As discussed  in Section  1.3.1, the site's storm  water management system has  been  altered
substantially as a result of demolition and IGR construction activities.  The vast majority of the
stormwater drains that used  to service the facility area have  been destroyed or otherwise
rendered inoperable.   In their place a system of drainage swales and ditches route  stormwater
to one of two stormwater and sediment control basins.   The  western basin discharges site
runoff through the western drainage gully and into the unnamed tributary wetlands, while the
eastern basin discharges stormwater overland to the wetlands that lie to the east of the  upland
portion of the site.    Stormwater  and suspended sediments  from  the  site  and  the discharge
pathways is transported downgradient, eventually reaching Red Lion  Creek.  The Red Lion
Creek discharges to the Delaware River approximately one mile east of the site.  A  tide  gate at
the mouth of the Red Lion Creek was installed to eliminate or minimize the  tidal effects of the
Delaware on the creek and prevent the transport of contaminated  sediments from the  site to
upstream areas (Black & Veatch, 2007a).

Because  of certain chemical properties  of most site contaminants and dilution in the Red Lion
Creek, detected concentrations of COCs in surface water have been, as expected, low relative
to those  found in the  groundwater and site soils. Chlorinated benzenes having three or more
chlorines in their structure (i.e., trichlorobenzenes, tetrachlorobenzenes, pentachlorobenzene,
and hexachlorobenzene), dioxins, and PCBs are strongly bound to organic material  in the soil.
Chlorobenzene and benzene  are not strongly bound to soil/sediment, but they are volatilized
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readily  and  undergo  degradation  processes  more readily  than their more  chlorinated
counterparts.  The more highly chlorinated benzene compounds, dioxins, and PCBs are known
to bioaccumulate,  and possibly biomagnify  in  food chains.  Therefore, organisms closely
associated with contaminated sediment (wading birds, amphibians, fish, and invertebrates) may
potentially accumulate contamination from the site and  transport bioaccumulative COCs into
food chains (Black & Veatch, 2007).

1.6.3   Groundwater Migration

Portions of the Columbia Aquifer  are contaminated with significant concentrations of benzene
and chlorinated benzenes.  The RI Report included a statement that PCBs and dioxins would
not be expected to be  significant groundwater contaminants (Black  & Veatch,  2007),  but
congener-specific analysis of recent Columbia Aquifer  groundwater samples has shown the
presence of PCBs at concentrations up to 10 times the drinking water standard.  Groundwater
from the Columbia Aquifer discharges into Red Lion  Creek and there is increasing  evidence of
a hydraulic connection between the Columbia Aquifer  and the underlying Potomac Aquifer.
These facts prompted implementation of the IGR (see Section 1.4.8).   The IGR includes the
GETS and a groundwater containment barrier. The GETS is being used to lower the Columbia
Aquifer groundwater elevation within the containment barrier alignment and impart an upward
gradient between the  Potomac and Columbia aquifers.  Because of the installation of the
containment barrier and the lowering of the Columbia Aquifer, the potential for migration of
contaminants from the on-facility  soil  via the  groundwater pathway is not expected  to  be
significant.

1.7 SUMMARY OF BASELINE RISK ASSESSMENT

The  Baseline Risk Assessment (BLRA)  Report (Black & Veatch, 2007) for  the SCD  site
includes detailed information on the human health and ecological risk assessment conducted in
2004. The findings of the BLRA Report are summarized  in the following sections.

1.7.1   Human Health Assessment

The Human Health Risk Assessment (HHRA) was conducted in accordance with the EPA Risk
Assessment Guidance for Superfund (RAGS) - Volume I  Human Health Evaluation Manual,
Part A (EPA, 1989),  Part D, Standardized Planning,  Reporting and Review of Superfund Risk
Assessments (EPA, 2001), and other appropriate  guidance (Black & Veatch, 2007).

1.7.1.1    Chemicals of Potential Concern

Over 100 constituents detected in various site media were screened by  eliminating  constituents
detected in blanks and comparing  maximum detected concentrations to risk-based screening
levels (EPA Region 3 Risk Based  Concentrations). Through this process, a large number of
constituents were selected as  Chemicals of Potential Concern (COPCs) for  the SCD site. A
summary of the  selected COPCs can be found in Tables  2.1  through 2.15 of BLRA Report
(Black & Veatch, 2007). Potential health risks and hazards were characterized based on the
selected COPCs for each relevant medium at each identified exposure area.
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1.7.1.2    Exposure Assessment

In exposure assessment, a fate  and transport analysis of the COPCs in conjunction with the
source area characteristics was used to identify the potential constituent migration and exposure
pathways at the SCD site. The  selected exposure  pathways considered most applicable to the
SCD site include:
   •   Future Ingestion of COPCs in Drinking Water from Wells in Columbia and Potomac
       Aquifers
   •   Future Dermal Absorption of COPCs in Water from Wells in Columbia and Potomac
       Aquifers
   •   Future Inhalation of Vapors Associated with Use of Water from Columbia and Potomac
       Aquifers for Showering
   •   Current/Future Ingestion of COPCs in Soil
   •   Current/Future Dermal Absorption of COPCs in Soil
   •   Current/Future Inhalation of COPCs in Dust
   •   Current/Future Inhalation of COPCs in Soil Gas Vapors (Indoor and Outdoor Air)
   •   Current/Future Ingestion of COPCs in Surface Water
   •   Current/Future Dermal Absorption of COPCs in Surface Water
   •   Current/Future Ingestion of COPCs in Sediment
   •   Current/Future Dermal Absorption of COPCs in Sediment
   •   Current/Future Ingestion of COPCs in Fish Tissue
   •   Current/Future Ingestion of COPCs in Duck Tissue

Exposure was quantified based on an analysis of the COPC exposure point concentrations for
each medium in each  exposure unit. The exposure  point  concentrations  for the reasonable
maximum exposure (RME) and central tendency  exposure  (CTE) are presented  in RAGS D
Tables 3.1  through 3.15 of the  BLRA Report  (Black &  Veatch, 2007). Intake was estimated
for receptors for each medium in each exposure unit.  The exposure equations and assumptions
used for the calculation of chemical intakes for the RME and CTE are presented in RAGS D
Tables 4.1 through 4.24 of the BLRA Report (Black & Veatch, 2007).

1.7.1.3    Toxicity Assessment

The toxicity assessment of the BLRA Report includes derivation of toxicity values based on the
available human health toxicological health effects criteria for each COPC and for each route
of exposure  identified for the  SCD site.   For carcinogenic  effects, the  available oral and
inhalation cancer  slope factors  and unit risk factors were  identified and presented for  each
constituent  classified  as a carcinogen by  the EPA, and dermal  cancer  slope factors were
calculated.   For chronic non-carcinogenic  effects, the available oral and inhalation reference
doses and reference concentrations were  identified and presented for each constituent.   In
addition, dermal reference doses were calculated.  The toxicity values used for each COPC in
each media  and each exposure  unit are presented in RAGS D Tables 5  and 6 of the  BLRA
Report (Black & Veatch, 2007).
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1.7.1.4    Risk Characterization

Potential  cancer  risks  and non-cancer  hazards associated with  exposures at each  of the
investigated areas at the SCD  site are discussed in the BLRA Report (Black & Veatch, 2007).
The  BLRA indicates that site-related contamination is present  in soils,  soil gas,  sediment,
surface  water,  groundwater,  and  fish tissue at concentrations that present an unacceptable
cancer risk or  non-cancer hazard to human health.  The BLRA's discussions of the  human
health risks associated with the OU-3 soil and soil gas are summarized below.

The  total On Facility cancer risk for exposure to OU-3 soil and soil gas ranged from 9.0E-04
for construction worker to  3.5E-02 for  age adjusted resident.   These risks exceed the  EPA
target risk range  of 1E-06  to 1E-04.  The primary On Facility cancer risk drivers are total
2,3,7,8-TCDD  TEQ,  hexachlorobenzene,  and   1,4-dichlorobenzene   in  soil   and  1,4-
dichlorobenzene,  benzene, carbon tetrachloride, chloroform, PCE and TCE in soil gas. The
total Off Facility  cancer risk for exposure to OU-3 soil and soil  gas ranged from 8.6E-06 for
construction worker to  2.0E-04 for age  adjusted resident.  These risks also exceed the  EPA
target risk range  of 1E-06  to 1E-04.  The primary Off Facility cancer risk drivers are total
2,3,7,8-TCDD TEQ and 1,4-dichlorobenzene in soil and 1,4-dichlorobenzene in soil  gas.

The  total  On  Facility  and Off Facility hazard  indices  exceeded  one  for  industrial and
construction workers as well  as adult and child residents,  indicating  the potential for a non-
cancer  effect.    The   primary  On  Facility  non-cancer  hazard  drivers  are  1,2,3,4-
tetrachlorobenzene and  1,2,4,5-tetrachlorobenzene in soil as well as 1,2-dichlorobenzene and
chlorobenzene  in soil gas.  The primary Off Facility non-cancer hazard drivers are 1,2,3,4-
tetrachlorobenzene  and  1,2,4,5-tetrachlorobenzene  in  soil and  chlorobenzene in  soil  gas.
Because the Off Facility driver development was based on sampling that occurred both within
and outside the Northern Area,  the cancer and non-cancer  risk drivers for the Northern  Area
may  need to  be  re-evaluated if  contamination in that area is  further delineated  through
additional sampling (possibly conducted as part of the RD).

1.7.2  Ecological Risk  Assessment (Surface Soil)

The  BLRA  concluded that there are potential risks to ecological  receptors via direct exposure
to site surface  water, sediment, and surface soil.  Potential food chain risks  were identified
through incidental ingestion of sediment and surface soil and  ingestion of contaminated food
items (plants and earthworms).  The risks related to the OU-3  soil are briefly discussed here.
The BLRA Report (Black & Veatch, 2007) should be consulted  for complete information.

A conceptual model defining the contaminant sources,  exposure  and migration pathways, and
receptors  of concern was used  to develop  and define  the  seven  assessment endpoints (AEs)
evaluated  in the BLRA.  The AEs related to the OU-3 soil are as follows:
   •   AE3:   Protection of nutrient cycling and terrestrial  invertebrate populations  in surface
       soils at the SCD  Site (upland forest):
   •   AE4: Protection  of herbivorous wildlife  populations at the SCD Site  (emergent
       wetlands, open water, forested wetlands, and upland  forest);
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    •   AE6:   Protection of terrestrial vermivorous  wildlife  populations at the SCD Site
       (upland forest).

The evaluation of AE3, AE4, and AE6 indicated of the potential for ecological risk from site-
related contaminants in terrestrial habitats associated with the SCD Site.  These risks include:
reduced abundance and diversity of plants and soil organisms as a result of direct exposure to
elevated  contaminant levels  (AE3); and potential reproductive toxicity from bioaccumulative
contaminants absorbed by soil invertebrates and plants  ingested by terrestrial herbivores (AE4)
and vermivores (AE6).  Contaminants  in soil at concentrations that present an ecological risk
include:

    •   Total chlorobenzenes and benzene          •   Aluminum
    •   Hexachlorobenzene                        •   Chromium
    •   4,4'-DDD                                •   Copper
    •   4,4'-DDT                                 •   Iron
    •   Total PAHs                               •   Lead
    •   Fluoranthene                              •   Mercury
    •   Phenanthrene                              •   Nickel
    •   Pyrene                                    •   Vanadium
    •   Pentachlorophenol                         •   Zinc

The BLRA indicated that uptake of a COPC by soil invertebrates is greater than that for uptake
by plants; therefore, vermivores would be more significantly exposed.  As a result,  remedial
goals that are protective  of vermivore communities will  also be  protective  of herbivore
communities.
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FIGURES

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                     HGL— Feasibility Study Report, Standard Chlorine of Delaware Site—
                                         New Castle County, Delaware
                                                                             Scale  1:44,782
                                                                             Source: Delaware
                                                                                   DataMIL
Filename: S:\EPA 010\PROJECTS - WORK ASSIGNMENTS\002
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                   v HGL
     Legend
Approximate Site
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          Figure 1.1

      Site Location Map
Standard Chlorine of Delaware
 New Castle County, Delaware
       SCD FS Report
                                             U.S. EPA Region 3
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                    HGL— Feasibility Study Report, Standard Chlorine of Delaware Site—
                   	New Castle County, Delaware	
    Approximate
    SCO Site
    Boundary
                                                                                   W>,Xte±i±
                                                           Temporary Soil
                                                           Storage Area
  Soil Bentonite
  Containment Barrier
  Alignment
Groundwater Treatment
System Building
      Northern Area
          Kfl
          Warehouse
          E^
Western Drainage Gully
                Eastern Drainage Ditch
                                                                                 Wastewater
                                                                                 Treatment Plant
                                                                             Drum Cleaning Area
   1986 Tank Collapse Area
           Rail Siding
           •
    Loading Area

                      Air Products Drainage Ditch
Filename: S:\EPA 010\PROJECTS - WORK ASSIGNMENTS'^
Standard Chlorine RIFSWSFilesWigures\Figurel-2.doc
Revised: 06/02/08 CW
Project: El 0002. 12. 01
Source:
v HGL

Legend
Approximate
Containment Barrier
Alignment
Figure 1.2
Site Layout
Standard Chlorine of Delaware
New Castle County, Delaware
                                                U.S. EPA Region 3
                                                                                 HydroGeoLogic, Inc. 5/15/09

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                    HGL—Feasibility Study Report, Standard Chlorine of Delaware Site—
                    	New Castle County, Delaware	
Soil Bentonite
Containment Barrier
Alignment
                                                                                    Approximate Extent
                                                                                    of OU-3
Filename: S:\EPA 010\PROJECTS - WORKASSIGNMENTS^002
StaiidaniC>ilorineXIFS\FSFile.,,fi!.m;,r fire j-4.doc
Revised: 06/02/08 CW
Project: FJ0002J20J
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Legend
| | Approx. Containment Barrier
Alignment
| 	 1 Approx. Extent o CU3
Figure 1.3
Approximate Extent of OU-3
Standard Chlorine of Delaware

          SCD FS Report
                                              U.S. EPA Region 3
                                                                                            HydroGeoLogic, Inc. 5/15/09


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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
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2.0  REMEDIAL ACTION OBJECTIVES

This section provides details about the desired outcomes of the remediation of the OU-3 areas.
Overall Remedial Action  Objectives (RAOs) are described first  in  Section 2.1.   This  is
followed by an examination of the government requirements that will  dictate or guide the
direction of any RA conducted for OU-3 and an initial discussion of specific impacts that they
might have on the implementation of the RA. To provide target cleanup levels that ensure the
RAOs  will be met by  the  RA,  quantifiable preliminary  remedial  goals  (PRGs) are then
developed  (where  possible).    Finally these  PRGs  are  used to estimate the   volume  of
contaminated materials that might require remediation to achieve the RAOs.

2.1 REMEDIAL ACTION OBJECTIVES

CERCLA requires that selected remedial actions attain a degree of cleanup that ensures the
protection of human health  and the environment. The cleanup remedy  must also be cost-
effective and provide permanent solutions. Remedial Action Objectives (RAOs) for the soil and
soil gas at  the SCD site are  generic goals that have  been developed to achieve protection of
human health and the environment.

RAOs for Human Health;
   •   Prevent exposure to non-carcinogens in  the  soil and soil gas at concentrations that
       would  result  in a target organ Hazard Index (HI)  greater than  1  via the potential
       exposure routes of inhalation, ingestion and dermal contact.
   •   Prevent exposure to carcinogens at concentrations  that would result in a  cumulative
       cancer  risk in excess of IxlO"5 (1E-05) via the potential exposure routes of inhalation,
       ingestion, and dermal contact.

RAOs for Environmental Protection;
   •   Prevent risks to ecological communities  exposed  directly to the  soil   COCs and
       indirectly via bioaccumulation of soil COCs in plants and earthworms.

RAOs for Limiting Further Migration of Contaminants;
   •   Minimize the further spread of contamination via any of the following major migration
       pathways:
       •   Soil to groundwater
       •   Soil to surface water
       •   Soil to sediment
       •   Soil to air

2.2 APPLICABLE OR RELEVANT  AND APPROPRIATE REQUIREMENTS

Section 121 to the CERCLA as part of the Superfund Amendments and Reauthorization Act
(SARA)  provides  the statutory basis for including ARARs in the remedy selection process.
Section 121(d) requires that primary consideration be given to remedial alternatives that attain
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or exceed all ARARs, and that valid justification for a waiver from a requirement be presented
if the selected alternative will not meet an ARAR.  SARA also provides for the inclusion of
promulgated, enforceable, state  standards  as ARARs as long as they are more stringent than
the related federal statutes. ARARs include:
    •   Any  standard, requirement, criterion, or limitation under  any Federal  environmental
       law,  such as  the Toxic Substances  Control Act (TSCA), the Safe Drinking Water Act
       (SDWA),  the Clean Air  Act  (CAA), the  Clean  Water Act  (CWA)  the Marine
       Protection, Research, and Sanctuaries Act (MPRSA), and  the Resource Conservation
       and Recovery Act  (RCRA)
    •   Any   promulgated  standard,  requirement,  criterion,  or  limitation  under  a  state
       environmental or  facility  siting law,  including those  contained in EPA-approved
       programs, which has been identified by the state to EPA in a timely manner.

ARARs  consist of two  sets of requirements,  those  that are  applicable and those that are
relevant  and  appropriate.  Applicable requirements  are  those  substantive standards  that
specifically address the situation at a CERCLA site. However, an applicable requirement need
not  have been promulgated specifically  to  apply  to CERCLA  sites.  When making  a
determination of the applicability of a requirement, the site circumstances are compared to the
following jurisdictional prerequisites:
    •   Who is subject to the statute or regulation;
    •   What types of substances or activities fall under the authority of the statute or
       regulation;
    •   What is the time period for which the statute or regulation is in effect; and,
    •   What types of activities does the statute or regulation require, limit, or prohibit.

If this comparison indicates that these prerequisites are met at the  site,  the requirement is
applicable.

Requirements that are not applicable must  be evaluated further to determine whether they are
relevant  and appropriate.   Requirements  that  address situations  sufficiently  similar to the
proposed response action and are well suited to the conditions of the site are considered to be
relevant.  For  a complete  determination  of relevance  and appropriateness,  the following
comparisons must be performed:
    •   The respective purposes of the requirement and of the response action;
    •   The medium regulated or affected by the requirement and the medium contaminated or
       affected at the site;
    •   The substances regulated by the requirement and those found at the site;
    •   The activities regulated by the requirement and the remedial  action contemplated at the
       site;
    •   Any variances, waivers, or exemptions of the requirement and their availability for the
       circumstances at the site;
    •   The type of place regulated and the  type affected by the release or action;
    •   The type and size of the structure or facility regulated, and those affected by the release
       or contemplated by the action; and
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    •   Any consideration of use or potential use of affected resources in the requirement and at
       the site.

In some cases, only portions of a requirement will be both relevant and appropriate.

In addition to the ARARs,  information that  is provided in certain federal and  state  criteria,
advisories,  guidance, and proposed standards, though not legally enforceable, can be helpful in
selecting a  site remedy and/or determining how protective the remedy will be.  These "to be
considered" (TBC) requirements complement the use of ARARs but do not to compete with or
replace them (EPA, 1992).

Potential chemical-specific,  location-specific,  and  action-specific  ARARs  for  OU-3  are
summarized in Table 2.1. These ARARs are considered potential because they become  final
only after the ROD is approved and issued.   The following sections provide additional details
on the  potential federal and state ARARs for OU-3.

As  stated in 52 Federal Register (FR) 32497,  chemical-specific ARARs typically, set health or
risk-based concentration limits or ranges in various environmental  media for specific hazardous
substances,  pollutants,  or  contaminants. At the SCD  site, chemical-specific ARARs  are
applicable to the contaminated site soils.  If a selected remedy generates air emissions  or spent
treatment media (such as spent carbon) the ARARs would apply  to these as well.   Similarly,
any alternative that includes generation of liquid waste that requires modifications or additions
to the  GETS, or additional  discharge to the  surface water, must comply with the applicable
standards.

Location specific ARARs  are  restrictions  on  certain  types  of activities  based  on  site
characteristics.    Location-specific  ARARs  govern  activities   conducted  within  critical
environments  such  as  wetlands, endangered  or  protected  species  habitats,  and  historic
locations.

Action-specific ARARs are  usually technology  or activity  based  directions or limitations  that
control actions taken at hazardous waste  sites.   Action-specific ARARs are triggered by the
types of actions under consideration.

The following are the ARARs that have been identified for OU-3:

Resource  Conservation  and  Recovery  Act,  and  Delaware  Regulations  Governing
Hazardous Waste
EPA has promulgated regulations pursuant to the Resource Conservation and Recovery  Act
(RCRA), as amended in 42 USC  §§6901  et seq.  These regulations,  and the  associated
Delaware Regulations Governing Hazardous Waste  (DRGHW),  define hazardous waste  and
regulate its handling and disposal.   The RCRA regulations that  are not administered by the
state of Delaware and the federally-authorized and the more stringent provisions of DRGHW
are applicable to OU-3 because some of the site soils are expected to be hazardous  and will be
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treated as hazardous wastes.  These regulations are applicable to contaminated site materials as
well as wastes generated during the implementation of the selected remedy (e.g., spent carbon
from any off-gas treatment units).

From 1966 until May 2002, the former chemical facility was used to manufacture nitrobenzene
and chlorinated benzenes (including chlorobenzene, 1,2-dichlorobenzene, 1,3-dichlorobenzene,
1,4-dichlorobenzene, and trichlorobenzenes). Benzene, which was used in the manufacturing
process,    and    highly    chlorinated    chlorobenzene    species    (tetrachlorobenzenes,
pentachlorobenzene, and hexachlorobenzene), which were generated as off-products during the
manufacturing process, are present  in site soils.  DRGHW Part 261 and 40 CFR Part 261
identify solid wastes that are regulated as hazardous  wastes.  These regulations will be used to
determine which materials  must be managed  as  hazardous wastes. Based on the results  of
remedial investigation (RI)  and remedial design (RD) characterization efforts and portions of
DRGHW or the RCRA regulations  [DRGHW  sections 261.33(d) and (f); 40 CFR 261.33(d)
and (f)],  site soils may be classified as one or more of the following waste types:
       U037 - chlorobenzene
       U070-1,2-dichlorobenzene
       U071 - 1,3-dichlorobenzene
       U072-1,4-dichlorobenzene
       U127 - hexachlorobenzene
       U183 - pentachlorobenzene
       U207 - 1,2,4,5-tetrachlorobenzene
       U169 - nitrobenzene

Alternatively,  soil waste  types could be classified because  of toxicity characteristics if they
meet the concentration requirements  specified in DRGHW § 261.24(b) and 40 CFR 261.24(b).
Based on observed concentrations  in site soils,  potential classifications for  excavated materials
under this section include:
       D021 - chlorobenzene
       DO 18 - benzene
       D027 - 1,4-dichlorobenzene

RCRA regulations would be superseded in those cases where  Delaware  has  been  delegated
authority from EPA to administer the law. Additionally, any state provision that is not a part of
the authorized program, and that is more stringent than the federal requirement, would also be
applicable. The  following  parts  of the  DRGHW  and  RCRA  regulations are considered
applicable to the OU-3 alternatives at the SCO site unless otherwise noted:
    •   DRGHW Part 262 Subpart A (Sections 262.10-262.12) and Section  262.34 and 40 CFR
       Part 262 Subpart A (Sections  262.10-262.12) and Section 262.34 establish standards for
       hazardous waste determinations and regarding accumulation time, which are applicable
       to generators of hazardous waste.   The substantive requirements of these sections are
       considered applicable to the RA activities.
    •   DRGHW 264 Subpart G (Sections  264.110-264.120) and 40 CFR  Part 264 Subpart G
       (Sections 264.110-264.120) establish standards for the closure of, and post-closure care
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       for,  sites  containing  hazardous  wastes.    The  substantive  requirements  of these
       regulations are applicable to any remedial alternative selected for the site.
    •   DRGHW Part 264 Subpart I (Sections 264.170-264.179) and 40 CFR Part 264 Subpart
       I  (Sections 264.170-264.179)  establish  requirements for  containerized  storage  of
       hazardous  waste.  The substantive  provisions  are applicable  to temporary storage
       containers and on-site treatment systems.
    •   DRGHW Part 264 Subpart L (Sections 264.250-264.259) and 40 CFR Part 264 Subpart
       L (Sections 264.250-264.259) establish  standards for owners and operators of facilities
       that store  or treat hazardous waste  in waste piles. The substantive provisions of this
       subpart are applicable to any soil or sediment that is excavated and stored in waste piles
       before or during treatment.
    •   DRGHW Part 264 Subpart N (Sections 264.300-264.317) and 40 CFR Part 264 Subpart
       N (Sections 264.300-264.317) establish standards for owners and operators of facilities
       that store or dispose of hazardous  waste in landfills. The substantive provisions of this
       subpart are applicable  to remedies that include on-site  landfilling of contaminated soils
       and sediments.  The requirement  to  construct a liner system will not be  met by a
       capping alternative.  Instead, any cap will be tied  into the soil bentonite  containment
       barrier that was installed  as  part  of  the IGR.  This barrier is keyed  into a low
       permeability layer that lies between  the contaminated soils of the  Columbia Formation
       and the underlying drinking water aquifer (the Potomac).   This method of construction
       will  isolate  any contaminated OU-3  soils  left  under   the  cap  from  surrounding
       uncontaminated  areas.  As a result,  the capping alternative will attain a standard of
       performance  that is equivalent to the  standard that  would  be attained  through the
       construction of a liner system. As a result, this ARAR is  waived pursuant to 40 CFR
       Section 300.430 (f)(l)(ii)(C)(4).
    •   DRGHW Part 263 Subpart C and 40 CFR Part 263 Subpart C establish standards for
       the  cleanup of  hazardous  waste discharged during transportation.   The substantive
       provisions of this subpart would be applicable to any hazardous wastes  that is spilled on
       site during  transportation.

Clean Water Act  (CWA)
The substantive requirements  of the CWA's National Pollutant Discharge Elimination System
(NPDES) are applicable to alternatives  that would include  remedial construction activities that
could impact stormwater quality and remedies that generate water requiring treatment through
the GETS  before being discharged.   Previously constructed sediment  and erosion control
features will  be used (and upgraded as needed) to prevent/minimize sediment  run  off resulting
from construction activities.  Stormwater must be sampled and analyzed in accordance with the
NPDES permit equivalence that is in place at the  site, which is included in Appendix  B.  If the
selected remedy utilizes the GETS, the requirements of the NPDES permit equivalence would
have to be met.

Delaware Regulations Governing the Control of Water Pollution
The Delaware Regulations Governing the Control of Water Pollution govern point-source and
non-point  source discharges to Delaware  waters.  The rules include requirements for permits
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and monitoring.  These regulations prohibit unpermitted discharges of pollutants into surface
waters. Permits will not be obtained at the site. The substantive provisions of these regulations
are applicable for remedial actions involving treatment system discharges to surface  water as
well as for stormwater discharges that impact the  Red Lion Creek and its unnamed tributary.
These provisions were considered in determining the NPDES permit equivalence limits.

State of Delaware Surface Water Quality Standards
These standards set forth water quality standards for surface waters of the State. The standards
are based upon water uses that are to be protected and are considered by the DNREC  in its
regulation of discharges to surface waters.  In the case of the SCD Site, the designated uses of
the Red Lion Creek, along with federal drinking water standards, were considered during the
development of the NPDES permit equivalence for the site.  The designated uses  for Red Lion
Creek are:
       Public water supply source (goal use);
       Industrial water supply;
       Primary contact recreation;
       Secondary contact recreation;
    •   Agricultural water supply (fresh water segments only); and
    •   Fish,  aquatic life, and wildlife  (DNREC, 2004).

These standards are  applicable to point and non-point discharges  (including stormwater and
GETS effluent) from the site to surface water.  The water quality standards  will be complied
with as part of meeting the substantive requirements of the NPDES permit equivalence.

Coastal  Zone  Management Act  (16 USC   Section  1451)   and  Coastal Zone  Act
Reauthorization Amendments of 1990
This Act and its Amendments require  that any activities that directly affect the coastal zone and
are conducted or supported by federal agencies be performed in a manner that is consistent
with the  enforceable  policies of  the approved  state coastal  zone  management program.
Because  the  SCD Site is  located  in the  Delaware  coastal  zone,  the Act  and the related
Amendments are  applicable to the site. All RA activities  will be performed, to the maximum
extent practicable, in  a manner consistent with the enforceable policies of Delaware's coastal
zone management program.

Delaware Coastal Zone Act  (7  Delaware Code Sections  7002-7003) and the Delaware
Regulations Governing Delaware's Coastal Zone
This statute and  regulations  control the location,  type, and extent of industrial activities in
Delaware's coastal areas.  The site is located in the coastal zone. Section E of the regulations
specifically allows the  "installation and modification of pollution control and  safety equipment
for nonconforming uses within  their  designated  footprint  providing such  installation and
modification does not result in any negative environmental impact over and above impacts
associated with the present use."   Consequently, the  bulk of the activities associated  with this
remedial action would be allowed.  It is expected, however,  that the  act's prohibition on the
placement  of incinerators  in  Delaware's  coastal  zone would prevent the  use of on site
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incineration to treat soils.  Similarly, redevelopment of the site for heavy industrial use would
be prohibited.

Archaeological and Historical Preservation Act of 1974 (16 USC Section 469)
This Act outlines requirements to guard against the loss of significant scientific, historical, or
archaeological data.   This Act is considered applicable to the  site and  will therefore require
that  an effort be made to identify any potential  resources  that might  be  put at  risk by the
construction activities related to the OU-3 remedies.  Because previous  construction activities
have been conducted in the area being  addressed under this  FS Report,  it is unlikely that this
ARAR will  affect RA activities. However, if any such resources are identified, steps will be
taken to minimize the potential for any adverse impact.

National Historic Preservation Act (16 U.S.C § 470)
This Act, and its implementing regulations, requires that federal agency actions avoid adverse
effects on  historic  properties.  EPA does not have  any information that there are historic
properties at the site. If historic properties are found on or near the site,  action will be taken to
mitigate any adverse effects on those properties resulting from the remedial activities.

Protection of Wetlands (40 CFR Section 6. 302(a))
These  regulations codify  the EPA  policies for  carrying  out Executive  Order 11990.  These
regulations require that activities within wetlands be conducted in a manner that avoids adverse
effects, minimizes potential harm,  and restores and  preserves the beneficial values of these
areas.  Although none of the potential OU-3 remedies include construction activities within the
site wetlands, these regulations are  applicable because of the  potential for stormwater runoff to
impact the  wetlands  surrounding   Red Lion Creek and its unnamed tributary.   Previously
constructed  sediment and erosion  control features will be used (and upgraded as needed) to
prevent/minimize sediment run off from impacting the nearby wetlands.

Delaware Regulations Governing Hazardous Substance Cleanup
Similar to CERCLA and the National Contingency Plan,  the Delaware Regulations Governing
Hazardous Substance  Cleanup (DRGHSC) lay out procedures for  the cleaup  of hazardous
waste  sites.   Subsection 9.3 of the DRGHSC, pertaining to surface water cleanup  levels, is
applicable to the cleanup of soils,  groundwater that  discharges to water bodies, and surface
water at the SCO Site.

Toxic  Substances Control Act
TSCA was  enacted  to  regulate  chemical substances  and  mixtures  whose  manufacture,
processing,  distribution, or disposal might present an  unreasonable  risk of injury to  human
health  and the environment. The  purpose of the act was to regulate commerce  and protect
human health and the environment by requiring testing and necessary use restrictions on certain
chemical substances.  Portions of the TSCA deal specifically with PCB  remediation waste and
are applicable to this site.  TSCA defines occupancy areas and identifies varying PCB cleanup
levels for these areas.  The  "low occupancy areas" (as defined in 40 CFR 761.3) classification
would  likely suit most portions  of  this site following remediation.  There  have  not  been any
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samples collected that exhibit PCB concentrations greater than the 25 parts per million cleanup
level specified for low occupancy areas.  These regulations also define what is considered a
"high occupancy area" and provide more stringent cleanup levels for  this  type of area.   40
CFR 761 provides requirements for the handling and disposal of soils contaminated with PCBs
at concentrations in excess of the regulation-specified cleanup levels.

Delaware Regulations Governing the Construction and Use of Wells
These  regulations establish requirements for the construction,  location,  repair, use,  and
abandonment of wells and pumping equipment. The substantive provisions of these regulations
are applicable to the construction,  modification,  and abandonment  of monitoring wells,
extraction wells,  piezometers, and temporary injection points.  Construction, modification, and
abandonment (where applicable) of these  features  will be performed in accordance with the
substantive requirements of these regulations.

Delaware  Statute  Regarding Licensing of Water  Well  Contractors, Pump  Installer
Contractors, Drillers, Pump Installers,  Septic Tank Installers,  Liquid Waste Treatment
Plant Operators and Liquid Waste Haulers.
These regulations are applicable to activities at the SCD  Site.   Any drilling, installation or
abandonment activities pertaining  to  monitoring  wells,  extraction wells,  piezometers,  and
temporary injection points will be conducted by properly licensed workers.

Delaware Sediment and  Stormwater Regulations
These regulations establish a statewide stormwater and sediment management program.   The
substantive provisions are applicable to stormwater from the SCD site.

State of Delaware Implementation Plans  for Attainment  and Maintenance  of  National
Ambient Air Quality Standards (codified at 40 CFR  Section 52, Subpart I) and Delaware
Air Quality Management Regulations
These regulations establish ambient air  and emissions standards at the  state and  county  level
and set forth the permitting requirements for equipment and construction activities that might
discharge air contaminants into the atmosphere.  The regulations are applicable to air strippers,
SVE systems,  and soil gas capture systems.  The substantive requirements of these regulations
will  be  met and vapor phase carbon  will be used  to treat the  air stripper off-gas before
discharge to the  atmosphere.  If an SVE or soil gas capture system is employed as part of the
selected remedy  and the  system(s)  is anticipated to emit pollutants at a rate greater  than that
prescribed in the regulations, emissions controls (such as vapor phase carbon) will be required.
Additionally, excavation  activities  will  implement dust suppression measures in accordance
with the regulations.

2.3 DETERMINATION OF REMEDIATION GOALS AND DESCRIPTION OF
    CONTAMINATED  MEDIA

2.3.1  Derivation of Risk-Based Preliminary Remediation Goals

PRGs are  risk-based  concentrations  used as initial cleanup  goals. PRGs  are  not  the  final
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cleanup standards.  However, they are helpful in providing long-term targets to use during the
analysis of different remedial alternatives.

PRGs protective of both human health  and  environment were developed for all  COCs in the
soil and soil gas.  The COCs are those chemicals that were determined to pose  unacceptable
human health or ecological risks in the BLRA (Black & Veatch, 2007). Development of the
human health and  ecological PRGs is  discussed  in the following  subsections. Detailed PRO
calculations are included in Appendix A of this document. PRGs were calculated separately for
the On Facility  area and  the Northern Area (as shown in Figure  1.2). The lowest of the
ecological and human health risk PRGs was retained  as the final PRG for each COC in each
medium. The On Facility and Off Facility COCs retained for the FS are listed along with their
corresponding PRGs in Table 2.2 and Table  2.3, respectively.

It  should be noted that PRGs for the Northern Area were developed using Off Facility  data
from the RI.  While these Off Facility data include samples from the Northern Area, additional
samples from other portions of the site  are also included.  It is expected that these PRGs will
be protective of human  health  and the environment  in  the  Northern  Area.  However,  if
delineation sampling conducted  in the Northern Area as part of an RD for the  site  indicates
otherwise, these PRGs will need to be revisited.

As part of the PRG development process for OU-3 at the SCO Site the following sources of
information were considered:

EPA Region 3 Risk-Based Concentrations  Table, October 2007
The EPA Region 3 Risk-Based Concentration (RBC) table provides soil concentrations that are
associated with a cancer  risk of 1E-06 or a non-cancer hazard quotient  of 1 for a  standard
resident exposure (residential soil RBCs) or  industrial worker exposure (industrial soil RBCs).
In addition, this table provides toxicological  information that can be used in the development of
PRGs to protect human health.

Oak Ridge National Laboratory Ecotoxicological Screening Benchmarks (1997)
This document  provides  non-enforceable  ecological toxicity screening levels  for use in
determining  ecological PRGs. Based on communications with the EPA, these benchmarks will
be considered in the development of ecological PRGs for the SCD site.

EPA Soil Screening Levels
This document  provides  non-enforceable  ecological toxicity screening levels  for use in
determining  ecological PRGs. Based on communications with the EPA, these benchmarks will
be considered in the development of ecological PRGs for the SCD site (EPA,  2008).

Development of Human Health PRGs
Human health risks were established in the BLRA for the following  COCs in soil and soil gas:

   •   Benzene
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   •   Chlorobenzene
   •   1,4 Dichlorobenzene
   •   1,2 Dichlorobenzene
   •   1,2,3,4 Tetrachlorobenzene
   •   1,2,4,5 Tetrachlorobenzene
   •   Hexachlorobenzene
   •   Chloroform
   •   Carbon tetrachloride
   •   PCE
   •   TCE
   •   TCDD (dioxin)

Free phase dense non-aqueous phase liquid (mobile  DNAPL) has been historically detected in
several monitoring  wells and extraction wells  in the Columbia  Aquifer  across the site and
within the barrier containment. Contaminant concentrations in most of the  monitoring wells
and  extraction wells  screened  in the Columbia  Aquifer and  located  within the barrier
containment suggest that DNAPL is located in close proximity.  Therefore,  PRGs for the on-
site soil to prevent the degradation of the Columbia Aquifer were not developed  because  a
source in  the form  of mobile and  residual  DNAPL is present throughout the aquifer on site.
Additionally, the groundwater contamination within the  OU-3 area is being  addressed as part
of OU-1.  It is doubtful that the further leaching of soil contamination will have a substantial
negative impact on the quality of groundwater in contact with DNAPL. Consequently, this FS
employs a more general goal of minimizing infiltration  of precipitation through contaminated
soils instead of developing  COC-specific PRGs that address the soil to groundwater pathway.
This  generalized  goal can  be   achieved  either  through  the  removal/treatment  of  the
contamination or the minimization of precipitation infiltration.

PRGs based  on human health  risk were  calculated for each medium of concern  and COC
identified  in the BLRA  and  RI. The site  receptors considered  were trespasser/visitor,
residential, industrial worker, and construction worker receptors.  Media were combined for a
total target risk when one receptor would be exposed to both media (soil and soil gas).

For carcinogens, PRGs were calculated for two target cancer risks. The first target cancer risk
was 10~6 for each COC.  The second target risk was developed to  result in a total cancer risk of
10~5 across all COCs and all  media.   For this calculation, the target  risk for each  COC was
determined by dividing 10~5 by the number of carcinogenic COCs within each medium.  The
10~5 target total risk was used as a maximum allowable total risk  level in accordance with the
DRGHSC.

For non-carcinogens,  the target HI of 1 was divided by the number of chemicals in soil and
soil gas that affected the same target organ to determine the target hazard quotient (HQ)  for the
individual COCs.

Once the  target risks and HQs were  calculated for the  COCs, PRGs were  derived from the
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exposure point concentrations (EPCs) for each chemical and corresponding site risks presented
in the BLRA by solving the following equation for the PRO:

                  EPCI (Site Risk or HQ)  = PRO I (Target Risk or HQ)

The PRO calculated using the carcinogenic 10~6  risk level was compared to the PRO for an HI
of 1, and the lower of these two PRGs was selected as the minimum end of the PRO range for
that chemical, medium, and receptor.  Similarly, the PRO calculated using the carcinogenic
10~5 risk level  was compared to the PRO at the  HI of 1, and the lower of the two became the
maximum end of the PRO range for that chemical, medium, and receptor.

Taking  into account the site history and location, the final human health PRGs were selected
based on the cumulative cancer risks of 10~5 for commercial,  industrial and trespasser targets.
Although the cancer-risk trigger level for a chemical to be identified as a COC was significant
contribution to a  cancer risk above 10~4, the 10~5 risk level was used in the determination of
human-health  PRGs to ensure compliance with the DRGHSC.   Residential PRGs were  not
retained because the likelihood of the site becoming a residential property is  extremely low.
Institutional Controls (ICs) prohibiting  residential use will be necessary if final cleanup  goals
are not based on residential (unrestricted) use.

Development of Ecological PRGs
The BLRA evaluated  ecological risks resulting  from several  routes of exposure.  For OU-3,
the only pertinent receptors are terrestrial receptors because this OU  does not include any
aquatic  habitat.  To develop ecological PRGs for surface soil that are protective of terrestrial
receptors  the  following AEs  and measurement  endpoints  (MEs) from  the  BLRA  were
considered.
   •   AES -  Protection of nutrient cycling and  terrestrial invertebrates
   •   AE4 -  Protection of herbivorous wildlife
   •   AE6 -  Protection of terrestrial vermivorous wildlife
   •   ME3.1 -  Compare surface soil  concentrations to  those known to adversely affect
       nutrient cycling and terrestrial invertebrates
   •   ME4.1 - Estimate food chain exposure for terrestrial herbivores and  compare to no
       observed  adverse effects level  (NOAEL) and  lowest  observed adverse effects  level
       (LOAEL) toxicity reference values
   •   ME6.1 -  Estimate food chain exposure  for terrestrial  vermivores and compare to
       toxicity reference values (NOAELs and LOAELs).

It should  be noted that while the BLRA grouped  total chlorobenzenes and benzene as a
category,  separate PRG analyses  were performed for benzene  and each  of the  individual
chlorobenzene compounds.

The BLRA  did not distinguish between chemicals that resulted from background conditions
(metals) and site-related chemicals.  Therefore, site-specific  metals data were compared to
background concentrations.    Aluminum,   chromium,  iron,  manganese,  and   vanadium
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concentrations in soils within the facility fence line were reported to be statistically equal to
background levels in the BLRA.  Vanadium concentrations in soils outside  the facility  fence
line were reported in the BLRA to be statistically equal to background levels (Black & Veatch,
2007).   As a result, these metals are not included in the COC list, and samples in which these
contaminants would have been the only ones exceeding  their PRGs were  discounted  when
calculating soil areas and volumes requiring treatment and/or containment.

Nutrient Cycling and Terrestrial Invertebrates (AE3, ME3.1)
To  evaluate  potential  effects to nutrient  cycling  and terrestrial invertebrates, the BLRA
compared maximum detected concentrations in surface soil samples to the EPA  Region 3
Biological  Technical  Assistance  Group (BTAG) Soil Screening Values.   Based on this
comparison,   total   chlorobenzenes,    benzene,    hexachlorobenzene,   2-methylphenol,
dichlorodiphenyldichloroethane     (DDD),     dichlorodiphenyldichloroethylene    (DDE),
dichlorodiphenyltrichloroethane  (DDT),  PAHs,  pentachlorophenol, aluminum,  antimony,
beryllium,  chromium, cobalt,  copper,  iron,  lead,  manganese,  mercury,  nickel,  thallium,
vanadium,  and zinc were identified in the  BLRA as  potentially presenting a risk to nutrient
cycling  and the  soil invertebrate community (Black & Veatch,  2007).   The EPA  Region 3
BTAG Soil Screening Values are conservative screening levels intended to protect all potential
ecological receptors, not just soil invertebrates and microorganisms.  Thus, a concentration
above this screening  value might  not pose a  threat to nutrient cycling and the  terrestrial
invertebrate community.  To identify  the chemicals that could pose a threat for this AE,  the
following approach  was used:
   •   Maximum detected concentrations of the compounds listed above were compared to the
       Ecological Soil Screening Level (Eco-SSL) for  terrestrial invertebrates,  the Eco-SSL
       for  plants,  the Oak  Ridge  National  Laboratory  (ORNL) benchmark  value  for
       earthworms, the ORNL benchmark value for soil microorganisms/microbial processes,
       and the  ORNL benchmark value  for plants (ORNL,  1997).   The  Eco-SSLs and
       benchmark values are listed in Appendix A.
   •   Benchmark values are not available for benzene, DDD, DDE, DDT, 2-methylphenol,
       thallium,   1,2-dichlorobenzene,  1,3-dichlorobenzene,  1,2,4,5-tetrachlorobenzene,  or
       1,3,5-trichlorobenzene.
       0  For the dichlorobenzenes, the concentrations of the three isomers were summed and
          compared to the  available benchmark value  for 1,4-dichlorobenzene.
       0  For 1,2,4,5-tetrachlorobenzene,  its concentration was added  to  that for 1,2,3,4-
          tetrachlorobenzene  and  the  sum  was   compared  to  the  available   1,2,3,4-
          tetrachlorobenzene benchmark value.
       0  1,2,3-Trichlorobenzene and 1,2,4-trichlorobenzene have the same benchmark value.
          The concentrations  of  the three trichlorobenzene  isomers  were  summed and
          compared  to 20  mg/kg,  the  available  benchmark  value  for   both  1,2,3-
          trichlorobenzene and 1,2,4-trichlorobenzene.
       0  For  benzene, DDD,  DDE,  DDT,  2-methylphenol, and thallium,  quantitative
          evaluations were not performed due to the lack of benchmark values.

Based on this evaluation, chemicals  were identified as  COCs for nutrient cycling and  terrestrial
                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                       Delaware

invertebrates. These chemicals are listed along with the results of the above screening analysis
are in  Appendix A.   The PRO for each nutrient cycling/terrestrial invertebrate COC is the
lowest  available benchmark value.

Terrestrial Herbivores (AE4, ME4.1)
The BLRA indicated that three contaminants (copper, mercury, and zinc) present a food chain
risk to terrestrial herbivores  at the site (Black & Veatch, 2007).  The food chain model,
toxicity reference values (TRVs),  and biotransfer factors (BTFs)  presented in Tables 3-11
through 3-13 of the BLRA were used to calculate the soil concentration that would result in an
HQ of  1 for the NOAEL and LOAEL. The  resulting NOAEL and LOAEL PRGs are provided
in Appendix A of this document.

Terrestrial Vermivores (AE6, ME6.1)
The BLRA  indicated that 11 contaminants (copper, lead, zinc, DDD,  DDT, fluoranthene,
hexachlorobenzene, pentachlorophenol, phenanthrene, pyrene,  and TCDD) present a food
chain risk to terrestrial vermivores at the site (Black & Veatch, 2007).  Similar to the approach
described  above for terrestrial herbivores, the  food chain model, TRVs, and BTFs provided in
the BLRA were used to calculate NOAEL  and LOAEL  PRGs.  The target HQ was 1.   The
calculated NOAEL and LOAEL PRGs are provided in Appendix A of this document.

The PRGs calculated for pentachlorophenol and hexachlorobenzene were less  than the EPA
Region 3 BTAG Soil Screening Values (identified in Table 3-9 of the BLRA).  Because of the
very low PRGs calculated for these chemicals (10~5 to 10"4 mg/kg), it was recommended that
the EPA  Region 3  BTAG  Soil  Screening Value or the Eco-SSL for  avian receptors be
identified  as the  PRG.   The  BTAG  agreed that the pentachlorophenol  PRG  should be
established at the Eco-SSL for avian receptors  (2.1 mg/kg).

2.3.2   Volume Estimates

To determine the volume of soil requiring remediation, concentrations of COCs in soil and soil
gas samples in the RI Report (Black & Veatch, 2007) were compared to the  corresponding
PRGs developed as part of this FS.  Locations where COCs were detected at concentrations in
excess  of the PRGs are included in the area requiring remediation.

Direct  contact, inhalation, and ingestion of soil particles are  the main routes  of human and
ecological exposure.  Twelve feet is the maximum depth one would reasonably expect that any
future construction activities  at the site would  reach.  Thus, 12 feet represents  the base of the
soil for which there  is a reasonable expectation of a complete exposure pathway  for human
health-related risks.   ICs will  be  required to prevent  disturbance of  soil below  12 feet.
Ecological risks are only expected to be relevant in the biologically active zone  (considered to
be from 0 to 2 feet bgs).  As a result, the vertical depth  of the soil contaminant concentration
to PRG comparison was limited to  12 feet bgs for human-health driven PRGs and 2 ft bgs for
ecologically driven PRGs.  In those  areas where a surface sample represents the only available
data and contaminants exceeded the human health PRGs, it was conservatively assumed that
the full 12 ft depth would exceed the human  health PRG.
                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                          Delaware
Locations with samples collected at depths up to 12 ft bgs that have COC concentrations above
one or more PRGs are presented on Figure 2.1.  This figure shows widespread contamination
throughout the facility  portion of the site.  Based on the distribution of contamination,  it is
expected that the entire area within the  former facility fence line will require remediation.  A
review of the mapped data revealed that samples from 54 of the 65 locations within the former
facility area had at least one contaminant present at concentrations greater than  its  PRO.   This
includes 30 of the 40  locations where subsurface soil samples were collected at depths up to  12 ft
bgs.  Soil gas concentrations exceeded at least one PRO in samples collected from eight of the 10
locations where soil gas samples were analyzed.

Although 25 dioxin samples were collected from 15 locations within the former facility fence line,
subsurface data  are  only  available  for 10  of  these  sample  locations  (See Figure  2.2).
Additionally, all of the subsurface data are from samples that were collected from depth intervals
of 2 to 4 ft bgs.  Dioxins were detected at concentrations greater than the PRO  in 14 of the 15
surface soil  samples and 8 of the 10 subsurface  samples.  While dioxins are not typically  very
mobile in soils, the lack of data from depths greater than 4 ft, combined with the prevalence of
subsurface exceedances in the  available  data, makes it difficult  to  rule out the  possibility  that
dioxin contamination could extend to the  12 foot depth limit on the soil identified for remediation.
It should be noted that  in nine of the 10 locations where  surface and subsurface (2 to 4 ft bgs)
dioxin data are available, concentrations decreased substantially (by a median factor of 4.54) with
depth.   One additional dioxin sample was collected as  a background  sample just outside the
facility fence line in the southeast corner of the SCD Site  property.   Dioxin levels in this surface
soil sample exceeded the dioxin PRO.

One possible area that might not require remediation is the far southwest corner of the facility
(an area of less than one acre)  where none of the samples from  boring NESB-1 had COCs
present  at concentrations greater than their respective soil  PRGs.   An additional soil boring
(SB-1) from this area also was free of contaminants at concentrations  greater than the PRGs,
but this sample was collected from a depth  of approximately  30 ft bgs.  Although there are a
few locations to the north of the warehouse where contaminant concentrations  in samples did
not exceed the PRGs,  these are either  adjacent to locations with samples that exceeded the
PRGs or in  areas with other evidence of contamination (such as the drum remnants and waste
material found to the  north of the warehouse).

2.3.2.1    Volume to Address Soil Risk

From a soil contamination perspective,  it  appears that  any  remedy will  need  to  address the
entire portion of the facility area that  lies within the containment barrier (22.8 acres).  In
general, the data indicate  that the remedy will need to address soils  to a depth of approximately
12 ft across  the  vast majority of this area, although it appears that  some areas might  only
require  remediation to  depths  of approximately 2 ft bgs to mitigate  soil risks.  These  areas
include  the  southwest corner  of the facility (approximately  1.6 acres), portions  of the  area
between  and to the north of the warehouse and the northeast  tank farm  (approximately 1.6
acres), and an area along  the eastern fence line extending from north of the drum cleaning area
                                      U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

to the northern facility boundary (approximately 2.4 acres).  Taking into account these reduced
depth areas, the volume of site soils requiring RA to address soil risks (excluding those from
soil gas) equals 351,060 cubic yards.

2.3.2.2    Volume to Address Soil Gas Risk

In the calculation of soil volumes requiring remediation to  address  soil gas risks,  all  soils
within the vadose zone were considered  to  be contributory to detected  soil  gas  contaminant
levels. As discussed earlier, the GETS is being used to lower the groundwater elevation within
the walled area, so the future depth to groundwater is expected to be approximately 50 ft bgs.
An initial  volume calculation approach assumed that a 50-ft radius around each of the soil gas
sample  locations where at least one contaminant exceeded its PRO would require remediation
to a total depth of 50 ft (the  expected depth to groundwater resulting from the ongoing GETS
operation).   Because  of the limited  available soil  gas sample data and the fact  that the
suspected/known "hot  spots"  listed  above  overlapped  the  soil gas  sample locations,  this
approach was altered to one in which all vadose  zone soils associated with each of the  "hot
spots" (with the exception of the  warehouse) were assumed to require  remediation to a total
depth of 50 ft.  For the purposes of these volume calculations, approximately half of the  soils
underlying the  warehouse  and  its  surrounding  area  were  assumed  to be  contaminated.
Estimated areas of contamination associated with each hot spot were obtained  from AutoCAD*
using the surveyed site map with a minimum area of 10,000 square ft assigned for each area in
question.   The revised method  resulted in  an estimate of  464,650  additional  cubic yards
requiring remediation to address risks related to soil gas. When  combined with the volume of
soil requiring remediation to address  soil risk, a total remedial soil volume of 815,710 cubic
yards is expected for the on facility area.   The fact that eight of the ten soil gas samples from
the On  Facility area had at least one  contaminant present in excess of its PRO might indicate
that additional soil volumes within the facility fence line will require remediation.

2.3.2.3    Volume to Address Potential Northern Area Risk

Using a worst  case scenario for risks from  soil in the Northern Area portion of OU-3, it is
estimated  that an additional 1.4 acres of  soils (beyond those  found within the former facility
fence line) will need to be addressed to a depth of 12 ft.  Inclusion of the Northern Area thus
adds 26,700 cubic yards to the volume requiring remediation for  soil risks. Similarly, a worst
case scenario wherein all of the soils in the  1.4 acre Northern  Area portion of OU-3 would
need to be remediated to address  risks from soil gas yields a total of 111,000 cubic yards of
soil from  the area that would require treatment.  Based on the available  soil  data and passive
soil gas sampler  data  from the Northern Area, it is unlikely that such  worst case scenarios
would be  observed.   For this reason, the volumes related to remedial measures necessary to
address soil and soil gas risks from the Northern Area portion of OU-3 have  been broken out
separately.  Table 2.4 provides a summary  of the area and  volume estimates for the  soils
requiring remediation.
                                     U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report               2~ 15                            HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                          Delaware

2.3.2.4     Volume to Address Dioxin Risk

To develop an estimate of the volume of soil that might require additional treatment or  special
handling because of dioxin contamination in excess of the PRO, the area of each hot spot was
multiplied by a  depth of 12 ft.  This approach was taken because of the overlap between the
available dioxin data and the listed hot spots.  It is possible, based on the prevalence of dioxin
exceedances that the  dioxin impacted area is underestimated by this approach, but the assumed
12  foot depth  is  likely  conservative  given  the observed decreases  in subsurface  dioxin
concentrations with depth.  Table 2.5 provides a summary of the area and volume estimates for
the dioxin impacted soils requiring remediation.
                                      U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report               2-16                             HydroGeoLogic, Inc. July 2009

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TABLES

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                                                                       Table 2.1
                                         Applicable or Relevant and Appropriate Requirements (ARARs)
                                                for Standard Chlorine of Delaware Operable Unit 3
                                                                      (Page 1 of 9)
               ARAR
        Toxic Substances
        Control Act (TSCA)
                       40 CFR Part 761
                       (particularly §§1, 3, 61,
                       70, 75, 202-218, 265,
                       272, 274)
                        Applicable
Establishes restrictions on the disposal
of bulk polychlorinated biphenyl
(PCB) remediation wastes.
This portion of TSCA will be
applicable if any soils excavated from
the site contain PCBs at concentrations
greater than 25 parts per million. This
concentration is based on the
assumption that the site is a low
occupancy area as defined in 40 CFR
761.3.
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Clean Water Act
(CWA): National
Pollutant Discharge
Elimination System
(NPDES)
Requirements
Clean Water Act,
Section 402: 33 U.S.C.
§1342, 40 CFR Parts
122-125
                                                       Applicable
NPDES Permit Equivalence for the
site establishes discharge limits for
surface water discharges from the
groundwater extraction and treatment
system (GETS) and stormwater
outfalls.
The substantive provisions of these
requirements are applicable to any
portion of the remedy that may affect
the water quality in the nearby wetlands
or Red Lion Creek. Previously
constructed sediment and erosion
control features will be used (and
upgraded as needed) to
prevent/minimize sediment run off
resulting from construction activities.
Water discharges will be sampled and
analyzed in accordance with the
NPDES permit equivalence in place at
the site, included in Appendix B of the
Feasibility Study Report.  Discharge
limits shall be met for all onsite
discharge to surface water including
stormwater and water treated by the
GETS.

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                                                                        Table 2.1
                                         Applicable or Relevant and Appropriate Requirements (ARARs)
                                                for Standard Chlorine of Delaware Operable Unit 3
                                                                      (Page 2 of 9)
        Delaware Regulations
        Governing Control of
        Water Pollution as
        amended 6/23/83
                       Sections 7, 8, 10
Applicable
Contain water quality regulations for
discharges into surface and ground
water.
The substantive provisions are
applicable to stormwater runoff into the
unnamed tributary and Red Lion Creek.
Also applicable to discharge of treated
ground water into surface water. These
provisions were considered in
determining the NPDES permit
equivalence limits.
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State of Delaware
Surface Water Quality
Standards, as amended
July 11, 2004
                               Sections 1-7, 9, 10
Applicable
Standards are established to regulate
the discharge into state waters to
maintain the integrity of the water.
Applicable to stormwater runoff from
site. These standards were considered
in determining the NPDES permit
equivalence limits.
        Coastal Zone
        Management Act of
        1972; Coastal Zone
        Act Reauthorization
        Amendments of 1990
                       16 USC 1451etseq.

                       15 CFR Part 930
Applicable
Requires that Federal agencies
conducting activities in or affecting
the coastal zone, conduct those
activities in a manner that, to the
maximum extent practicable, is
consistent with the enforceable
policies of the appropriate approved
State coastal zone management
program.
The substantive requirements are
applicable to this remedial action,
which is being conducted by EPA at a
facility that is located in the Delaware
coastal zone.

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                                                                          Table 2.1
                                          Applicable or Relevant and Appropriate Requirements (ARARs)
                                                  for Standard Chlorine of Delaware Operable Unit 3
                                                                        (Page 3 of 9)
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         Delaware Coastal Zone
         Act; Delaware
         Regulations Governing
         the Coastal Zone
7 Delaware Code,
Chapter 70, at Sections
7002-7003;

Delaware Coastal Zone
Act Regulations of May
11, 1999, amended on
October 1, 2001.
Applicable
Governs permissible activities and
land uses for properties located in
Delaware's Coastal Zone.  Section
7003 of the Act sets forth the uses that
are absolutely prohibited in the
Coastal Zone. Section E of the
regulations specifically allows the,
"installation and modification of
pollution control and safety equipment
for nonconforming uses within their
designated footprint providing such
installation and modification does not
result in any negative environmental
impact over and above impacts
associated with the present use."
The Site is located in the Coastal Zone.
As a result, the substantive standards of
the statute and regulations apply to this
remedy.
         Preservation of
         Historical and
         Archeological Data
         Act (or Archeological
         and Historic
         Preservation Act of
         1974)
16U.S.C.§469
Applicable
Requires that Federal agencies take
action to recover, protect, and
preserve any significant scientific,
prehistorical, historical, or
archeological data that may be
irreparably lost or destroyed as a
result of the alteration of terrain
caused by Federal activities.
EPA does not currently have any
information that there are any
significant scientific, prehistorical,
historical, or archeological data at the
site. If EPA discovers that such data are
present at the site, actions will be taken
to comply with the substantive
requirements of this act.
         The National
         Historical Preservation
         Act and regulations
16 U.S.C. §470;

36 CFR Part 800
Applicable
Requires that Federal agency actions
avoid adverse effects in historic
properties.
EPA does not currently have any
information that there are historic
properties at the site. If a determination
is made that there are historic
properties on or near the site, action
will be taken to mitigate any adverse
effects on those properties resulting
from the remedial activities.

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                                                                     Table 2.1
                                        Applicable or Relevant and Appropriate Requirements (ARARs)
                                               for Standard Chlorine of Delaware Operable Unit 3
                                                                    (Page 4 of 9)
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        Delaware Regulations
        Governing Hazardous
        Waste (DRGHW)
SEE ITEMS 1 THROUGH 8
BELOW
The DRGHW provisions that
are a part of Delaware's
federally authorized program
would apply instead of the
federal RCRA regulations.
Additionally, any provision
that is not a part of the
authorized program, but that
is more stringent than the
federal requirement, would
also be applicable.
Applicable
Regulate the transportation,
management, treatment, and
disposal of hazardous wastes.
SEE ITEMS 1 THROUGH 8 BELOW
        Regulations
        promulgated pursuant
        to the Resource
        Conservation and
        Recovery Act of 1976;
        Hazardous and Solid
        Waste Amendments of
        1984
SEE ITEMS 1 THROUGH 8
BELOW

Federal RCRA regulations
would not apply for those
regulations where Delaware
has the authority from EPA
to administer.  Federal
citations are also included in
items 2 through 8 below
because any federal
regulations that are imposed
under the Hazardous and
Solid Waste Amendments of
1984, which are not a part of
Delaware's authorized
program, and which are
immediately effective, would
apply.	
Applicable
Regulates the management of
hazardous waste, to ensure the safe
disposal of wastes, and to provide
for resource recovery from the
environment by controlling
hazardous wastes "from cradle to
grave."
SEE ITEMS 1 THROUGH 8 BELOW

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                                                         Table 2.1
                                 Applicable or Relevant and Appropriate Requirements (ARARs)
                                      for Standard Chlorine of Delaware Operable Unit 3
                                                        (Page 5 of 9)

1. Identification
and Listing of
Hazardous Wastes
2. Standards
Applicable to
Generators of
Hazardous Waste






3. Standard for
Closure and Post-
Closure


4. Requirements
for Use and
Management of
Containers



DRGHW Part 261


DRGHW Part 262
subpart A (sections
262. 10-262. 12) and §
262.34;

40 CFR Part 262.
subpart A (§§262. 10-
262. 12 and §262.34)


DRGHW Part 264
Subpart G (Sections
264.110-264.120)
40 CFR Part 264 Subpart
G (§§264. 110-264. 112)
DRGHW Part 264
Subpart I (§§264. 170-
264.179)

40 CFR Part 264 Subpart
I (§§264. 170-264. 179)

Applicable


Applicable









Applicable




Applicable






Identifies solid wastes which are
regulated as hazardous wastes.

Establishes standards for generators
of hazardous wastes including waste
determination and requirements
regarding accumulation time.






Establishes standards for closure and
post-closure of hazardous waste
management facilities


Requirements for storage of
hazardous waste in storage
containers.




This part of the regulations will be used
to determine which materials must be
managed as hazardous wastes.
The substantive standards of the listed
sections would be applicable to the
residual waste generated by the
treatment of soils and sediments if the
waste generated by the treatment
system(s) is a RCRA-hazardous waste.
The substantive standards of the listed
sections would be applicable to
excavated soils if they are to be
disposed in an onsite landfill.
The substantive provisions of this
subpart are applicable to the capping of
the contaminated soil at the site.


The applicable substantive provisions
of this subpart are applicable for
temporary storage containers and on-
site treatment systems.


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                                                                         Table 2.1
                                          Applicable or Relevant and Appropriate Requirements (ARARs)
                                                 for Standard Chlorine of Delaware Operable Unit 3
                                                                       (Page 6 of 9)
            5. Standards for
            owners and
            operators of
            facilities that store
            or treat hazardous
            waste in waste
            piles
                   DRGHW Part 264
                   Subpart L (§§ 264.250 -
                   264.259)

                   40 CFR Part 264 Subpart
                   L (§§ 264.250 -
                   264.259)
                         Applicable
Requirements for storage or treatment
of hazardous waste in waste piles.
The substantive provisions of this
subpart are applicable to any soil and
sediment that are excavated and stored
in waste piles prior to or during
treatment.
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6. Standards for
owners and
operators of
facilities that store
or dispose of
hazardous waste in
landfills
DRGHW Part 264
Subpart N (§§ 264.300-
through264.317)_
                                40 CFR Part 264 Subpart
                                N (§§ 264.300 through
                                264.317)
                                                        Applicable
Requirements for storage or disposal
of hazardous waste in landfills.
The substantive requirements of this
subpart are applicable to on-site
landfilling of soils and sediments. The
requirement to construct a liner system
will be waived. Instead, any cap  will be
tied into the soil bentonite containment
barrier that was installed as part of the
IGR. This barrier is keyed into a low
permeability layer that lies between the
contaminated soils of the Columbia
Formation and the underlying drinking
water aquifer (the Potomac).  This
method of construction will isolate any
contaminated OU-3 soils left under the
cap from surrounding uncontaminated
areas.  As a result,  the capping
alternative will attain a standard of
performance that is equivalent to the
standards that would be attained
through the construction of a liner
system as allowed under 40 CFR §
300.430(f)(l)(ii)(C)(4).

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                                                                        Table 2.1
                                         Applicable or Relevant and Appropriate Requirements (ARARs)
                                                 for Standard Chlorine of Delaware Operable Unit 3
                                                                      (Page 7 of 9)
            7. Air emission
            standards for
            process vents for
            owners and
            operators of
            facilities that treat
            or dispose of
            hazardous waste.
                   DRGHW part 264,
                   Subpart AA (§§
                   264.1030-264.1034)

                   40 CFR Subpart AA (§§
                   264.1030-1034)
                         Applicable
Applies to process vents associated
with air stripping operations that treat
hazardous wastes.
The substantive requirements of this
subpart are applicable to treatment
options that result in air emissions of
VOCs.
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8. Standards
applicable to
transporters of
Hazardous Waste
DRGHW Part 263,
Subpart C

40 CFR Part 263,
Subpart C
                                                        Applicable
Establishes standards for the cleanup
of hazardous waste discharged during
transportation.
The substantive provisions of this
subpart would be applicable to residual
waste generated by the treatment of
soils and sediments, if such waste is
spilled on site during transportation.
        Delaware Regulations
        Governing Hazardous
        Substance Cleanup,
        9/96, as amended
        02/2002
                   Subsection 9.3
                         Applicable
Establishes surface water cleanup
levels.
Applicable to the cleanup of soils,
groundwater that discharges to water
bodies, and surface water at the site.
         State of Delaware
         Regulations Governing
         the Construction and
         Use of Wells,
         February 1997
                   Sections 1-6, 8-10
                         Applicable
Contains requirements governing the
location, design, installation, use,
disinfection, modification, repair, and
abandonment of all wells and
associated pumping equipment.
Any GETS or monitoring well
modifications or repairs needed to
implement OU-3 remedy will be done
in accordance with the substantive
requirements of the well regulations.
No permits will be obtained for on site
work.

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                                                                      Table 2.1
                                        Applicable or Relevant and Appropriate Requirements (ARARs)
                                               for Standard Chlorine of Delaware Operable Unit 3
                                                                    (Page 8 of 9)
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State of Delaware
Statute Regarding
Licensing of Water
Well Contractors,
Pump Installer
Contractors, Drillers,
Pump Installers, Septic
Tank Installers, Liquid
Waste Treatment Plant
Operators and Liquid
Waste Haulers.
                              7 Del. Code §6023
                        Applicable
                 Requires that those who install,
                 maintain, repair, and remove wells
                 and associated pumping equipment be
                 licensed.
                                   Any GETS or monitoring well
                                   modifications or repairs needed to
                                   implement the OU-3 remedy will be
                                   done by qualified workers.
Delaware Sediment
and Stormwater
Regulations, 01/23/91,
as amended April 11,
2005
Section 1-3, 10, 11, 12,
13,  15
Applicable
Establishes a statewide sediment and
Stormwater management program.
The  substantive  provisions   of  this
regulation are applicable to Stormwater
from the  site. No permits or plans will
be obtained or prepared.

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                                                                       Table 2.1
                                         Applicable or Relevant and Appropriate Requirements (ARARs)
                                                for Standard Chlorine of Delaware Operable Unit 3
                                                                     (Page 9 of 9)
               ARAR
     Legal Citation
  ARAR Class
       Requirement Synopsis
 Applicability to Proposed Remedies
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        Delaware Air Quality
        Management
        Regulations
Air Quality Management
Regulations Number
1102 (Section 11.6), 3
(sections 3 and 11), 6,
19, 24
Applicable
Regulation No. 1102 sets forth the
permitting requirements for equipment
and construction activities that may
discharge air contaminants into the
atmosphere. Regulation No. 3,
sections 3 and 11, establish ambient
air quality standards for particulates.
Regulation No. 6 limits particulate
emissions from excavation/
construction operations. Regulation
No. 19 requires that odorous air
contaminants be controlled.
Regulation No. 24 requires the control
of emissions of the volatile organic
compounds.
Applicable to potential releases from
soil vapor extraction (SVE), soil gas
capture systems, excavation work, or
other remedial actions. If air stripper,
SVE, or soil gas system emissions
exceed 15 Ibs/day, the substantive
requirements of regulation No. 24 must
be met. In addition, the emissions must
meet the Ambient Air Quality Standards
set forth in Regulation No. 3. rjust
suppression measures  must also be in
place to ensure that excavation and
construction activities meet the
regulatory requirements.  Further, the
substantive requirements of Regulation
No. 1102 must be met.

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                           Delaware
                                           Table 2.2
                            On Facility Contaminants of Concern
                             and Preliminary Remediation Goals
                    for Standard Chlorine of Delaware Operable Unit 3
                                         (Page 1 of 2)


1 ,4-Dichlorobenzene
Total Dichlorobenzene
Chlorobenzene
1,2,3 , 4-Tetrachlorobenzene
Total Tetrachlorobenzene
Pentachlorobenzene
Hexachlorobenzene
1 , 2 , 3-Trichlorobenzene
1,2, 4-Trichlorobenzene
Total Trichlorobenzene
2,3,7,8-TCDD
4,4 '-ODD
4,4'-DDT

20
20
40
10
10
20
7.01E-05
20
20
20
1.40E-05
4.94E-03
4.62E-03

ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
Robin NOAEL PRG
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG

Acenaphthene
Fluoranthene
Fluorene
Phenanthrene
Total Low Molecular Weight PAHs
20
0.19
30
0.21
29
ORNL Benchmark Concentration for Plants
Robin NOAEL PRG
ORNL Benchmark Concentration for Earthworms
Robin NOAEL PRG
Eco-SSLs for Terrestrial Invertebrates

Pyrene
Total High Molecular Weight PAHs
Pentachlorophenol
0.19
18.0
1.56E-04
Robin NOAEL PRG
Eco-SSLs for Terrestrial Invertebrates
Robin NOAEL PRG

Aluminum
Antimony
Beryllium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
50
5
10
0.4
13
50
200
39.80
100
0.10
30
ORNL Benchmark Concentration for Plants
ORNL Benchmark Concentration for Plants
ORNL Benchmark Concentration for Plants
ORNL Benchmark Concentration for Earthworms
Eco-SSL for Plants
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Soil Microorganisms
and Microbial Processes
Robin NOAEL PRG
ORNL Benchmark Concentration for Soil Microorganisms
and Microbial Processes
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Plants
Standard Chlorine of Delaware Site Feasibility Study Report
                                        U.S. EPA Region 3
                                                                               HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                                  Delaware

                                                 Table 2.2
                                On Facility Contaminants of Concern
                                 and Preliminary Remediation Goals
                       for Standard Chlorine of Delaware Operable Unit 3
                                               (Page 2 of 2)





Thallium
Vanadium
Zinc
1 ,4-Dichlorobenzene
Hexachlorobenzene
1,2,3, 4-Tetrachlorobenzene
1 ,2,4,5-Tetrachlorobenzene
2,3,7,8-TCDD
1.00
2.00
39.96
188.71
1.697
17
16
3.02E-05
ORNL Benchmark Concentration for Plants
ORNL Benchmark Concentration for Plants
Robin NOAEL PRG
Industrial Worker PRG
Industrial Worker PRG
Construction Worker PRG
Construction Worker PRG
Industrial Worker PRG

Benzene
1 ,4-Dichlorobenzene
Chlorobenzene
Carbon Tetrachloride
Chloroform
PCE
TCE
1 ,2-Dichlorobenzene
98
70
1400
26
20
60
4
21,600
Industrial Worker PRG
Industrial Worker PRG
Industrial Worker PRG
Industrial Worker PRG
Industrial Worker PRG
Industrial Worker PRG
Industrial Worker PRG
Industrial Worker PRG
mg/kg - milligrams per kilogram
ppbv -   parts per billion by volume
NOAEL - No Observed Adverse Effect Level
ORNL - Oak Ridge National Laboratory
Eco-SSL - Ecological Soil Screening Level
(1)   Summary  of all human health and ecological receptors considered in the development of PRGs is included in Appendix A of this
    document.
(2)   Human Health PRGs were developed for trespasser, industrial worker, and construction worker receptors based on the 105 cumulative
    target cancer risk and cumulative Target Hazard Quotient of 1 for non-carcinogens.
Standard Chlorine of Delaware Site Feasibility Study Report
                                              U.S. EPA Region 3
                                                                                           HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                                  Delaware

                                                 Table 2.3
                                Off Facility Contaminants of Concern
                                 and Preliminary Remediation Goals
                       for Standard Chlorine of Delaware Operable Unit 3
OFF-FACILITY TOTAL SOIL PRGs
Chemical
1 ,4-Dichlorobenzene
1 ,2,3 ,4-Tetrachlorobenzene
1,2, 4 ,5 -Tetrachlorobenzene
Hexachlorobenzene
2,3,7,8-TCDD
4,4 '-ODD
4,4'-DDT
Fluoranthene
Pentachlorophenol
Phenanthrene
Pyrene
Copper
Lead
Mercury
Zinc
PRG(1)
(mg/kg)
566
23
25
7.01E-05
1.40E-05
4.94E-03
4.62E-03
0.19
1.56E-04
0.21
0.19
235
39.8
0.20
40.0
Basis
Industrial Worker PRG(2)
Construction Worker PRG(2)
Construction Worker PRG(2)
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Vole NOAEL PRG
Robin NOAEL PRG
Vole NOAEL PRG
Robin NOAEL PRG
OFF-FACILITY SOIL GAS PRGs
Chemical
1 ,4-Dichlorobenzene
Chlorobenzene
PRG(1)
(ppbv)
67
3200
Basis(2)
Industrial Worker PRG
Industrial Worker PRG
mg/kg - milligrams per kilogram
ppbv -   parts per billion by volume
NOAEL - No Observed Adverse Effect Level
(1)   Summary  of all human health and ecological receptors considered in the development of PRGs is included in Appendix A of this
    document.
<2)   Human Health PRGs were developed for trespasser, industrial worker, and construction worker receptors based on the 105 cumulative target
    cancer risk and  cumulative Target Hazard Quotient of 1 for non-carcinogens.
Standard Chlorine of Delaware Site Feasibility Study Report
                                              U.S. EPA Region 3
                                                                                          HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                               Delaware
                                              Table 2.4
                            Estimated Extent of Site Contamination
                      for Standard Chlorine of Delaware Operable Unit 3
Area of Concern




Soil PRO On-Facility Contamination
Added Volume for Soil Gas PRO On-
Facility Contamination
Off-specification product
PCB/dioxin concentration area
(RAS-1)
Catch basin #1 (RAS-2)
Former rail siding and loading area
(RAS-3/RAS-7)
Warehouse and the area to
the north of the warehouse (RAS-4)
Facility storm drains
Drum cleaning area (RAS-5)
Northern end of eastern drainage
ditch (RAS-6)
Former wastewater treatment plant
(RAS-8)
Chemical process area (RAS-
9/RAS-10)
1986 tank collapse area
Northeast tank farm
Total On-Facility Volume Exceeding
Soil/Soil Gas PRGs
22.8 Acres
2 to 12
351,060

10,000 sq. ft.
10,000 sq. ft.
65,000 sq. ft.
60,000 sq. ft.
5,000 sq. ft.
10,000 sq. ft.
10,000 sq. ft.
35,000 sq. ft.
50,000 sq. ft.
10,000 sq. ft.
65,000 sq. ft.
-
38(2)
38(2)
38(2)
38(2)
38(2)
38(2)
38(2)
38(2)
38(2)
38(2)
38(2)
-
14,100
14,100
91,500
84,450
7,050
14,100
14,100
49,250
70,400
14,100
91,500
815,710

Total "Northern Area" Volume
Exceeding Soil/Soil Gas PRGs (1)
1.4 Acres
50
111,000
NOTES:
(i)
    The value provided here is a worst case scenario assuming the entire area west of the treatment building
    would require remediation to address risks throughout the vadose zone.  Although the Northern Area is part
    of OU-3, it was separated for area and volume calculations because of the lack of data showing the presence
    of contamination at levels requiring remediation.  Contamination was found (drum remnants and chunks of
    chlorobenzenes) in the northern end of the On Facility Area that is adjacent  to the Northern Area. No
    contaminants  were detected  at concentrations greater  than the PRGs  in the limited number  of samples
    collected from three locations in the Northern Area.  Additionally,  passive soil gas samplers deployed in the
    Northern Area were relatively free of contamination when analyzed.  Additional sampling data are  needed to
    further characterize this area.
    Depth of soil to be addressed in addition to top 12 feet addressed for Soil PRGs.
Standard Chlorine of Delaware Site Feasibility Study Report
                                           U.S. EPA Region 3
                                                                                    HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                               Delaware

                                              Table 2.5
                        Estimated Extent of Site Dioxin Contamination
                      for Standard Chlorine of Delaware Operable Unit 3





Volume of On-Facility Soil Exceeding
Dioxin Soil PRO
Off specification product
PCB/dioxin concentration area
(RAS-1)
Catch basin #1 (RAS-2)
Former rail siding and loading area
(RAS-3/RAS-7)
Warehouse and the area to
the north of the warehouse (RAS-4)
Facility storm drains
Drum cleaning area (RAS-5)
Northern end of eastern drainage
ditch (RAS-6)
Former wastewater treatment plant
(RAS-8)
Chemical process area (RAS-
9/RAS-10)
1986 tank collapse area
Northeast tank farm
Total On-Facility Volume Exceeding
Dioxin Soil PRO

10,000
10,000
65,000
60,000
5,000
10,000
10,000
35,000
50,000
10,000
65,000
7.6 Acres
12
12
12
12
12
12
12
12
12
12
12
-
4,450
4,450
28,900
26,700
2,200
4,450
4,450
15,550
22,200
4,450
28,900
146,700

Total "Northern Area" Volume
Exceeding Dioxin Soil PRG(1)
1.4 Acres
12
26,700
(1)   The value provided here is a worst case scenario  assuming the entire area west of the treatment building
    would require  remediation to address dioxin risks.  Although the Northern Area is part of OU-3, it was
    separated for area and volume calculations because of the lack of data showing the presence of contamination
    at levels requiring remediation. Contamination was found (drum remnants and chunks of chlorobenzenes) in
    the  northern end of the On Facility Area that is  adjacent to the  Northern Area. No contaminants were
    detected at concentrations  greater than  the PRGs  in the limited number of samples collected from three
    locations in the Northern Area. Additional sampling data are needed to further characterize this area.
Standard Chlorine of Delaware Site Feasibility Study Report
                                          U.S. EPA Region 3
                                                                                    HydroGeoLogic, Inc. July 2009

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FIGURES



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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware
3.0    IDENTIFICATION AND SCREENING OF TECHNOLOGY TYPES
       AND PROCESS OPTIONS

General Response Actions (GRAs),  and specific technology  types  and Technology  Process
Options (TPOs) within  each general  response  action type are defined in  this section. The
phrase "technology process options" refers to specific processes within each of the general
technology types. For example, TPOs within the "treatment" GRA include chemical oxidation
and soil washing.

GRAs are introduced in  Section 3.1. In Section 3.2, potential remedial technologies  are
identified  within each of the General Response Actions. The identified TPOs are first pre-
screened based on technical feasibility at OU-3.  The results of the pre-screening analysis are
summarized in Table 3.1.   In Section 3.3, TPOs retained from the initial  pre-screening are
screened again based on effectiveness, implementability and cost. The TPOs that remain after
the screening are  summarized  in  Section  3.4.  These  remaining TPOs  will  be used  in
assembling remedial alternatives for OU-3.

3.1 GENERAL RESPONSE ACTIONS

GRAs are medium-specific  generic types of remedial actions that can, alone or in combination,
achieve the established RAOs for the site.  GRAs proposed for the site include the following:
   •   No Action.  No  action GRA implies that the  site is left in its present condition. This
       response action  provides  a background against  which  all other  remedies  can be
       compared. A no action alternative is required for consideration by the  NCP.
   •   Institutional Controls. ICs may reduce human health risks from site contaminants by
       restricting land use or activities at the site. ICs will not reduce ecological risks.
   •   Containment.    Containment  refers  to physical  processes   that would  restrict
       contaminant mobility without changing  their  concentration  or  toxicity. Containment
       protects human health and minimizes ecological risk by controlling  the  routes  of
       exposure.
   •   Treatment.  Treatment may include any physical, chemical or biological processes that
       would lower human health or ecological risk from the contaminants by their destruction
       or  conversion into less hazardous forms.
   •   Removal.  Removal includes physically  removing contaminated  soils as an initial step
       for treatment and/or disposal.
   •   Disposal.  Disposal involves methods  to discard the treatment by-product or removed
       soils off site in accordance with all applicable regulations.
   •   Monitoring.   Monitoring of site  conditions  provides useful information  about
       remediation  progress.  In addition to visual  inspection of installed  RA measures,
       monitoring also  includes  sampling  of soil,  sediments,  soil gas,  groundwater, and
       surface water.

Applicable technologies  associated with each of the above GRAs are discussed below.  These
technologies are typical of sites with nature and extent of contamination similar to OU-3.
                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware

3.2    IDENTIFICATION AND SCREENING OF POTENTIALLY APPLICABLE
    TECHNOLOGIES

A range of technology types and  process options was identified and pre-screened according to
their overall applicability to the primary contaminants and conditions present at the site. For
each GRA,  one or more technology types  and associated TPOs were identified. The initial
screening  results are summarized in Table 3.1.  Some  of the  sources consulted during the
identification of technologies include reference documents published by the EPA, feasibility
studies  for  similar  sites,  standard engineering  texts,  and  professional  experience.  Each
technology is described in more detail in Section 3.3.

3.3 EVALUATION OF POTENTIAL REMEDIAL TECHNOLOGIES

In this subsection, each  of the technologies listed in  Table 3.1  is described in  further detail.
For those technologies identified  in the preliminary screening as not potentially effective, the
rationale  for  this decision is included.  Those technologies  that  have been identified as
potentially  effective  are   evaluated   in   greater  detail  based   on  their   effectiveness,
implementability  and cost.  Based on this  evaluation,  the  technology is either retained for
further evaluation or eliminated. Each of the three criteria is briefly defined below:
   •   Effectiveness - The ability  of a technology to meet  defined RAOs for protection of
       human health and the environment.
   •   Implementability  -  Technical  and  administrative  feasibility   of implementing the
       technology. TPOs that are not technically feasible at the site were eliminated during a
       pre-screening step. During this evaluation, the remaining TPOs  are compared based on
       such considerations as the  ability  to  meet the  substantive  provisions  of permit
       requirements,  the availability of treatment,  storage, and disposal  services,  and the
       availability of necessary equipment and skilled workers to implement the technology.
   •   Cost -  A relative estimate of the cost of implementing the technology. This is based on
       engineering judgment and available  reference sources.  Costs are  given as very low,
       low, moderate, or high relative to other process options.

Table 3.2 summarizes the  results of this evaluation for those  technologies that were carried
forward from the pre-screening.

3.3.1   No Action

Description-The no-action option consists of leaving the site as it is, without any remediation
activities.

Effectiveness-This response does not meet  the  RAOs and would not be protective of human
health or the environment.

Implementability-No actions are required  to  implement this option,  but is not likely to be
approved by the public.
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

Cost-No costs are associated with this option.

Recommendation-The NCP requires that the no  action  alternative be  used as a  baseline
against  which  to compare  remedial technologies.  Therefore, the No  Action option  was
retained for further analysis.

3.3.2   Institutional Controls

Institutional controls are actions, such as legal controls, that help minimize the potential for
human exposure to contamination by ensuring appropriate land or resource use. Although it is
EPA's expectation that treatment or engineering controls  will be used to address  principle
threat wastes and that groundwater will be returned  to its beneficial use  whenever practicable,
ICs can and do play an important role in remedies.  ICs do not reduce contaminant  toxicity,
mobility, or mass. They do reduce  or eliminate the potential for human exposure and  can help
protect existing and future remedial measures.

All of the proposed remedial alternatives include ICs in combination with other treatment or
containment methods.  Therefore, the ICs were retained for further analysis.  The proposed
ICs  include  proprietary  controls   such as  restrictive  covenants and  access  agreements,
governmental controls such as a Groundwater Management Zone, and  informational devices
such as public information/awareness programs.

With  regard to the SCD  Site, it is expected that ICs  will be  used to  achieve the following
goals:
    •   Prevent residential or other  incompatible  land use -  Eliminating the  potential for
       residential  land use will help reduce the potential exposure that a person (or people)
       could have to  site  contaminants by limiting the  amount of time that they spend on the
       site in any one day.  The PRGs  that were developed for the OU-3 portion of the site
       were not based on residential factors, and therefore  the possibility  of future residential
       use must  be  eliminated  to  ensure that future  potential exposure  levels match those
       envisioned in the development of the PRGs.  Similarly, incompatible uses such as a
       children's day care center must be prevented to restrict the potential exposure  of those
       most vulnerable to any potential residual hazards from the site.   This goal  could be
       accomplished through the use of a proprietary control such as a restrictive covenant.
    •   Prevent heavy  industrial site use - To meet the requirements the Delaware Coastal
       Zone Act, no heavy industrial operations may be  situated on the site in the future.
       Eliminating the potential for heavy industry  will  be accomplished via government
       controls (i.e., the Coastal Zone Act itself) and proprietary controls  such as a restrictive
       covenant.
    •   Prevent use  of site  groundwater  -  Because  of the  contamination  located in the
       subsurface soils and the groundwater underlying the  site, it is imperative that no one be
       allowed to drink groundwater recovered from the site.  This goal  would be  achieved
       through a government control (i.e., Groundwater Management Zone).
    •   Require vapor intrusion protection measures  in any building built at the site -  Because
       human health risks from soil vapor at the site are primarily through the indoor exposure
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

       pathway (Black & Veatch, 2007), restrictive covenants may be implemented to require
       that future on site buildings be equipped with vapor intrusion control features (e.g.,
       passive  barriers, passive or active venting, and subslab pressurization).
    •   Ensure  that installed remedial measures remain in good working condition -  It will be
       necessary  to inspect,  monitor,  operate, and maintain OU-3 remedial measures as well
       as already existing measures [e.g., GETS, containment barrier, and the temporary soil
       staging  area (TSSA)].  EPA and/or DNREC representatives will also need to have
       access to effect repairs and conduct site  monitoring  activities.  These goals  would be
       achieved through the use of proprietary controls  including restrictive covenants and
       access agreements.
    •   Prevent or restrict activities that would damage installed remedial measures  or cause
       excessive  exposure  to site contaminants -  Certain types  of  activities  (including
       excavation of  site soils) will have  to be  prevented or restricted to prevent damage to
       existing  remedial measures  (i.e., GETS,  containment  barrier,  and  the TSSA).
       Similarly, excavation of deeper soils will need to be prevented to reduce the potential
       for worker exposure.  These goals would be  achieved through the use of proprietary
       controls including restrictive covenants.
    •   Inform  the public about site developments and warn people about site  hazards - It is
       important  to   keep  the   public  informed   about   site  developments   to  prevent
       misunderstandings and  to improve public  perceptions about  site activities.    Public
       meetings and informational  brochures  can be used along with warning signs  to ensure
       that these goals are met.

3.3.3   Containment

Containment involves  installation  of physical  barriers to  prevent further  migration  of
contaminants from the soil and to  eliminate the  routes of exposure to humans and ecological
receptors. Containment TPOs considered in this  FS Report include horizontal surface barriers
(caps) and subsurface barriers.

3.3.3.1    Security Fencing

Description-The site  has a chain  link security fence around the perimeter of the former facility
area.  This option would involve  maintenance  of  the fence, possible elimination of some access
gates, and replacement of sections that are in need of repair.

Effectiveness-The security  fence  does  limit  access to  the  site,  but  there  have  been
unauthorized entries made to the  site by cutting the locks on one or more gates.  A reduction in
the number of gates might reduce the ability of unauthorized personnel to gain access.  The
security fence does not reduce environmental risks or the toxicity, mobility or volume of the
site contaminants.

Implementability - The security fencing is already in place.  Maintenance of the fence would
be easily implemented.  Depending on the eventual use of the site, the security fence could be
seen as an aid or an impediment to future development.
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware
Cost-The cost of security fencing at the site would be very low to low.

Recommendation-Security fencing was retained for further consideration in combination with
other remedial options.

3.3.3.2    Surface Horizontal Barriers (Caps)

Construction of a surface horizontal barrier on the site can potentially achieve multiple RAOs:
    •   Minimize human and wildlife exposure to contaminants in the surface soil and soil gas
    •   Prevent spread of contaminants via air-blown soil particles,  surface runoff, or seepage
       into groundwater;
    •   Minimize escape of the soil  gases into the atmosphere;
    •   Prevent or substantially reduce infiltration of stormwater into contaminated  subsurface
       soils;
    •   Serve as a temporary control to contain waste while treatment is being applied.

Any surface cap design for the site  would  need to  be equipped  with a gas collection and
treatment system.  Tying the surface cap  into the  previously  constructed vertical groundwater
containment  barrier should be considered where practical to improve remedy performance.
Care  must be taken during construction  activities to avoid damaging the previously installed
containment  barrier and  GETS. To  provide a stable  foundation  for the cap construction,
subsurface structures (such as catchment  basins, storm drains, process piping,  and  abandoned
utilities)  will  need to be removed along with concrete containment pads, tanks,   and other
demolition debris.   Additionally, the  potable water supply to  the  GETS  building  should  be
relocated to avoid possible damage to the cap and allow easier access for maintenance of the
water line.  If capping is subsequently considered in offsite areas to the east of the SCD fence
line, some mature vegetation will need to  be removed.

It is possible that some soil will need to  be  removed  as part of the cap construction process.
Because  the removed materials would  contain contaminants above acceptable risk levels, these
excavated soils would need to be treated or disposed of as hazardous waste, unless they  can be
placed back in the area being capped.

Types of surface caps  that are being considered include evapotranspiration  (ET),  soil/clay,
chemical sealant, multilayer, concrete, and asphalt.  Regardless of the type of cap selected,  the
design must include an associated stormwater control so that the cap  can be naturally  integrated
into the adjacent ecosystems. The effectiveness, implementability, and cost of the different cap
types, as well as the findings of the TPO screening process are summarized below:

Evapotranspiration Cap

This TPO was eliminated in  the pre-screening  stage.  ET caps use  vegetative  cover to  reduce
the infiltration of  precipitation  into  contaminated soils.    This type of cover  has  gained
popularity in  recent years as a  low cost alternative  to traditional  cap construction methods
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

because  of its  low  cost of  construction  and reduced maintenance requirements.   It is
particularly appropriate in more arid climates where a lack of moisture can cause cracking  and
failure of traditional clay liners (AFCEE, 1999). Unfortunately, ET caps would not effectively
eliminate the soil gas  exposure pathway at OU-3 unless a vapor barrier were integrated into the
design, and the precipitation rate in the area (approximately 43 inches/year) would  likely be
too high for such a cap to function properly. The required vapor barrier  would likely worsen
the performance of the ET cap in this high precipitation area.  For these reasons, this TPO was
removed from further consideration during the pre-screening stage.

Soil and Clay-Based Caps

Description-Soil and clay-based caps are single layer caps that use low permeability  soil or
clay to reduce or stop infiltration of precipitation.

Effectiveness-Single  layer  soil and clay-based caps could potentially achieve RAOs for the
OU-3  soil  and  soil gas,  provided sufficiently  low permeability material is used  to prevent
infiltration. Although it would be somewhat easier to reseal a cap of this  type as opposed to a
multilayer  cap  in the event of a breach (as part of future construction activities),  substantial
effort would still be required to ensure that  the disturbed areas did not result in increased  soil
and/or soil gas exposure.

Implementability-Single layer soil  or clay-based cap can be relatively easily constructed at
OU-3 using standard  construction equipment and procedures. This type of cap often requires
more maintenance than asphalt or concrete caps because it is more susceptible to erosion  and
cracking from freezing and thawing. Although warm season grasses might reduce maintenance
costs for this type of cap, the a soil or clay cap would  still be more likely than an asphalt or
concrete cap to have structural failure because of erosion, cracking, or burrowing  animals.
Because  damage to monitoring  wells  and  piezometers  is possible during cap construction,
replacement or modification of these features might be required.

Cost - The cost of this TPO would be  relatively low to moderate.

Recommendation-Because of the increased potential  for  failure relative to other types of caps,
single layer soil/clay caps were eliminated from further consideration during the screening  and
evaluation  stage.

Chemical Sealant Cap

Chemical sealant caps were eliminated from further consideration during the pre-screening
stage (Table 3.1). A  chemical sealant cap uses native soil mixed  with some form of binding
agent (cement, lime,  grout) to reduce the soil  permeability. Because  contamination  exists in
much of the surface soil and shallow subsurface soil across the area of consideration, the use of
native  soils in cap construction is not  feasible.  Consequently, chemical sealant caps  were not
retained for further consideration.
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Multi-Layer Cap

Description-A multilayer surface  cap,  such as a RCRA Subtitle  C cap, is appropriate  for
hazardous waste applications. This  type of cap generally includes an upper vegetative (topsoil)
layer,  a drainage  layer, a synthetic membrane, and a low  permeability  barrier layer placed
over a foundation layer of sand or native soils. The barrier layer can be constructed with low-
permeability  soil (clay) and/or geosynthetic  clay liners.  RCRA Subtitle C caps are typically
six foot or more in thickness (AFCEE, 1999).

Effectiveness-A  multilayer surface cap  could potentially achieve RAOs at OU-3 by limiting
contact with contaminated  soil and soil gas, reducing infiltration and  limiting contaminant
mobility.  By  limiting infiltration,  a multilayer cap would greatly reduce the  potential  for
contaminants to spread via the soil to groundwater pathway.  Multilayer soil caps tend to be
more effective than simple  soil covers.  It would be relatively difficult to reseal a multilayer
cap if it were to be breached for future construction of a building, additional  extraction wells,
DNAPL removal wells, or monitoring wells.

Implementability-A  multilayer  surface  cap can be  implemented  relatively  easily at OU-3
using readily available technology and materials. This technology is harder to implement than
other surface soil cap types. To be used at OU-3, demolition debris and possibly a substantial
quantity of soil would have to be removed to prepare the site for installation of a multilayer
cap.   Additionally, features such  as the GETS piping, extraction well vaults, monitoring wells,
piezometers,  and the  asphalt access road might need to be raised, reconstructed, or otherwise
modified to make the  implementation of a multilayer cap feasible.  Maintenance of a multilayer
cap would include erosion repair, vegetation trimming, and possibly  animal control/removal.

Cost - Low to Moderate: unit costs of between $500,000 and $650,000 per acre are typical for
surface cap construction. Well repair/replacement costs would be added to these figures as well
as disposal costs for the demolition debris that would have to be removed (or possibly crushed)
to provide an acceptable base for  cap construction.

The  costs associated  with the multilayer surface cap are low to moderate, although they  are
expected to be somewhat higher than the cost of other surface cap alternatives.

Recommendation-This approach was retained for further analysis.

Asphalt or Concrete Cap

Description-Asphalt  and  concrete  caps consist of an  asphalt  or concrete layer  over  the
contaminated soils, designed to minimize contact with soil and soil gas and limit infiltration of
stormwater.

Effectiveness-Concrete  and asphalt caps can effectively control  erosion,  reduce  soil  gas
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exposure, and minimize precipitation infiltration.  These caps are more resistant to erosion and
require less maintenance than  soil  and multilayer  caps  (AFCEE,  1999).   By limiting
infiltration,  an asphalt or concrete cap would greatly reduce the potential for contaminants to
spread via the soil to groundwater pathway.  It would be relatively simple to reseal a concrete
or asphalt cap if it were to be breached for future  construction of a  building,  additional
extraction wells, DNAPL removal wells, or monitoring wells.

Implementability-Concrete or asphalt caps can be easily implemented at OU-3.  Maintenance
of these caps typically involves the  periodic application of sealers and repair of  cracks.  The
appearance of these caps can be considered a draw-back, but because they are fairly thin (less
than one foot thick in general) they could be installed relatively quickly, would require less soil
removal  than a multi-layer  cap, and would  be  less  likely to  require  modification of  the
previously installed  IGR features.  Because  damage to monitoring wells and piezometers is
possible  during cap  construction,  replacement or modification  of these features  might be
required.

Cost - Low to Moderate: unit costs  of between  $300,000 and $550,000 per acre are typical
for surface cap construction.  Reapplication of sealants and well repairs/replacements would be
added  to these figures as well as disposal costs for the demolition debris that would have to be
removed (or possibly crushed) to provide an acceptable  base for cap construction.

Recommendation-This treatment option was retained for further consideration.

3.3.3.3   Subsurface Horizontal Barrier

The subsurface horizontal barrier alternative was  eliminated from further consideration at the
pre-screening  stage. In this  treatment option,  a  horizontal  impermeable barrier is installed
within the subsurface. Several of the available subsurface barrier installation technologies, such
as high pressure jet grouting and deep soil  mixing, can be used to  avoid  the excavation  of
surface soils.
This technology would be an attractive option for locations where the  main contamination of
concern is limited to subsurface soils.  As this is not the case  for the SCD  site, surface soils in
areas with contamination exceeding  the developed PRO concentrations would still need to be
excavated or treated. Additionally, stormwater that collects above the subsurface barrier would
have to be collected.  Collected water would need to be treated until the surface soil is free of
contamination.  In addition, the extent of the  contamination present  at OU-3 might make it
difficult to ensure continuity and integrity of the subsurface barrier across the site.

3.3.4  Treatment

Soil treatment methods can be subdivided  into two general categories: in  situ and ex situ. Ex
situ  methods  involve excavation of  the  soil  before  treatment,  while in  situ  treatment  is
performed in place.  In situ and ex situ treatment methods can  rely on chemical, physical,  or
biological processes, as well as combinations  of these.  All ex situ treatment considerations
must take into account the costs for excavation and,  for some alternatives, transportation  of
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soils.

Ex situ processes that were considered  for use  in conjunction with some other  remedial
alternative  include  ex  situ  chemical  oxidation, thermal  destruction  (incineration),  low
temperature thermal  desorption (LTTD), soil washing, in-vessel bioremediation, and biopiles.

In situ processes considered for the site include in situ chemical oxidation (ISCO), soil vapor
extraction   (SVE),  soil  flushing,  in  situ  thermal  desorption  (ISTD),  and  enhanced
bioremediation.  These processes are evaluated below.

3.3.4.1    Chemical Oxidation

Chemical  oxidation typically involves the introduction of an oxidant via injection or soil mixing
into  contaminated soil or water to initiate a reduction/oxidation (redox) reaction. This redox
reaction  can  chemically convert  hazardous  contaminants  to  nonhazardous or  less toxic
compounds  and  elements through the transfer of electrons from the contaminant to the oxidant.
As a result, the  organic contaminant is broken down, with water, carbon dioxide, chlorine (in
the  case  of chlorinated  compounds), and  other  relatively  nontoxic chemicals as the end
products of the reaction.

Contaminants that are present on the  site  and could be treatable  with ISCO include benzene,
chlorinated  benzenes,  chlorinated solvents (TCE and  PCE),  carbon  tetrachloride,  and
chloroform. It has also  been suggested that PCBs, PAHs,  dioxins, organic pesticides, and
phenols could also be treated using this technology  (ITRC, 2005).  Further site characterization
would  be  needed to  identify the best locations for  oxidant applications  (through either
injections  or mixing) and determine dosing requirements.

The  primary benefits to the  chemical oxidation approach are its fairly quick treatment time and
the fact that the  contaminants are destroyed.  Potential drawbacks for this technology include:
   •  Mobilization  of metals as a result of change in pH and/or oxidation states;
   •  Volatilization of organic chemicals due to the exothermic nature of the reactions;
   •  Potential difficulty delivering and effectively distributing the  treatment chemicals to  all
       of the contaminated areas;
   •  Potential regulatory  issues associated with underground injection control (UIC) and air
       quality impacts from off-gassing; and
   •  Potential chemical or temperature effects on the newly constructed containment barrier.
       (The area where  the heaviest soil contamination was  identified in the RI is  along  the
       former rail siding.)

When  determining the costs and  feasibility of employing oxidation for  a  particular case,
various parameters must be  taken into  account including:
   •  Kinetic rate of reaction
   •  Unit cost of oxidant
   •  Application method requirements
   •  Hazardous material handling requirements
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    •   Required quantity of the oxidant
    •   Site geology and hydrogeology
    •   Soil pH
    •   Abundance of naturally occurring organic matter
    •   Mass of contaminants sorbed to site soils
    •   Accessibility to the contaminated area

In-Situ Chemical Oxidation

Description-For ISCO, oxidants are injected into the subsurface as a solution (or in the case of
ozone as a gas) or mixed into  the soil as a solid or a liquid, although ozone can also be injected
as a gas.  In some cases co-amendments (such as iron in Fenton's reagent reactions) are added
to optimize the reaction.

Effectiveness-ISCO can potentially treat most of the organic contamination present at the site,
but it would not likely  reduce the toxicity of  most metals contamination.   Because of the
potential for the exothermic reactions to harm the existing containment barrier, it would not be
possible to apply this  technology near the barrier. Thus, this approach would not address some
of the heavily contaminated  soils  located in the former  rail siding area.   Additionally, the
oxidation process and the introduction of liquids into  the vadose zone could mobilize  site
contaminants and allow them to further contaminate the underlying groundwater.

Implementability-Further site characterization would be needed  to identify the best locations
for oxidant  applications (through either injections or mixing), to  select the oxidant, and to
determine dosing requirements. A  bench-scale treatability study showed that Fenton's reagent
(hydrogen   peroxide   mixed   with   acidified   iron)  successfully  reduced   chlorobenzene
concentrations in facility soils by an average of more than 90 percent.  It would be difficult to
distribute the  oxidant  throughout the  vadose zone  across the  areas with  contaminant
concentrations greater than the  PRGs.   Pilot-scale  studies would be  needed to  determine
whether a full-scale chemical  oxidation approach could cost-effectively treat the contaminated
soils in question.   Oxidants should not be injected or mixed into  soil near the groundwater
containment barrier because they could alter chemical properties of the barrier and possibly
increase its permeability.  Another potential problem is that the oxidant injections  could create
high pressure pathways that  could penetrate the barrier.   Soil mixing  in  the  area of the
containment barrier would alter the mechanical  properties of the soil and possibly undermine
the barrier's structural integrity.  Oxidation of chlorinated compounds would increase chloride
concentrations  in  the  subsurface.    Elevated  chloride  concentrations  could  attack GETS
components as well as the containment barrier.

Cost  - Moderate  to High:  Costs  for ISCO  are highly  variable depending  on site  and
contaminant  characteristics, but  estimates of  $30 - $100 per cubic yard of soil have been
reported (ITRC, 2005).

Recommendation-Because of the inability to treat the highly contaminated soils adjacent to the
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containment  barrier,  and the inability to meet PRGs  for  metals,  ISCO was retained for
consideration only in combination with other technologies. For example, ISCO could be used
to treat certain hot spots that are not located close to the containment barrier.

Ex-Situ Chemical Oxidation

Description-For ex  situ  applications of chemical oxidation, the  contaminated  soils are
excavated and placed  in a lined containment area before the oxidants are mixed in.

Effectiveness-Ex situ chemical  oxidation could effectively treat organic contaminants in site
soils.  The  technology  could be  used to  treat soils  that  have been  excavated during the
construction of a surface cap.

Implementability-Construction  of a suitable containment structure equipped with leachate and
gas collection and treatment systems would be  expensive and would  require substantial  open
area.  Treatability studies would be needed to determine whether oxidation would effectively
treat PCBs, PAHs, pesticides, and dioxin.  Excavation of soils to the 50 foot depth required to
address soil gas risks would be very difficult and expensive.   Additionally, off site disposal of
the treated soil might be required if sufficient on site disposal areas cannot be identified or if
PRGs cannot be met.

Cost - High: Construction costs  combined with the excavation costs and those of the  large
quantity of oxidant that would  be required to  ensure destruction  of  the contaminants would
likely make this option somewhat cost-prohibitive,  with estimated costs ranging from $150 to
$500 per cubic  yard (FRTR, 2002).

Recommendation-Because of the  space requirements,  high implementation costs, difficulties
related to  excavation of deeper contaminated  soils,  and lack of metals  treatment, ex situ
chemical  oxidation  was  eliminated  from further  consideration  during  the  screening  and
evaluation stage.

3.3.4.2    Soil Vapor Extraction

Description-SVE involves the application of vacuum to contaminated soils to extract volatile
and  some semivolatile organic compounds in a gaseous  form. To ensure  that  the vacuum  is
applied to all of the  contamination  above the groundwater table, vacuum  wells  should be
installed  and screened across the  entire  vadose zone  below  the  cap.   Well placement and
blower sizing should  be selected to ensure that the radii  of influence  overlap and address the
entirety of the contaminated area.

The extracted gas is typically treated using a condenser, vapor phase GAC,  a thermal oxidizer,
or a catalytic oxidizer before it is released into the atmosphere.  It is best suited for well
drained,  high-permeability soil  (sand  and gravel)  with low  organic carbon content (EPA,
2006).  In soils  with heterogeneous properties (such as varying water  content or permeability)
short-circuiting might lead to poor treatment in the regions with less permeable or water logged
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soils. In addition, organic contaminants in soils that  are too dry or have substantial natural
organic matter will adsorb more strongly to the soil, and therefore increase difficulty of their
removal.

Effectiveness-SVE has  been used to treat  many of the contaminants present on  the site.
However,  SVE would have limited  effectiveness  on  or  would  be  ineffective  in  treating
pesticides,  PCBs, dioxins, and most SVOCs and metals.  An SVE system would likely need to
be operated for at least one to two years for effective reduction of soil and soil gas risks from
those contaminants that would be amenable to treatment.

Implementability-SVE is a well established technology for Superfund  sites.  The vadose zone
soils at the SCD  site are sandy with permeabilities in the range  of  10~3 to 10~2  cm/sec.   This
type of soil is generally well-suited to treatment with SVE. SVE performance  can be enhanced
by covering  the soil  surface with a low permeability layer (such  as concrete, asphalt, or a
geomembrane) to prevent short-circuiting of the air flow and to increase the radius of influence
of the extraction wells (FRTR, 2002).  Consequently, combining an SVE system with a surface
cap could enhance both remedial options.  Additionally, the blowers and off-gas treatment for
an SVE system could be utilized for a surface cap's gas collection system.  Any media used for
the vapor treatment (e.g. activated carbon) would have to be regenerated or disposed of as
hazardous  waste, and the substantive provisions of air  discharge permit requirements would
most likely need to be met. Pilot-scale treatability studies would be needed  to confirm potential
effectiveness and provide guidance  for determining well spacing. Further site characterization
would  assist in optimizing SVE well placement.

Cost - Low to High: Cost estimates for unheated in situ SVE vary widely with ranges from
$30  to $110 per  cubic yard  cited for  sites involving the treatment of  5,000  to 50,000 cubic
yards of soil and  costs as low as $2 to $3 per cubic yard achieved for sites involving over
100,000 cubic yards of contaminated soil (EPA, 2001).  Although large volumes of soil would
require treatment at the SCD  Site, the recalcitrant nature of certain site contaminants and  the
depth over which contamination extends indicate that unit costs for OU-3 would probably be in
between these figures (in the  $5 to $15 per cubic yard range).

Recommendation-Because the bulk of the site contaminants  are VOCs, SVE  could be used to
reduce contaminant levels  in certain hot spot areas.   SVE would not be  suitable as a  stand-
alone,  site wide  treatment because it fails to address dioxins, metals, pesticides,  and most
SVOCs.   SVE was retained as an option for use in conjunction  with other  treatment and
containment alternatives.

3.3.4.3     In Situ Soil Flushing

Description-Soil flushing  involves flooding  contaminated  soil with  water  or a solution to
mobilize contaminants. The water or liquid solution is injected or infiltrated  into the area of
contamination. The contaminants leach into  the water/solution, which is  then recovered and
treated before being re-injected or discharged.
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Effectiveness-Even though some of the  site contaminants may be amenable to soil flushing, it
is unlikely that a  single wash fluid would be able  to remove all  COCs due to their  diverse
physico-chemical characteristics.  Thus,  application  of multiple flush solutions would likely be
required.  To be effective, it is necessary for the flush solution to be distributed  throughout the
entire treatment zone.  The potential for  the  injected fluid to short-circuit the contaminated
soil, particularly  if it is necessary  to  inject multiple solutions, decreases the effectiveness of
this TPO.  Additionally,  soil flushing would mobilize many of the  contaminants  in question
allowing those contaminants that are not  recovered to further impact the groundwater.

Implementability-In situ flushing  is well-suited to  treatment of contaminants in sandy soils,
but the  depth  of groundwater in the treatment area (between  40 and 50 ft bgs) would make
treatment with this technology more  difficult  and  would  require greater volumes of liquid
injection.   With  the  large  area  requiring treatment, it would be difficult to  install  a fluid
injection/capture system that would allow  treatment of the entire soil volume while ensuring
that  the wash solution and mobilized contaminants are  captured before they  reach the
groundwater.   The greater liquid  injection volume would have the effect of  increasing the
groundwater  elevation  and instill/increase a  downward gradient between the  Columbia and
Potomac aquifers.  This would increase the likelihood of  spreading site contaminants to the
Potomac and increase the operational costs  of the GETS.

Cost -  High: Published costs for  large scale  projects using soil flushing range from $65 to
$200 per cubic yard of treated soil (ITRC, 2003).

Recommendation-In situ soil flushing was eliminated from further consideration  during the
screening and evaluation  stage because  of its potential to drive additional contamination into
the Potomac Aquifer.

3.3.4.4    Ex Situ Soil Washing

Description-Ex situ soil washing applies the soil flushing concept to excavated soils.

Effectiveness-Ex  situ  soil  washing  would  eliminate the  concerns over  the potential for
increased contamination of the Columbia  and  Potomac Aquifers  associated with the in situ
flushing technique. Because of the  large volume of soils that would require treatment and their
sandy nature, it is  possible that these soils would likely require disposal in an off-site landfill.

Implementability-This treatment process would require a large area for implementation.  The
complex mixtures  of contaminants (VOCs,  SVOCs, PCBs, pesticides, dioxins, metals) found at
the site would require sequential  washing steps,  using  different wash formulations and/or
different soil-to-wash-fluid ratios.  Treatability studies would be required to determine what
combination  of washing  steps  and  solutions would  be  needed  to  treat  the   site soils.
Additionally,  because this  technology only separates  the  contamination from the soil, the
recently built GETS would need to be expanded,  a separate treatment system constructed, or
the generated wastewater would have to be  transported to an off-site disposal facility.
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Cost -  Moderate to High: Costs for this technology have  been reported to range between
approximately $50 and $200 per cubic yard (FRTR, 2002; ITRC, 1997), but the nature of the
wastes at the site and the possibility that the treated wastes will need to be disposed off site
would push the costs of implementation to (or possibly above) the high end of this range.

Recommendation-Because of the complexity of the technology, space requirements, and the
potential disruption to the existing GETS, ex situ  soil washing was retained for possible use
with only excavated materials resulting from cap construction.

3.3.4.5    In Situ Thermal Desorption (ISTD)

Description-During ISTD, the soil is heated to temperatures above the  boiling points of the
contaminants (in the range of 500 to 650°F for  most chlorobenzenes), enhancing volatilization
of adsorbed  VOCs  and SVOCs.   Higher temperatures can be utilized  to  address  PCB,
pesticide, or dioxin contamination if necessary.  Heating of the soil in ISTD can be achieved
by several methods,  including hot air or steam  injection,  radio-frequency heating (RFH),
electrical resistance (ER) heating, and thermal conduction heating. Any volatilized compounds
are typically  removed  using  an  SVE  system. Off-gas  is  treated  (typically using carbon
adsorption or thermal oxidation) before discharge. Alternatively, a condenser can be used to
separate the contaminants from the  air stream and  capture them for reuse or disposal as a
liquid.   This combination of SVE and ISTD,  sometimes referred to as thermally enhanced
SVE, is a relatively well established technology that can achieve remediation of a wider range
of organic contamination in a shorter time frame than SVE alone.

Effectiveness-Most, if not all, of the organic contaminants in the soil at SCO can be treated by
ISTD. Unfortunately, this technology would not adequately address most  metals contamination
in the soils, but a mercury capture system would be required as part of  the off-gas treatment
train. While the heating of the soil would increase the mobility of organic contaminants, the
vacuum that  is  developed by  the  systems  extraction wells  would  pull  the volatilized
contaminants away from  the  groundwater and recover them,  minimizing the potential for
contaminant migration to groundwater during process implementation.

Implementability-If used near the soil bentonite  containment barrier, the heat generated  by
ISTD during the treatment of site soils would likely  have an adverse  impact on the long-term
performance of the barrier. For this reason, ISTD  should not be used  in close proximity to the
containment barrier, but the technology could be used to treat other hot  spots.  According to
information  provided  by  one  vendor,  the  "heat  front"  from  ISTD   dissipates  within
approximately 7 ft of the heated zone (TerraTherm, 2007).  To protect the containment barrier
from damage, the heat zone should be kept a minimum of 10 ft from the barrier.  To ensure at
least partial treatment of soils near the  containment barrier, unheated SVE wells could be used
in that area.  Because of the need to place heat sources in relatively  close proximity to each
other, additional  site characterization  would  help  optimize  treatment and  reduce operational
costs.

Cost - Moderate to High: Literature sources list approximate costs for treating site soils using
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ISTD in the range of $40  to  $130 per cubic yard  of  soil (FRTR, 2002;  P2Pays, 1998).
Budgetary estimates obtained in conversations with TerraTherm indicate that costs treatment of
soil contamination of the type found at SCD would be in the range of $125 to $175 per cubic
yard, with treatment of dioxin contaminated soils costing approximately $200/cubic yard.

Recommendation-Because ISTD's expense and the fact that it cannot be used near the soil
bentonite containment barrier, the  technology was retained for use only  in combination with
other technologies, such as unenhanced SVE.

3.3.4.6    Ex Situ Low Temperature Thermal Desorption (LTTD)

Description-Ex situ  LTTD  can be used to remove VOCs and  some SVOCs from excavated
soils. It operates using the same principles as in situ LTTD described earlier:  soil  is heated to
volatilize organic contaminants, and  a carrier  gas or vacuum system transports volatilized
water and organics to the gas treatment system.

Effectiveness-Thermal desorbers with temperatures in the range of 200 to 600°F are able to
achieve 95 percent contaminant destruction efficiency for treating VOCs and SVOCs while the
decontaminated soils retain their physical properties.  Thermal desorbers with temperatures in
the thermal range 600 to 1,000°F can produce final contaminant concentrations below  5 mg/kg
and are effective for treating PAHs, PCBs, pesticides, SVOCs, and VOCs.  LTTD would not
address the bulk of metals contamination at the site and  would require the use of a  mercury
capture system.

Implementability-The  ex  situ  process   has  benefits  of  providing   a  more  controlled
environment, and ensuring consistent treatment. However, it is a more  intrusive and costly
alternative, with high associated excavation and equipment costs.

Cost - Moderate to High: Based on vendor information gathered for the Soil/Sediment Design
Comparison Study, unit costs of between $104 and $195 per cubic yard can be expected (Black
& Veatch, 2003).  These costs are in  line  with those listed in the FRTR for this technology
(FRTR, 2002). It is likely that recent increases in fuel costs would  result in higher treatment
costs than those listed here.

Recommendation-Ex situ LTTD was retained as a possible treatment option  for excavated
soils removed in the process  of surface cap construction.

3.3.4.7    Ex Situ Thermal Destruction (Incineration)

Description-During  the  incineration process,  the  soils are  heated  above  the  combustion
temperature  of most  organic  contaminants  (1,600 to  2,200°F)  in  the presence  of  oxygen.
Available incineration processes include rotary kiln, fluidized-bed, and infrared options.

Effectiveness-High temperatures  employed  during  the incineration process  result in the
destruction of most organic compounds, with treatment efficiencies commonly exceeding 99.99
                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

percent. Generated off gases and combustion residuals generally require treatment.

Implementability-Mobile incinerator units are commercially available, but it is doubtful that
an incinerator would be granted the necessary  permits to operate in the coastal zone.  Off-site
incineration is possible, but transportation of the quantities of soil requiring  remediation over
the distances to the closest acceptable incinerator would increase  the potential to spread site
contamination,  and  would substantially  increase cost.  Given the history  of the  site,  this
approach  would probably not be viewed favorably  by the local citizenry.   Other regulatory
concerns associated with incineration include generation of toxic air pollutants and disposal of
ash residue. An incineration facility must submit to a full-scale evaluation, including a  trial
burn monitored by regulatory agencies, to demonstrate its ability to meet performance criteria
for various materials.  Separately, the soils  in question would have relatively  low energy
content and could require  substantial additional fuel for incineration.

Cost - High: Incineration is a very expensive process with costs ranging from approximately
$585 to $1,171 per cubic yard of soil (FRTR, 2002;  Black & Veatch, 2003). The large volume
of soil from OU-3 that would require treatment might push costs toward  the  lower end of this
range, although recent increases in fuel costs might result in higher  costs.

Recommendation-Considering  the high costs, off site ex situ incineration was retained for
possible treatment of small quantities of excavated soils with contaminants that are  not suitable
for other forms of treatment (such as dioxins and PCBs).

3.3.4.8     In Situ Enhanced Bioremediation

Description-Bioremediation  is  a   process  in  which  microorganisms  degrade  organic
contaminants found in soil and/or groundwater, converting them to less toxic  or innocuous end
products.  There are two  general types of bioremediation: aerobic, which takes place in the
presence of oxygen,  and anaerobic, which takes place in the absence  of oxygen. Natural
bioremediation relies  on  indigenous microorganisms under  existing site  conditions, and  is
likely  to  proceed under  all  alternatives,  including  the no  action  alternative.   Enhanced
bioremediation is  a process in  which site  conditions are modified  to  enhance  the desired
microbial  activity. Addition  of nutrients  (biostimulation),  oxygen (bioventing),  or other
amendments (lactic acid, edible  oil  substrates, oxygen releasing compounds, etc.) may be used
to enhance bioremediation.  Acclimated  microorganisms also can be  added  to  the system
(bioaugmentation). Solutions such as surfactants may  be  utilized to enhance  desorption of the
COCs and increase their bioavailability.

Effectiveness-While the low molecular weight organic COCs, in particular benzene, PCE, and
TCE, may be amenable to bioremediation, the PAHs, pesticides (DDD, DDT), and dioxin are
recalcitrant to biodegradation.   In addition, those compounds that may be  readily degraded
require different  conditions  for optimum degradation  rates.   For  example,  the highly
chlorinated benzenes may be reduced to less-chlorinated benzenes under anaerobic conditions,
but aerobic conditions are required  for the degradation of chlorobenzene  and benzene.  In
addition,  bioremediation  would not address the  metal  COCs.   While  this technology can
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

effectively treat some of the COCs, it cannot address the entire COC list.  Bioremediation was
selected as the primary remedy  for certain site soils and sediments in the  1995 ROD,  but
treatability studies carried out by the  PRP were not successful, and EPA elected to replace
bioremediation with the contingency remedy (ex situ LTTD).

Additionally, the increased chloride concentrations  that would result from the dechlorination
process could have detrimental effects on both the soil bentonite containment barrier and GETS
components.   Finally,  the changes in contaminant composition would likely result in more
mobile  intermediate   species  that  could  travel   into  the  groundwater  before  complete
mineralization is achieved.

Implementability-Because of the  need to distribute amendments  throughout the treatment
zone, to maintain a minimum moisture content for  microbial activity, and to ensure a specific
redox condition for the microbes, in situ bioremediation can be difficult to implement in soil.

Cost - Low to Moderate: Enhanced bioremediation is relatively inexpensive if carried out in
situ, ranging  from $20 to $80 per cubic yard of soil (FRTR, 2002). It also does not require soil
excavation or  expensive reagents.   Enhanced bioremediation  tends  to  be  a  long-term
technology, which may take years to complete cleanup.

Recommendation-Because of the lack of success in the treatability studies, in situ enhanced
bioremediation was eliminated from further consideration during the screening and evaluation
stage as a stand-alone treatment option.

3.3.4.9    Ex Situ Bioreactor/ In-Vessel Bioremediation

Description-In ex situ bioreactors,  the excavated soils  are mixed  with  water and other
additives in a vessel to create a slurry phase for biological treatment of excavated soils.  The
slurry  is  mixed  to  keep solids  suspended  and microorganisms  in contact with the  soil
contaminants. Upon completion of the process,  the slurry is dewatered, and the treated soil is
disposed or reused. Water resulting from dewatering soils also would need to be treated  and
disposed.

Effectiveness-The ex situ bioreactor  can be optimized  to treat most organic contaminants.
This technology will not address the metal COCs.

Implementability-Slurry phase bioreactor vessels can be constructed at the site. Difficulties in
implementation of this TPO  at the SCO  site may result from the large quantities of soils that
would need to be excavated, processed, and dewatered for this site, the process time required
for treatment, the  area that would be required for bioreactor construction, and the likely need
for sequential treatment stages to allow for aerobic and anaerobic reactions.

Cost -High:  The estimated cost of bioreactors with off-gas treatment can range from $125 to
$160 per cubic yard of soil (FRTR, 2002).
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

Recommendation-Because of uncertainties, relatively high costs  and potential difficulties in
implementation, ex  situ bioreactors  were eliminated from further consideration  during  the
screening and evaluation stage.

3.3.4.10   Ex Situ Biopiles

Description-In this  process,  excavated soils are mixed with  soil  amendments  and placed in
aboveground enclosures. The  piles  are aerated with blowers or vacuum pumps, and leachate is
collected.  Moisture,  heat,   nutrients,  oxygen,   and pH  can  be controlled to  enhance
biodegradation.

Effectiveness-This  technology would  require the design and  construction of a pilot-scale
biopile system at the site to confirm its applicability.  Biopiles can treat larger volumes and are
less  costly  than  bioreactors.  Biopile  treatment   is  most  applicable  to  treatment   of
nonhalogenated VOCs and fuel hydrocarbons.  Halogenated VOCs and SVOCs can be treated,
but the effectiveness of the process will vary,  and inorganic contaminants will not be affected
(FRTR, 2002).

Implementability-As  with other ex  situ treatment technologies, soil stockpiling areas would
need to be properly lined to  prevent spread of contamination.  A leachate collection  system
would  also be  required, potentially  requiring treatment of the collected liquid. Any off-gas
from the soil would  likely have to be treated to remove or destroy the VOCs. It is questionable
whether there would be enough area available to construct biopiles  of sufficient size to treat all
of the excavated material resulting from the construction of a surface cap.

Cost - Moderate: Typical costs range from $30 to $60 per cubic yard of soil (FRTR, 2002).

Recommendation-While the technology will not treat all of the contaminants present on site, it
could be used to reduce the toxicity  of excavated soil and make final disposal of the material
less costly.   The technology  was retained for possible use in the pretreatment of excavated
soils excavated during  the construction of a surface cap.

3.3.5   Removal and Disposal TPOs

Removal  cannot  be  considered  a  stand-alone  option  for  the  site  but  instead must be
incorporated  into any technology that includes ex situ treatment or disposal of the contaminated
material.

Excavated soil  can be  disposed in  an on-site or  off-site landfill, either directly  or after it  has
undergone ex situ treatment. Excavated material, whether sent to a landfill off site or placed in
an on-site entombment, would likely be classified as hazardous waste under RCRA.  This waste
classification  could  result in additional  disposal   restrictions.   The  presence  of  certain
compounds (such as dioxins and PCBs)  at concentrations greater than land disposal restriction
limits might  require that  the soil be  treated prior  to disposal.    Excavation of the entire
contaminated soil mass for disposal is not feasible.  As a result, no  disposal alternatives will be
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

retained as stand-alone remedial option.

3.3.5.1    Excavation

Description - Removal of contaminated material would entail excavation of the soil where the
contamination is located.

Effectiveness - Excavation of contaminated  soil would remove the  on  site risks from the
material, but the excavated materials would then have to be treated and  disposed of off-site.

Implementability - While excavation of the entire volume of contaminated soil is not practical
because of the depth and volume of contamination, as well as the potential for damage to the
containment barrier and GETS,  selected hot spots might be excavated for disposal or ex situ
treatment. Limited soil excavation would be needed for construction of the surface containment
barrier.

Cost - Low to High: Excavation costs and health risks associated with soil removal activities
must be  considered as  a part  of any alternatives  involving soil  removal.  These costs  were
incorporated into the unit costs for cap installation.

Recommendation  - Excavation was retained for further  consideration in conjunction  with
surface capping and ex-situ treatment technologies.

3.3.5.2    On Site Landfill

Description -A landfill  will be constructed  on site for disposal of excavated soil. Depending
on the volume of soil requiring disposal, there  might be sufficient area available within the
groundwater  containment  barrier  to accommodate construction  of  a landfill. Benefits,
constraints, and costs for the on-site landfill  option would be similar to those described earlier
for the  surface  cap.  Most  likely,  the  on-site  landfill would be  constructed  using the
Sedimentation Pond (see Figure 1.2). Because of the level of contamination  and  to minimize
the potential  for the spread of  soil  contaminants, the landfill would be  built to the RCRA
Subtitle C requirements.

Effectiveness-If properly constructed  and maintained,  an  on  site  landfill could  achieve
ecological and  human health objectives at the  SCD site by limiting contact with contaminated
soil and soil  gas,  reducing infiltration, and  limiting contaminant  mobility  in the soil. By
limiting infiltration, a landfill would greatly reduce the potential for contaminants to spread via
the soil to groundwater pathway.

Implementability-Space limitations make  this  technology an impractical choice for disposal of
the entire contaminated  soil volume, but an onsite landfill could be used to  dispose of some
surface soils excavated as part  of the construction of a surface cap at the site.  On-site disposal
could easily be implemented using  standard excavation  and landfill construction technology.
Potential problems/issues associated with an  on-site landfill  include  the need for perpetual
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                          Delaware

operation and  management activities,  the lack of  waste treatment,  and the  potential  for
contamination to migrate if the landfill fails.

Cost  -  Moderate:  Measures  to control water  infiltration  and waste  leaching,  including
construction of a bottom and side wall liner, increase  costs relative to surface cap construction.
It  is estimated that costs for landfill construction would be approximately 50% greater than
those for surface cap  installation.

Recommendation-On-site landfilling of excavated  soils was retained for consideration as an
option for surface  soil disposal during surface cap construction.

3.3.5.3    Off Site Landfill

Description-Excavated soil from the source areas at the site are disposed in an off-site landfill
with or without treatment.

Effectiveness-Disposal of contaminated soil in an off-site landfill would be an effective option.
While disposal of contaminated  soils at an existing off-site landfill  may have the benefit
of not  requiring construction of a new landfill, a nearby landfill designed to accept hazardous
wastes of the type present on site would have to be identified.

Implementability-A  detailed  contaminant analysis  would  be  required  before an  off-site
treatment/disposal facility accepts materials. Because  no landfills in Delaware would be able to
accept contaminated  soils, the soils would have to  be transported over  longer distances.  The
Model City landfill in New  York is  the closest permitted landfill that was identified as being
able to accept soils from the site, but there is no rail service to that landfill.  Because of the
volume of contaminated soils requiring disposal and the capacity of commercial dump truck
trailers, use of this landfill would require hundreds of shipments traveling over 450 miles using
public  roads.   In  addition to creating negative public  perception and  permitting issues,  this
approach would increase  the  potential to spread contamination off  site  through spills  or
accidents.  Using  railcars to transport the contaminated materials  would reduce the number of
individual shipments, the potential for off site spread of contaminants, and the  likelihood of
public perception problems.  The closest acceptable landfill that can accept rail shipments is the
Wayne Disposal landfill in Belleville, Michigan.  This landfill is over 580 miles from the SCO
Site.  Additionally, the loading of railcars would require obtaining permission to use  an area
located to the south of Governor Lea Road, constructing containment and loading features,  and
transporting hundreds of waste loads across that road.

The presence of substantial quantities of cement and  other debris  on the ground surface  at the
site means  that it is likely  that  some off-site landfilling will  be  required.   Because  the
demolition debris consists largely of concrete,  asphalt, steel reinforcing rods, and steel plate, it
is  less  likely,  relative to the  underlying and surrounding  soil, that the debris would  be
classified as hazardous waste.   If this material can  be classified as non-hazardous, it could be
disposed of in a landfill that  is closer  to the site (e.g.,  Tullytown  in  Pennsylvania).
Additionally, some of these materials could be recycled.
                                      U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware
Cost - High: Cost estimates for excavation and disposal of contaminated soils range from $210
- $350 per cubic yard of soil (FRTR, 2002). The costs for OU-3 are expected to be toward the
high end of these estimates because of the highly contaminated nature of the waste, increases in
fuel  costs since the time the referenced  estimates were developed, and  the distance to  an
appropriate landfill.   Additional costs  might be incurred if treatment is needed to  meet land
disposal  restriction requirements.  Disposal  of nonhazardous demolition debris would incur
lower costs because the debris could be disposed of in landfills located closer to the site.

Recommendation-Because of the potential  for the spread  of  site  contaminants,  the likely
negative  public  perception issues, and the relatively high expected costs, transportation of
contaminated soils to  an off-site  landfill was eliminated from further consideration during the
screening and evaluation  stage,  but  some  demolition debris (reinforced concrete  rubble  and
asphalt) might need to be sent off-site for landfilling or recycling.

3.3.6   Monitoring of Site Conditions and Contaminant Levels

Description-By inspecting the site and collecting soil, soil gas,  and groundwater samples for
analysis, progress  of other remedial options can be tracked.  For the first two years,  air  and
soil gas monitoring, including measurements of contaminants adsorbed to airborne particles,
would be conducted quarterly for all remedial alternatives to confirm that inhalation exposure
risks for onsite workers and others remain within the allowable human health criteria that are
expressed as  PRGs.  After the first two years sampling would  be conducted on a  semiannual
basis.

Effectiveness-While  monitoring  activities would not reduce  the  risks associated with  the
contaminants, or  the toxicity,  mobility or  volume of  the  contaminants at the  site, these
activities are  necessary for successful implementation of other remedial options.  Surface  soil
contamination could  still be spread  by  stormwater runoff  and   wind-blown particulates.
Monitoring would  be more effective in combination with other remedial options.

Implementability-Monitoring can be easily implemented.

Cost - The cost of monitoring site conditions and contaminants  for the site would be very low
to low depending on analytical requirements and costs.

Recommendation-Monitoring of site conditions and  site  contaminants  was  retained  for
further consideration in combination with other remedial options.

3.4 SUMMARY OF TREATMENT TECHNOLOGIES AND SELECTION OF
    REPRESENTATIVE PROCESS OPTIONS

The process options that were retained for further consideration will be used as components of
the potential remedial alternatives in the subsequent sections of this Report.  Results of the TPO
evaluation are summarized in Table 3.2.
                                     U.S. EPA Region 3
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TABLES

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                              Table 3.1
Identification and Preliminary Screening of Soil and Soil Gas Technologies
          For Standard Chlorine of Delaware Operable Unit 3
                             Page 1 of 3
General
No Action
Institutional
Controls
Containment

None
Institutional
Actions
Fencing
Surface Cap
Subsurface Cap

None
Zoning Ordinances
Restrictive covenants
Access Agreements
Security Fencing
Surface Cap -
Evapotranspiration (ET)
Surface Cap - Soil and Clay
Surface Cap - Chemical
Sealant
Surface Cap - Multilayer
Surface Cap - Asphalt or
Concrete
Subsurface Cap

Take no remedial action. Contaminated soil will be subject to natural
conditions and processes.
Restrict uses of the property and/or limit site access to minimize
exposure and protect site features
Require vapor intrusion control features for all new buildings
constructed on site; restrict groundwater use at the site
Provide access agreements to ensure access for monitoring of soil
gas and air contamination, groundwater sampling, and GETS(2)
operation
Surrounds site and restricts entry into contaminated areas but does
not mobilization/ transport of site contaminants.
Construct ET cap over contaminated areas to reduce infiltration of
precipitation into contaminated soils.
Construct single layer clay cap over contaminated areas
Construct chemical sealant cap using native soil mixed with a
binding agent to reduce the soil's permeability
Install impermeable multilayered surface cap (such as RCRA Subtitle
C cap) to encapsulate contaminated areas
Install low permeability asphalt or concrete cap to encapsulate
contaminated areas
Install a horizontal impermeable barrier within the subsurface at the
site;

Required for
consideration by
NCP
Potentially applicable
Potentially applicable
Potentially applicable
Potentially applicable
if used in conjunction
with other measures
Not effective for
controlling soil gas
contamination
Potentially applicable
Not applicable
because surface and
shallow native soils
are contaminated
Potentially applicable
Potentially applicable
Not applicable
because surface and
shallow native soils
are contaminated

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                              Table 3.1
Identification and Preliminary Screening of Soil and Soil Gas Technologies
          For Standard Chlorine of Delaware Operable Unit 3
                             Page 2 of 3

Treatment
Treatment
(continued)
Removal

Chemical/Physical
Treatment
Thermal
Treatment
Biological
Treatment
Biological
Treatment
(continued)
Excavation

In Situ Chemical Oxidation
Ex Situ Chemical Oxidation
In Situ Soil- Vapor Extraction
(SVE)
In Situ Soil Flushing
Ex Situ Soil Washing
In Situ Thermal Desorption
Ex Situ Low Temperature
Thermal Desorption (LTTD)
Ex Situ Thermal Destruction
(Incineration)
In Situ Enhanced
Bioremediation
Ex Situ Bioreactor/ In- Vessel
Bioremediation
Ex Situ Biopiles
Excavation

Chemical oxidants are injected or mixed into the soil to convert
COCs to less toxic forms.
Chemical oxidants are applied ex situ to excavated soils
A vacuum is applied to the vadose zone aid in removal of VOCs and
SVOCs;
The off-gas is treated (e.g. by activated carbon adsorption)
Contaminants are extracted from the soil with an aqueous medium;
the injected fluid is recovered for treatment and discharge
Excavated soils are suspended in washing solution to concentrate and
extract contaminants
The soil is heated to low temperatures, air is then blown through the
soil as a carrier for desorbed organics; the off-gas is collected for
treatment and discharge.
Excavated soils are run through a thermal desorber for
removal/destruction of organic compounds.
Excavated soils are combusted at high temperatures in the presence
of oxygen to thermally destroy organic contaminants.
Environmental conditions are modified to improve biodegradation
A slurry phase bioreactor is constructed for in-vessel biological
treatment of excavated soils.
Analogous to the bioreactor but the vessel is replaced with above
ground enclosures; Have larger capacities than bioreactors;
Soils are excavated for further treatment or disposal or for
construction purposes

Potentially applicable
away from GETS
components
Potentially applicable
to excavated soils
Potentially applicable
Potentially applicable
Potentially applicable
Potentially applicable
Potentially applicable
to excavated soils
Potentially applicable
to excavated soils
Potentially applicable
Potentially applicable
Potentially applicable
Potentially applicable

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                              Table 3.1
Identification and Preliminary Screening of Soil and Soil Gas Technologies
          For Standard Chlorine of Delaware Operable Unit 3
                             Page 3 of 3
General
Response
Action
Disposal
Monitoring
Technology
Type
Landfill
Site Monitoring
Technology Process Options
On-Site Landfill
Off-Site Landfill
Sampling and Site Inspection
Description of Process Option
An on-site landfill is constructed for disposal of excavated soils
Excavated soils are transported to an off-site landfill
Remedial measures are inspected to check for proper function and/or
damage. Samples are collected to check on and document site
remediation progress.
Pre-screening
Conclusion
Potentially applicable
Potentially applicable
Potentially applicable
in conjunction with
other measures

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                         Table 3.2
Evaluation and Screening of Technology Process Options (TPOs)
      for Standard Chlorine of Delaware Operable Unit 3
                        Page 1 of 9
General
No Action
Institutional
Controls

None
Zoning
Ordinances
Restrictive
covenants
Access
Agreements
Public
Awareness
Programs

Take no remedial action.
Contaminated soil will be
subject to natural conditions
and processes.
Restrict uses of the property
and/or limit site access to
minimize exposure and protect
site features
Require vapor intrusion
control features for all new
buildings constructed on site;
restrict groundwater use at the
site
Provide access agreements to
ensure access for monitoring
of soil gas and air
contamination, groundwater
sampling, and GETS(2)
operation
Conduct Public Meeting and
issue fact sheets to educate
citizens about risks of site
contamination; Post warning
signs at site to alert people of
associated risks.

Rank = 5
Does not address risks from site
soils or soil gas.
Rank =4
Reduces but does not eliminate
human health risks from the site
and should be combined with
other technology options; Does
not address ecological risks.
Rank = 4
Reduces but does not eliminate
human health risks from the site
and should be combined with
other technology options; Does
not address ecological risks.
Rank = 4
Reduces but does not eliminate
human health risks from the site
and should be combined with
other technology options; Does
not address ecological risks.
Rank = 4
Reduces but does not eliminate
human health risks from the site
and should be combined with
other technology options; Does
not address ecological risks.

Rank = 1
Rank = 1
Can be easily
implemented
Rank = 1
Can be easily
implemented
Rank = 1
Can be easily
implemented
Rank = 1
Can be easily
implemented

No to Very Low
cost;
NoO&M
Very Low cost;
NoO&M
Very Low cost;
NoO&M
Very Low cost;
NoO&M
Very Low cost;
O&M Required

Retained as
baseline
comparison
Retained for
development
of remedial
alternatives in
combination
with other
TPOs.
Retained for
development
of remedial
alternatives in
combination
with other
TPOs.
Retained for
development
of remedial
alternatives in
combination
with other
TPOs.
Retained for
development
of remedial
alternatives in
combination
with other
TPOs.

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                         Table 3.2
Evaluation and Screening of Technology Process Options (TPOs)
      for Standard Chlorine of Delaware Operable Unit 3
                        Page 2 of 9
General
Response
Action















Containment
















Technology
Process
Options


Security
Fencing








Surface Cap -
Asphalt or
Concrete











Subsurface Cap





Description of Process
Option
Maintain and add to fencing
around the contaminated
portions of the site



Install low permeability
asphalt or concrete cap to
encapsulate contaminated areas












Install a horizontal
impermeable barrier within the
subsurface at the site;








Effectiveness*1'
Rank = 4
Reduces but does not eliminate
human health risks from the site
and should be combined with
other technology options; Does
not address ecological risks.
Rank = 2
As effective as multilayered cap
in controlling exposure and
spread of contamination;
Improved erosion control; Does
not allow for site revegetation;
Visually unappealing; Resealing
of cap relatively simple if
additional extraction or
monitoring wells needed.





Rank = 4
Does not address contaminated
surface soil (must be excavated
and treated separately); Limits
exposure and transport of
contaminants into groundwater;
Does not treat or remove
contamination; limits allowable
future uses.


Implementability(1)
Rank = 1
Can be easily
implemented



Rank = 2
Is easier to
construct than
multilayered cap;
Requires minimal
modification of GW
extraction system
and monitor wells;
Some soil
removal/treatment
needed; Requires
additional gas
collection system;
Perpetual
maintenance.
Rank = 3
Is relatively easy to
construct; Possibly
requires treatment
or disposal for
large volume of
excavated surface
soil; Requires
additional
stormwater and gas
collection systems;
Cost
Very Low cost;
O&M Required




Low to moderate
cost with lower
O&M than multi-
layer cap











Moderate to high
cost:
O&M required.








Screening
Conclusion
Retained for
development
of remedial
alternatives


Retained for
development
of remedial
alternatives











Eliminated
because
contaminated
surface soils
not addressed
and water
collection and
treatment
issues



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                         Table 3.2
Evaluation and Screening of Technology Process Options (TPOs)
      for Standard Chlorine of Delaware Operable Unit 3
                        Page 3 of 9
General
Response
Action


Containment


















Technology
Process
Options

Surface Cap —
Evapotranspirati
on (ET)





Surface Cap —
Single Layer





Surface Cap —
Chemical
Sealant



Description of Process
Option
Construct ET cap over
contaminated areas to reduce
infiltration of precipitation into
contaminated soils.


Construct single layer clay cap
over contaminated areas






Construct chemical sealant cap
using native soil mixed with a
binding agent to reduce the
soil's permeability




Effectiveness*1'
Rank = 4
ET cap will not address risks
from soil gas; Addresses soil
risks but contamination remains
in place; Reduces infiltration.

Rank =3
Addresses soil and soil gas risks,
but contamination remains in
place; Reduces infiltration.
Single layer cap has increased
potential of failure compared to
other surface caps;


Rank = 4
Soil (and likely soil gas) risks
remain if contaminated surface
soils used as part of cap;
Contamination still in place.



Implementability(1)
Rank = 2
Can be easily
constructed
compared to other
caps; Perpetual
maintenance.
Rank =2
Can be easily
constructed
compared to other
caps; Requires
additional gas
collection system;
Perpetual
maintenance.
Rank =4
Native surface soils
cannot be used in
cap construction
because of
contamination;
Perpetual
maintenance.
Cost
Low Cost;
Reduced O&M
requirements


Low cost
High O&M






Low cost
Low O&M






Screening
Conclusion
Eliminated
because
doesn't
address risks
from soil gas

Eliminated
because of
higher failure
potential




Eliminated
because
contaminated
native soils
can't be used



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                         Table 3.2
Evaluation and Screening of Technology Process Options (TPOs)
      for Standard Chlorine of Delaware Operable Unit 3
                        Page 4 of 9
General
Response
Action


















Treatment




Technology
Process
Options






Surface Cap -
Multilayer









In Situ
Chemical
Oxidation




Description of Process
Option
Install impermeable
multilayered surface cap (such
as RCRA Subtitle C cap) to
encapsulate contaminated areas










Chemical oxidants are injected
or mixed into the soil to
convert COCs to less toxic
forms.





Effectiveness*1'
Rank = 2
Limits exposure and transport of
contaminants offsite;
Does not treat or remove
contamination; limits allowable
future uses; Reduces infiltration;
Limits reuse options for site.
Resealing of cap more difficult if
additional extraction or
monitoring wells needed.




Rank = 3
Potentially can treat most, if not
all, organic site contaminants to
eliminate site risks; Can
mobilize metals but will not treat
them.




Implementability(1)
Rank = 2
Some soil removal
and demolition or
modification of site
features
(particularly the
GW extraction
system and
monitoring wells
required; Requires
additional leachate
and gas collection
systems; Perpetual
maintenance.
Rank = 3
Cannot be applied
to entire site; Can
damage existing
groundwater barrier
wall; Multiple
injection points and
large amounts of
reagent may be
required.
Cost
Low to Moderate
Cost:

O&M required










Moderate cost to
high;

Pilot study
required




Screening
Conclusion
Retained for
development
of remedial
alternatives










Retained for
development
of remedial
alternatives in
combination
with other
TPOs.



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                         Table 3.2
Evaluation and Screening of Technology Process Options (TPOs)
      for Standard Chlorine of Delaware Operable Unit 3
                        Page 5 of 9
General
Response
Action























Treatment





Technology
Process
Options



Ex Situ
Chemical

Oxidation






In Situ Soil-
Vapor
Extraction
(SVE)






In Situ Thermal
Desorption




Description of Process
Option
Chemical oxidants are applied
ex situ to excavated soils









A vacuum is applied to the
vadose zone aid in removal of
VOCs and SVOCs;
The off-gas is treated (e.g. by
activated carbon adsorption)



The soil is heated to achieve
boiling point or near boiling
point of contaminants, air is
then blown through the soil as
a carrier for desorbed
organics; the off-gas is
collected for treatment and
discharge.


Effectiveness*1'
Rank = 3
Could potentially treat all
organic contaminants in
excavated soils. Does not
address inorganic contamination.






Rank = 4
Effective for volatile
compounds, but not for SVOCs,
dioxins, PCBs or metals;
Effectiveness could be enhanced
by combining with thermal
desorption

Rank = 3
Is able to destroy or extract less
volatile compounds; works well
as an enhancement to SVE;
Could address SVOCs, PCBs,
and dioxins; Does not address
inorganic contamination.



Implementability(1)
Rank = 4
Excavation of
entire contaminated
soil volume not
feasible; Would
require construction

of an enclosed
system including
leachate collection
and treatment.
Rank = 2
Air permitting may
be required for
discharge of treated
off-gas; substantial
number of wells
required to treat
entire site.
Rank = 3
Air permitting may
be required for
discharge of treated
off-gas; Substantial
number of wells
required to treat
entire site; high
energy
requirements
Cost
Moderate to high
cost

O&M required







Low to high cost

Pilot study
required;

O&M required


Moderate to high
cost

Pilot study
required;

O&M required



Screening
Conclusion
Eliminated
because of
prohibitive
costs
compared to
other ex-situ

options and
incomplete
treatment.

Retained for
development
of remedial
alternatives in
combination
with other
TPOs.

Retained for
development
of remedial
alternatives in
combination
with other
TPOs.



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                         Table 3.2
Evaluation and Screening of Technology Process Options (TPOs)
      for Standard Chlorine of Delaware Operable Unit 3
                        Page 6 of 9
General
Response
Action

Treatment
Technology
Process
Options
In Situ Soil
Flushing
Ex Situ Soil
Washing
Ex Situ Low
Temperature
Thermal
Desorption
(LTTD)
In Situ
Enhanced
Bioremediation
Description of Process
Option
Contaminants are extracted
from the soil with an aqueous
medium; the injected fluid is
recovered for treatment and
discharge
Excavated soils are suspended
in washing solution to
concentrate and extract
contaminants
Excavated soils are run
through a thermal desorber for
removal/ destruction of organic
compounds.
Environmental conditions are
modified to improve
biodegradation
Effectiveness*1'
Rank = 3
Complicated washing solution
regimen needed to treat all
contaminants; Would mobilize
contaminants and possibly
increase groundwater
contaminant levels.
Rank = 3
Complicated washing solution
regimen needed to treat all
contaminants.
Rank = 3
Excellent organic contaminant
removal; No inorganic
treatment; Higher temperatures
are required to destroy dioxins
and PCBs
Rank = 4
May not ensure the removal of
dioxins or highly chlorinated
compounds;
May take years to complete
cleanup; could result in more
mobile intermediate species that
could impact groundwater;
Previous studies unsuccessful.
Implementability(1)
Rank = 4
Injection of large
fluid volumes could
increase potential of
Potomac aquifer
contamination
Rank = 4
Excavation of
entire contaminated
soil volume not
feasible; Requires
expansion of GETS
or construction of
new treatment
system
Rank = 4
Excavation of
entire contaminated
soil volume not
feasible.
Rank = 3
Past studies by PRP
showed lack of
success
Cost
High cost
O&M required
High cost
Moderate to high
cost;
Pilot study
required
Low to moderate
cost;
Pilot study
required
Screening
Conclusion
Eliminated
because of
potential to
damage
Potomac
Retained for
possible use
with excavated
soils from
surface cap
construction
Retained for
possible use
with excavated
soils from
surface cap
construction
Eliminated
because of
unsuccessful
prior studies
and potential
harm to
barrier wall
and GETS

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                         Table 3.2
Evaluation and Screening of Technology Process Options (TPOs)
      for Standard Chlorine of Delaware Operable Unit 3
                        Page 7 of 9
General
Response
Action























Technology
Process
Options





Ex Situ
Thermal
Destruction
(Incineration)







Ex Situ
Bioreactor/ In-
Vessel
Bioremediation



Description of Process
Option
Excavated soils are combusted
at high temperatures in the
presence of oxygen to
thermally destroy organic
contaminants.









A slurry phase bioreactor is
constructed for in-vessel
biological treatment of
excavated soils.





Effectiveness*1'
Rank = 1
Eliminates all exposure scenarios
if applied to full depth of
contamination onsite;
Incineration is very effective for
treating the organic contaminants








Rank =3
Conditions can be controlled to
promote desired processes;
Bioreactor might not treat all
contaminant classes




Implementability(1)
Rank = 4
Cannot be applied
to entire site;
Potential spread of
contamination
during transport;
Not practical to
excavate all
contaminated
materials;
Incinerators not
permitted in
Delaware Coastal
Zone.
Rank = 4
Difficult to
construct; Cannot
be applied to the
entire site;
Large quantities of
waste fluid are
generated and must
be treated
Cost
Very high cost













High cost








Screening
Conclusion
Retained for
possible off-
site use with
small
quantities of
soil
contaminated
with PCBs
and dioxins





Eliminated
because of
high cost and
uncertain
effectiveness




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                         Table 3.2
Evaluation and Screening of Technology Process Options (TPOs)
      for Standard Chlorine of Delaware Operable Unit 3
                        Page 8 of 9
General
Response
Action




Treatment








Removal








Disposal





Technology
Process
Options




Ex Situ Biopiles








Excavation








On-Site Landfill





Description of Process
Option
Analogous to the bioreactor
but the vessel is replaced with
above ground enclosures;
Have larger capacities than
bioreactors;




Soils are excavated for further
treatment or disposal or for
construction purposes






An on-site landfill is
constructed for disposal of
excavated soils







Effectiveness*1'
Rank = 3
Extensive controls needed to
treat diverse contaminants;
May not treat all contaminant
classes;




Rank = 2
Could remove contamination if
all contaminated soil is removed
for treatment or off-site disposal





Rank = 2
A well designed landfill
eliminates the exposure scenarios
for contained soil;
Contamination is not treated





Implementability(1)
Rank = 3
Cannot be applied
to the entire site;
Easier to construct
than bioreactor;
Engineered
treatment area and
a leachate
collection and
treatment required
Rank = 4
Excavation of
entire contaminated
soil volume not
feasible; Part of
containment
construction and/or
ex-situ treatment
alternatives.
Rank = 3
Restriction on
landfilling exists for
some hazardous
wastes; Not
applicable for large
soil volumes;
Needs to be
maintained
indefinitely
Cost
Moderate to high
cost;

O&M may be
required




Low to high
cost;

No O&M





Moderate cost









Screening
Conclusion
Retained for
possible
limited
treatment of
soils excavated
during cap
construction



Retained for
development
of remedial
alternatives in
combination
with other
TPOs.


Retained for
possible
disposal of
soils excavated
during cap
construction




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                                                                 Table 3.2
                                  Evaluation and Screening of Technology Process Options (TPOs)
                                         for Standard Chlorine of Delaware Operable Unit 3
                                                                Page 9 of 9
General
Response
Action












Monitoring



Technology
Process
Options



Off-Site
Landfill






Monitoring of
Site
Contaminants


Description of Process
Option
Excavated soils are transported
to an off-site landfill







Collect and analyze soil,
groundwater, and soil gas
samples to determine changes
in risks posed by untreated
contaminants


Effectiveness*1'
Rank = 2
Eliminates all exposure scenarios
if applied to full depth of
contamination onsite, but does
not eliminate contaminants.




Rank = 5
Does not address risks from site
soils or soil gas. Useful for
assessing progress of other
technologies.


Implementability(1)
Rank =3
No nearby landfills
accept hazardous
waste; Potential
spread of
contamination;
Potential regulatory
and public
perception issues
Rank = 1
Can be easily
implemented




Cost
Moderate to high
cost







Very Low to
Low Cost





Screening
Conclusion
Retained for
potential
disposal of
non-hazardous
demolition
debris only



Retained for
development
of remedial
alternatives in
combination
with other
TPOs.
(i)   TPOs are ranked qualitatively for effectiveness and implementability, with 1 representing the most effective/easiest to implement and 5 representing the ineffective/impossible to implement
GETS - Groundwater Extraction and Treatment System

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware
4.0 DEFINITION AND SCREENING OF REMEDIAL ALTERNATIVES

The retained TPOs have been  assembled into remedial alternatives that could potentially meet
the RAOs for the site. The remedial alternatives include a "no action" alternative as required
by the NCP, as well as combinations of various containment and treatment processes. ICs are
included as part of all alternatives, except for the "no  action"  option in part because the PRGs
developed in this  FS  Report  are based on  a  restricted land use  scenario.  The proposed
alternatives  are defined in Section 4.1  and  summarized  in  Table 4.1.  In Section 4.2,  the
defined alternatives are evaluated qualitatively based  on their effectiveness, implementability
and cost, and some of the alternatives are eliminated from consideration.

Most  of the soil contamination at the  site  is confined to  the area within the former facility
fence.  As a  former industrial site, the property has very little or no habitat value. The area is
partially paved over, with several  containment  and building pads remaining from previous
operations. As discussed earlier, this area is  highly contaminated, with contamination spread
throughout most of the surface and subsurface.

Although only minimal evidence of contamination was found in the few samples collected from
the Northern Area during RD and RI sampling, drum  remnants and solid chlorobenzenes were
discovered  in  this   area  during  the  construction   of  the  Western  Stormwater Basin.
Consequently this area has been combined with the On Facility area for the  development,  but
not the detailed costing of treatment alternatives.  Additional sampling will be required to
delineate the extent of contamination in this area and determine to what extent remedial action
would be required  in the Northern Area.

4.1 DEFINITION OF ALTERNATIVES

4.1.1   Alternative 1A: No Action

This alternative is required by the NCP and  CERCLA. Alternative 1A requires no remedial
action to be taken at the site.   The  no action alternative serves as a  basis against  which the
effectiveness of all the other proposed alternatives can be compared.   Under this alternative,
the site would remain  in  its  present  condition,  and  the soils  would be  subject  to natural
processes only. No monitoring will take place to keep  track of any changes. Five year reviews
of the  site, required  under  CERCLA, would  consist of at  least  a  site  visit and report
preparation.

4.1.2   Alternative IB:  Limited Action

Alternative  IB is  a  limited action alternative that would  entail implementation of ICs and
revegetation of the site, without any treatment, containment or removal measures.  Under this
alternative,  all of  the ICs  introduced  in Section  3.2.2 would be implemented.  To limit  the
human health risks from the site, zoning restrictions and restrictive covenants would be used to
prohibit almost all future uses of the  land and most construction activities.  ICs under this
                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware

alternative would also include the requirement of vapor intrusion control/mitigation measures
for any future buildings on the site. This requirement could be implemented through the use of
a restrictive covenant.  Additional covenants  would be implemented to ensure that EPA and
DNREC  would be able to access the site to monitor, operate,  and maintain the components of
the existing remedial systems. Although PCBs were not found to be a soil risk driver based on
the available  EPA Method 8081 data,  it is somewhat likely, given the past site activities and
the detections of PCBs (using Method  1668a) in the underlying  groundwater and  adjacent
wetlands, that PCBs are present in some site soils.  To comply with the PCB remediation waste
disposal  requirements of TSCA, notifications  would be included on the deeds of the affected
tax parcels to  alert  future  owners of the presence of  PCB contaminated  soils  along with
restrictive covenants to ensure that the parcels be maintained as "low  occupancy"  areas as
defined in 40 CFR 761.3. Alternative  IB would also include some air monitoring to determine
to what  extent contamination is being spread and  to monitor site risks.   Finally,  security
fencing would be maintained and  inspected to minimize unauthorized site entry. Similarly to
Alternative 1A,  five year reviews of the site, required under CERCLA, would consist of at
least a site visit and report preparation.

The benefits of the  Limited Action  alternative  include its  low  cost and  relative ease of
implementation, accompanied by some decrease in the human health risks from the site through
limiting  human exposure to the contaminated soil and soil gas. However,  soil and soil gas
contamination would  remain at the  current  levels,  and would not be addressed by  this
alternative. Ecological risks would remain unchanged as would the potential  for the migration
of contamination via the soil to groundwater pathways.  Contaminant migration via the soil to
sediment and soil to air pathways would be reduced somewhat  as revegetation of the site would
reduce erosion from stormwater runoff and wind erosion. The current levels of soil and soil
vapor  contamination  exceed acceptable human  health risks  even  for the  limited land use
(industrial or commercial).  Consequently, the land would need to  remain undeveloped.  It is
expected that this option would meet with considerable resistance from local citizens.

4.1.3   Alternatives 2A - 2D: Containment

The On  Facility area is surrounded by the  recently constructed soil bentonite groundwater
containment barrier.  Depth to water within the containment barrier is approximately 40 ft bgs,
and is  expected to drop to  approximately 50 ft bgs as  the pump-and-treat system continues to
operate.  These features lend themselves to containment alternatives that utilize a horizontal
surface barrier. Contaminated surface soils that are excavated to construct a surface cap across
the On Facility portion of the site might require ex situ treatment and/or disposal if they cannot
be placed back in the area to be capped.

The surface barrier could be used alone (Alternative 2A) or in combination with some form of
treatment to address hot spots (Alternatives 2B-2D).  In the cap plus treatment alternatives,  the
surface cap would be constructed as described in Alternative  2A; however,  some form of in
situ soil  treatment would  be used to address the most  contaminated  areas to improve  the
potential  long-term options for the site. Even though these treatment alternatives would remove
only a portion of the contamination, it is expected that they would  decrease the potential  for
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

contaminant migration via the soil to groundwater pathway.  Additionally, a  reduction in soil
contaminant levels would reduce  the operational costs of the surface cap gas recovery  and
treatment system and could reduce  the annual operating  costs of the GETS.  The treatment
options that are compatible with the surface cap installation are:
    •   2B. In Situ SVE
    •   2C. ISTD
    •   2D. ISCO

In combination  with each containment option,  ICs would  be used to  restrict  land  use to
commercial, light industrial,  naturalized open space, or parkland use and to  require that any
construction activities minimize the  impact on and  repair any damage to  the cap.  Restrictive
covenants  could  be  used to  require  incorporation of vapor intrusion control/mitigation
measures into any building  constructed on  the  site, maintenance  of the installed cap,  and
provision of site access  to EPA  and DNREC to monitor, operate,  and  maintain all  remedy
components.  Although PCBs were  not found to be a soil risk driver based  on the available
EPA Method 8081 data, it is somewhat likely, given the past site activities and the detections
of PCBs  (using Method  1668a)  in  the underlying  groundwater and adjacent wetlands,  that
PCBs are present in  some site soils.   To comply with the  PCB remediation waste disposal
requirements of TSCA, notifications would be included on the deeds of the affected tax parcels
to alert  future  owners  of the  presence  of PCB-contaminated soils  along  with restrictive
covenants to ensure that  the parcels  be  maintained as "low occupancy" areas  as defined in 40
CFR 761.3.  All  containment options would include some monitoring of site conditions  and
possible collection of air and water (groundwater and surface water) samples  to document the
effectiveness of the remedy and guarantee that cap integrity is maintained.   Security fencing
would  remain in place at least until cap  construction is complete  and the disturbed area is
stabilized.  Maintaining the security fence beyond the completion of the  cap  construction and
site stabilization would reduce the possibility of damage to the cap because of vandalism, but
this would further limit the possible end uses of the site and incur extra expense.

Regardless of the containment approach used, demolition and removal of concrete  slabs, tanks,
process columns, and other structures located on site will be required.  Concrete resulting from
the demolition of building and tank farm foundations, secondary containment structures, storm
sewers, the former WWTP,  and other structures would be  crushed using a  mobile concrete
crusher.  The crushed material  would be spread across the area to be capped.  In the event that
crushing  of the concrete or  spreading  of the crushed  material proves to be unfeasible, the
concrete  would be  transported off-site to  a  landfill  or recycling  facility  along with the
remaining demolition debris.  Risks to construction workers from exposure to the COCs during
excavation and construction activities would also have to be monitored and mitigated.

4.1.3.1    Alternative 2A; Surface  Cap Alone

The surface cap would  be designed as described in subsection  3.3.3.1 of  this FS  Report.
Depending on the proposed use of  the site,  a concrete, asphalt, or multilayer cap would be
installed.   While  a multilayer  cap using a clay  and/or geosynthetic clay layer would allow
revegetation of  the site and  reduce  surface  water  runoff to some extent, construction of an
                                     U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report               4—3                             HydroGeoLogic, Inc. July 2009

-------
HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

asphalt or concrete cap would require less modification of the GETS and associated monitoring
wells/piezometers.   The asphalt and concrete cap options might  also reduce the amount of
surface soil and demolition debris that would need to be treated and/or disposed of.  The final
choice of material for a surface cap would be determined during the detailed alternative design
stage. Regardless of the type of cap emplaced,  demolition and removal of concrete slabs,
tanks, process  columns, and other  structures  located on  site will be required.   Demolition
debris could be crushed and  incorporated into the soils under the cap or transported off-site to
a landfill or recycling facility.

A soil gas capture system would be included to minimize gas buildup beneath the cap and off-
gassing to the atmosphere. To improve  capture,  it would  be beneficial to tie the cap into the
groundwater containment barrier on the south, west and  east sides, even though this would
result in the capping of some less contaminated  regions.  Gas collection measures would be
placed along the proposed northern edge of the cap and at other areas around the cap.

The entire portion of the On Facility area that lies within the containment barrier (22.8 acres)
would  be capped under  this alternative as shown in  Figure 4.1.   This  would effectively
eliminate the soil and soil gas exposure pathways in that area.  To ensure that none of the
contamination in the rail siding  area (a main  pathway of the 1981 and 1986 spills) remains
exposed, the surface cap would  be  extended  approximately ten foot beyond the containment
barrier in this area. Depending on subsequent  sampling results from the Northern Area portion
of OU-3, some or all of that area might be incorporated under the cap.  For purposes of cost
estimating,  a worst  case scenario in which the entire 60,000 square foot (approximately 1.4
acres) area  would be capped was used for the Northern Area.   Further delineation of the
contamination in this area must be conducted as part of the  RD.

A surface  cap would quickly and  effectively achieve  RAOs for the soil and soil  gas  by
preventing human and ecological contact with contaminated soils, and controlling the  spread of
contamination from the capped area. Infiltration of water into the contaminated soils  would be
minimized,  addressing the soil to groundwater  migration pathway and reducing the operational
costs of the GETS.   Surface capping is an attractive alternative because it would isolate the
entire depth of contamination  without  excavation  or treatment of the  subsurface  regions.
Construction of a surface cap would be considerably less expensive than other alternatives, and
installation of a surface cap can be completed  in less than a  year. Exclusive of the demolition
and disposal of the remaining surface and subsurface structures at the site, the cost for capping
the 22.8 acre  area  is estimated  at between  $7.0 million  and $13.5 million.   Adding the
Northern Area would increase this cost to between $7.4 million and $14.3 million.  Demolition
of the remaining site structures (i.e.,  warehouse, tank  farm foundations and  containment
structures,   abandoned  storm drains  and utilities,  roads),   crushing  and  spreading  of the
concrete, and off-site disposal of the remaining debris would  add approximately $4.1 million to
the total costs.   Project support activities (e.g.,  design, construction management,  project
management, waste  management, etc.) would  add another $4.3 to $4.4 million to the project
total.  If site soils excavated to complete construction of the cap cannot  be  placed back in an
area that will be  covered by the cap, costs  for  treatment  and/or disposal of the excavated
                                     U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report               4-4                            HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

material must be added to the above price range.  Technologies for  addressing the excavated
materials are discussed following the presentation of Alternative 2D.

The primary deficiencies of this alternative are that, without additional treatment measures, the
COCs would not be removed or destroyed in a  reasonable time frame. However, the capping
of the area would eliminate the  human and ecological exposure pathways related to  soil,
sediment, and soil gas.  Additionally, a properly constructed and maintained cap would greatly
reduce the potential for precipitation to infiltrate through the contaminated OU-3 soil  and
would  thus  reduce  the  potential  transportation  of  additional  contamination  into  the
groundwater.   The  cap would likely have  to  be maintained into perpetuity,  resulting in
continuing  inspection,  maintenance,  and  repair expenses.   Simple  containment of  the
contaminants  might also  meet with   some  resistance from nearby  residents,  and future
construction and site use alternatives would be limited.

4.1.3.2    Alternative 2B; Surface Cap with In Situ SVE

Alternative 2B incorporates all of the features of Alternative 2A  but adds an SVE system to
address "hot  spot"  contamination.    By equipping  the surface  cap with an SVE system,
contaminant toxicity and volume would be reduced, and migration  of contaminants into the
groundwater could be  further reduced. In addition to the gas recovery system that would be
installed  with the  cap,  multiple SVE  wells would be placed in some or  all of the  hot spots
identified in Section 1.5.1  and  shown  on Figure 4.1.  The total number of SVE wells needed
would be determined based on  the areas of influence observed during pilot studies that would
be conducted at the site as part of the design process.  The sandy soils that underlie the site and
the relatively deep water table (over 40 ft bgs) indicate that larger radii of influence (15 to 25 ft
per well) can be expected.   Pilot studies  would  also be used to  quantify  the  potential
contaminant reductions  that could  be achieved by SVE at the site. Captured vapor would be
treated (along with the gases from  the cap gas recovery system)  with activated carbon  or a
condensing system before being released into the atmosphere.  Thermal and catalytic  oxidizers
have been  eliminated  as  potential  off-gas  treatment options because  the chlorinated  site
contaminants would be corrosive and require the additional use of a scrubber system.

Although SVE would not effectively treat metals, PCBs, dioxins, or most of the SVOCs, it
would help reduce the soil gas concentrations and would likely remove substantial contaminant
mass.  Additionally, SVE could  be  used  in fairly  close  proximity  to  the  soil  bentonite
containment barrier without significant risk of damage.  Because of the large volume of soils
(approximately 610,000 cubic yards) that would be treated in this approach, an SVE system of
the type envisioned here would likely add between $3.1 million and $9.2 million to the cost of
the cap alternative. These estimates assume unit treatment costs between $5 and $15 per cubic
yard. If site soils excavated to complete construction of the cap cannot be placed in an area that
will be covered by the  cap,  the costs  for treatment and/or  disposal of the excavated material
would need to be added to the total cost range  stated above.
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

4.1.3.3    Alternative 2C; Surface Cap with In Situ Thermal Desorption

In this alternative, the SVE system in 2B would be supplemented with heat to enhance removal
of organic contaminants including  SVOCs,  dioxins,  pesticides,  and PCBs. As mentioned
previously, ISTD could be  achieved by steam  injection,  hot air injection, ER heating, or
thermal conductance heating. Because of the temperatures necessary for volatilization of the
chlorobenzene compounds, it is likely that neither steam injection nor air injection would be
effective.  Pilot studies would be required to determine appropriate temperatures, identify well
placements for effective  treatment, and quantify the potential reduction that could be achieved
by ISTD.  Because of the potential for the heating to dry out the clay  that would be used in the
barrier layer of a multilayer cap, ISTD might be applied to the aforementioned hot spots before
construction of that type of cap.   Alternatively, the zones nearest  to the cap could  be left
unheated.   Because some of the worst contamination lies in the subsurface soils close to the
western leg of the soil bentonite containment barrier, ISTD would likely be augmented with
some regular SVE wells  to avoid damage to the barrier but achieve at least partial treatment in
this area.

It is estimated that using ISTD to treat the 610,000 cubic yards of soil that compose the "hot
spot" areas prior to installing a surface cap would  increase the On  Facility remedy costs by
approximately $76.2 million  to $122.0 million. If site soils excavated to complete construction
of the  cap cannot be placed in an  area that will be covered by the cap, costs for treatment
and/or disposal of the excavated material would need to be added to the previously stated price
range.

4.1.3.4    Alternative 2D;  Surface Cap with ISCO

This alternative includes all of the features from  Alternative 2A, but oxidants would be either
injected or mixed into the soils of the "hot spot" areas.  As opposed to the other alternatives in
which  treatment could continue during and  following  the cap construction,  ISCO would be
performed to reduce contaminant concentrations before the construction of a surface cap.  This
sequential effort would be utilized to ensure that the cap integrity would not be impacted by the
oxidants or disrupted by  soil mixing activities.  Additionally, because of concerns regarding
possible chemical attack, ISCO would not be used near the  containment barrier.  Increased
chloride concentrations that would result from the oxidation of site contaminants could also be
detrimental to the long term effectiveness of the soil bentonite  containment barrier and GETS.
Further compatibility testing  would be required to determine whether this technology could be
used without damaging these two features.  It is estimated that adding ISCO treatment of the
"hot spot" areas to the  surface capping approach would increase the facility remedy costs by
approximately $18.3 million to $61.1 million.

4.1.4  Options for Excavated Soil from Surface Cap Construction

Removal  of  from one  to four feet of surface  soil might be  required during  surface  cap
construction.  Given that the total proposed area to be capped is ranges from 22.8 to 24.2 acres,
the total excavated volume would be  in the range of 37,000 to  156,000 cubic yards.
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware
Because large areas of surface soil at the facility are contaminated, excavated soil would need
to be treated or properly disposed of if it cannot be reintegrated into the area being covered by
the cap. This  soil can either be landfilled on site as hazardous waste or treated ex situ before
on site disposal or utilization. Options 1 through 4 for dealing with the excavated surface soil
are detailed below.   While these approaches could  effectively deal with  some or all of the
contaminants  in  the  excavated soil, the most cost-effective method of  dealing with these
materials would be to integrate them back into the soils that  would be covered by the surface
cap.  Consequently,  no  detailed analysis  of these  contingency measures will  be provided
beyond the screening  level examination presented in this section.

4.1.4.1    Excavated Soil Option I; On-Site Landfilling

Under this  option, an  on-site  landfill would have  to be designed and  constructed  for the
disposal of excavated surface soils that are above PRGs.  A landfill can be constructed in the
northern portion  of the site,  most likely in  place of the Sedimentation Pond (see Figure 1.2).
The Sedimentation Pond now contains highly contaminated sediment covered with water. The
liner in the  basin has deteriorated and the  contaminants  are  leaking into  the soil below. Site
preparation for construction of a new landfill at the basin location would involve removing and
dewatering the sediments  and a portion of the underlying contaminated  soils. The removed
water would  be  treated  in  the  existing  groundwater  treatment system.   The remaining
sediments and soils would be placed into the newly constructed landfill.

The TSSA was  constructed to contain approximately 20,000 cubic yards  of material.  The
TSSA crowns at  approximately 9  ft above ground surface, and covers 1.5 acres.  If an on-site
landfill were constructed to a height approximately three times that of the TSSA, it is estimated
that an area of approximately one to three acres would be required to contain the excavated
soil. Assuming that the unit costs for constructing an on-site landfill would be approximately
50% greater than the capping costs described above,  it is expected that the additional cost of
the landfill would be between $340,000 and $2.25 million.

This option does  not  provide treatment or eliminate the COCs from the excavated soils. As in
the case of the surface cap, the on-site landfill would need to be maintained  into perpetuity.

4.1.4.2    Excavated Soil Option II; Ex Situ LTTD / Incineration

Under this option, excavated surface soils would be treated ex situ, using a mobile LTTD unit
equipped with an off-gas collection  and treatment system.  Although LTTD could substantially
reduce organic contaminant levels, it would not address inorganic contamination.   Treated soils
determined to  have metals  concentrations in excess  of the PRGs would have to be landfilled on
site or shipped to an off-site industrial landfill.

Treated soils and untreated soils that do not exceed PRGs could be reused in the construction
of a multilayer cap or disposed of on site.  The reuse of these soils would require that certain
logistical  issues  be  addressed.   Primary  among  these  are achieving  sufficient  treatment
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

throughput to  keep up with surface cap construction rates and ensuring sufficient soil storage
area is available.

In LTTD, temperatures are usually raised to approximately  200 °F  to 800 °F.  A pilot test or
test-burn would need  to  be conducted to determine  whether the LTTD unit is capable of
removing/destroying  the  dioxins,  PCBs, and  other  COCs present in the  soils.  If it  is
determined that the technology cannot sufficiently treat PCBs and dioxins, the affected soils
would  probably need  to be  shipped off-site for incineration and/or disposal.    Additionally,
LTTD would  not address inorganic contamination that has been found  throughout  the site.
Although a certain amount of wastewater would be generated from on-site LTTD treatment,
the water could be treated in the GETS.  Assuming that 30 percent of the excavated material
would  need to be incinerated and  average unit costs of $150/cubic yard for LTTD and
$900/cubic yard  for incineration, the expected added costs  related to this treatment option
would be approximately $13.9 million to $58.5 million.

4.1.4.3    Excavated Soil Option III; Ex Situ Biopile Treatment

This option would require the design and construction of a biopile system at the site.   The
excavated soil would  be  mixed with soil amendments and  placed  in enclosed  aboveground
aerated piles, equipped with aeration and leachate collection systems. Moisture,  heat, nutrients,
oxygen, and pH can be controlled to enhance biodegradation.  Collected liquid waste would be
treated in the  existing groundwater treatment system,  potentially requiring an update to the
current NPDES permit. The air leaving the soil also  would have to be treated to remove or
destroy the VOCs.  As with LTTD, organic contamination would be reduced, but it is unlikely
that inorganic  contamination  would be  reduced.   Treated soils determined to have metals
concentrations in excess of the PRGs would likely have to be landfilled on  site.

Halogenated  benzenes  are the primary   COCs  in  the  surface soils.  Highly  halogenated
compounds  are  not  readily  biodegraded  under aerobic  conditions,  but  benzene  and
chlorobenzene (potential daughter  products of the reductive dechlorination of chlorobenzenes)
typically degrade more readily in aerobic environment.  Potentially, an anaerobic stage could be
used to dehalogenate chlorinated compounds and make them more amenable to biodegradation,
followed by aerobic degradation.  Pilot studies  would be  required  to determine the  specific
requirements for implementing this option.

Assuming the  same  logistical issues that are  listed  in Excavated Soil Option II  can be
overcome,  this option would likely add  between  $1.7 million  and $7.0 million to  the cap
construction costs.   This range assumes  an average unit cost of $45 per cubic yard of soil
treated.

4.1.4.4    Excavated Soil Option IV; Ex Situ Soil Washing

The principles of operation for the soil washing system were described  in the TPO  section.
Assuming that most of the soil contaminants are  adsorbed  to  fine particles,  the amount of
contaminated soil that  needs to be landfilled could  be  significantly lowered  by  separating fine
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

soil particles from bulk soil using ex situ soil washing.

The washing solution can be augmented with a leaching agent, surfactant, or pH adjustment to
help remove the contaminants.  The system should also include an air treatment  unit (e.g.
carbon adsorption) to remove VOCs. Pilot studies would be needed  to determine the specific
requirements for implementing this technology and to formulate the washing solutions. The
groundwater treatment system  should be  capable of treating  the  resulting liquid wastes,
although some modification might be required.

The  same  logistical  issues  that  are listed in Excavated  Soil Option II would need  to  be
overcome for this option to be considered.   Assuming  an average unit treatment cost  of
$150/cubic yard, this option would likely  add between $5.6 million  and $23.4 million to the
cap construction costs.

4.1.5   Alternatives 3A - 3D: In Situ Treatment

The entire  contaminated area could possibly be treated in situ without construction of a cap.
This approach, if successful, would ultimately  eliminate the risks associated with soil and that
portion of the  soil gas risk that is the result of soil contamination. Soil gas risks related to the
presence of groundwater contamination and non-aqueous phase  liquid  (NAPL) will continue
until these  contaminants are cleaned up.    Groundwater and NAPL  contamination  are being
addressed as part of OU-1.

If controlled properly, ISTD (Alternative  3A) could remove all  COCs, including SVOCs,
PCBs,  and possibly,  to a lesser extent, dioxins from the  site soils.  Additional controls and
higher temperatures necessary to achieve dioxin removal with SVE could be avoided  by adding
ISCO to  treat regions contaminated with certain recalcitrant COCs, provided these regions are
not located close to the containment wall (Alternative 3B).  Alternatively,  soils from areas with
high concentrations of dioxin and other recalcitrant COCs could be excavated and shipped off-
site for incineration (Alternative 3C).  Instead of  using ISTD, most of the contaminated soils
could  be treated  using  ISCO,  with  SVE utilized only  in the regions close  to  the  wall
(Alternative 3D).  In any treatment alternative, pilot studies would be required to  determine
treatability  of the site contaminants and optimize the treatment application. Because the PRGs
reflect the assumption that ICs will  be utilized as part of any remedy for the site, ICs  would be
used to restrict land use to  commercial, light  industrial, naturalized  open space, or parkland
use regardless of the remedial alternative that is selected.

Although PCBs were not found to be a soil risk  driver based on the available EPA Method
8081 data,  it is somewhat likely, given the past site activities  and  the detections of PCBs (using
Method 1668a) in the underlying groundwater and adjacent wetlands, that PCBs are present in
some site soils.  Therefore,  depending on the clean up levels achieved, notifications  might be
required  on the deeds of the affected tax parcels to alert future owners of the presence of PCB
contaminated soils and restrictive covenants might be employed  to ensure that the parcels are
maintained as  "low occupancy" areas as defined in 40 CFR 761.3.  Finally, security fencing
would  remain  in place at least until clean up goals have been achieved and any disturbed area
                                     U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report               4-9                            HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware

is stabilized.  These alternatives would include at least some monitoring to determine whether
any contaminant rebound occurs.

Regardless of the type of treatment used, demolition and removal of concrete slabs, tank farm
foundations and containment structures, process columns, the warehouse,  and other structures
located on site  will be required.  Demolition debris would be transported off-site to a landfill
or recycling facility.

4.1.5.1     Alternative 3A; ISTD/SVE for Entire On Facility Area

Under this alternative, a vacuum would be applied at several extraction wells throughout the
On  Facility area to extract volatilized contaminants. Because SVOCs, PCBs, and dioxins are
present,  SVE would be  thermally  enhanced using one  of the available  techniques, such as
thermal conduction or ER heating. The installed heating and extraction wells must be thermally
resistant  to withstand the high temperatures.   ISTD heating wells  are typically constructed of
carbon steel  casings with combination heating/extraction wells constructed of a carbon steel
outer casing with a stainless inner casing.  Because of the acidic nature of the groundwater at
the  site,  it is possible that wells will need to be constructed of stainless steel.  Some form of
surface cap or liner would be utilized to  minimize  fugitive emissions and the potential for
short-circuiting. The collected vapor  would  be treated  in  an activated  carbon system and
discharged. Compliance with the substantive provisions  of air discharge  permit requirements
would likely  be required.  The duration of operation and maintenance for an ISTD system is
typically  in the range of several months to a few years.

Pilot treatability studies and additional sampling are recommended before ISTD is implemented
so that well placement and operating parameters (such as temperature and required vacuum)
can be optimized.   Based on  the  estimated  soil  volumes requiring  treatment (presented in
Tables 2.4 and 2.5) and the aforementioned unit costs for this technology,  it is expected that an
ISTD remedy would cost between $124.2 million and $162.2 million to complete.

4.1.5.2     Alternative 3B; ISTD Combined with ISCO for Select Locations

This alternative is similar to Alternative 3A,  except that some of the  soils containing certain
recalcitrant COCs  would be treated  with ISCO.  Treatability studies would be required to
ensure that ISCO would be capable of destroying these COCs.  Additional sampling would be
needed to  confirm which  areas  would  be  treated with ISCO.   Of the identified areas of
contamination  at  the  site, ISCO  would  likely  be used to address the  off-product/PCB
concentration area and portions of the former process area.  If shown to  be effective  in pilot
tests,  the use of ISCO to address areas could possibly allow the use of lower temperatures for
the  ISTD and decrease overall remedial costs.   Using  the estimated soil volumes requiring
treatment presented in Tables 2.4 and the aforementioned unit costs for ISTD and ISCO, and
assuming that 10% of the contaminated soils would be addressed with ISCO, the total costs of
this combined treatment  approach would likely fall in the range of $104.6 million to $151.8
million.
                                     U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report              4-10                           HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

4.1.5.3    Alternative 3C; ISTD with Excavation and Off-Site Incineration of Dioxin
Contaminated Soils

This alternative is similar to Alternative 3B, except that some of the soils containing dioxin and
other recalcitrant COCs  would be  shipped off site to be incinerated and disposed of. To
develop costs for this alternative,  the estimated soil volumes  requiring treatment presented in
Tables 2.4 and 2.5,  the aforementioned unit costs for ISTD,  and  an average incineration cost
of $900/cubic yard were assumed.   If the total volume of dioxin contaminated soils is sent off
site for incineration,  it is estimated that the cost of this alternative would range between $226.9
million and $264.9 million.

4.1.5.4    Alternative 3D;  ISCO with SVE near the Wall

Under Alternative 3D, Fenton's Reagent would be applied, either through subsurface injections
or soil mixing, to achieve ISCO throughout almost the entire contaminated soil volume  in the
former facility area.   Because of concerns about the possible  impacts of the oxidation process
(or the resulting increase in chloride levels)  on the containment barrier,  the use of ISCO would
be restricted to areas more  than  25 ft from the barrier.  If soil mixing  were selected as the
application method,  this zone  of prohibition  would likely be increased  to address structural
stability concerns.   Within  those  portions of the site where  ISCO is  prohibited, SVE wells
would be installed to provide treatment of VOC contamination.

Although earlier bench scale testing did show effective treatment of multiple chlorobenzenes,
PRGs were not available at  the time, and not all species that  pose  ecological and/or human
health risks were monitored.   Consequently,  additional testing would  be necessary to ensure
that  those  species that drive these  risks would be  sufficiently treated  and to optimize the
required dosing schemes. Because  soil concentrations have been shown to vary substantially
across the  former facility area, additional  characterization of  the site would be required to
identify dosing/application requirements.  Pilot scale testing for the SVE  component would be
needed to determine an accurate  radius of influence  so that the spacing  of injection wells, if
utilized, could be optimized.

Because the added volume of liquid oxidants  required to achieve contaminant treatment could
increase the hydraulic head  in  the Columbia Aquifer,  additional groundwater extraction wells
and modifications to the treatment system might be required.   A modification to the  NPDES
permit equivalence for the GETS also might be required to account for any additional volume
of treated effluent.

The  costs for this alternative were  developed using  the estimated soil volumes  presented in
Table 2.4, the aforementioned unit costs for ISCO, and an average SVE cost of $15 per cubic
yard. Assuming that 10% of the contaminated soils would be addressed with SVE, the total
costs of this combined treatment approach  would likely fall in the range of $25.8  million to
$82.9 million.
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

4.2 SCREENING OF REMEDIAL ALTERNATIVES

The  assembled alternatives defined  above  were  screened  based  on  their effectiveness,
implementability,  and cost. The  purpose of this  evaluation  is  to  reduce  the  number of
alternatives that will undergo a more thorough and extensive analysis as the FS progresses.  In
terms of effectiveness, each alternative  was ranked on a scale of 1 (complete destruction or
removal  of  all site  contaminants) to  5  (no  or minimal destruction  of removal of site
contaminants).  With regard to implementability,  the alternatives were ranked on a scale of 1
(no construction or O&M required) to 5 (not feasible to implement).  Alternative costs were
rated on a scale of very low to very high using the following ranking brackets:
   •   Very Low: $0 to $4.99 million
   •   Low:  $5 million to $14.99 million
   •   Medium: $15 million to $24.99 million
   •   High: $25 million  to $49.99 million
   •   Very High: >  $50 million.

The  results  of the screening are  summarized  in Table 4.2.  Based on the results of the
screening process the following alternatives will be carried forward for more detailed analysis:
   •   Alternative 1:  No Action (required)
   •   Alternative 2A: Surface Cap
   •   Alternative 2B: Surface Cap with SVE
   •   Alternative 2C. Surface Cap with ISTD enhanced SVE

If possible, soil excavated during the cap construction process should be placed back into the
area that will be  capped.  In case it is  not possible to reintegrate the excavated soil, the
following options for dealing with this  material should be considered as contingency measures:
   •   Option I: On Site Landfilling
   •   Option II:  Ex Situ  LTTD/Landfilling
   •   Option IV: Ex Situ Soil Washing
                                     U.S. EPA Region 3
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TABLES

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                                                            HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware
                                                                                                                                                                                                                         Table 4.1
                                                                                                                                                                                             Summary of Remedial Alternatives
                                                                                                                                                                           for Standard Chlorine of Delaware Operable Unit 3
                                                                                                                                                                                                                        Page 1 of 2

No Action
Institutional
Controls
Containment
Removal
In Situ
Treatment
Ex Situ
Treatment
Disposal/
Discharge
Monitoring

None
Zone Ordinances;
Restrictive
covenants; Access
Agreements
Security Fencing
Horizontal Surface
Cap
Excavation
In Situ Chemical
Oxidation
In Situ Soil-Vapor
Extraction (SVE)
In Situ Thermal
Desorption (ISTD)
Ex Situ Biopiles
Ex Situ Thermal
Destruction
(Incineration)
Ex Situ Low-
Temperature
Thermal Desorption
(LTTD)
Ex Situ Soil
Washing
On-Site Landfill
Off-Site Landfill
Additional Discharge
to Surface Water
Site Inspections and
Media Samnline
No Action

•




















































































































































•
•
•
•








.(i)

•


•
•
•
•

•






.(i)

•


•
•
•
•

•
•





.(i)

•

































































































































































































































































































































































































































































































































































































































•
•
•
•







•


•


•
•
•
•




•
•



•




























































































































•
•
•
•






•


•

Standard Chlorine of Delaware Site Feasibility Study Report
                                                                                                          U.S. EPA Region 3
                                                                                                                                                                                                                   HydroGeoLogic, Inc. July 2009

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                                                             HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware
                                                                                                                                                                                                                              Table 4.1
                                                                                                                                                                                                 Summary of Remedial Alternatives
                                                                                                                                                                               for Standard Chlorine of Delaware Operable Unit 3
                                                                                                                                                                                                                            Page 2 of 2
General
Response
Action
Studies
Technology Process
Options
Additional
Characterization
Sampling
Pilot/Treatabilitiy
Studies
No Action
Alternative
Alternative
1A:
No Action


: : : Limited : : : :

: : : : ACtMW : : : : :

^Alternative::









: : Alternate : :
:::::: IB?: ::::::

• - - - i ^liyfl \i£ jj- ' ' ' '























Containment Alternatives (Surface Cap)
Alternative
2A:
Surface Cap
•

Alternative
2B:
Surface
Cap with
In Situ
SVE
•
.
Alternative
2C:
Surface Cap
with
Thermally
Enhanced In
Situ SVE
•
.







; ; AllCrHatWe; ; ;




: : Surface: Cap : :

::Wltt:In:Sltti:::














::::::::»:::::::::








Treatment Alternatives









: : : : :t .-. :sHt,, : : : : :
: : : : Ui:M.tli: : : : :

: : : Thermal: : : :


















::::::::#::::::::




















' ' l^fllJLJ' with ' ' '


















:::::::«::::::::













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; ; ; IKTI&wiflih ! !


' 'RfeJti0i^^ii ftitu '
> > >• >*riri?*T' > >>>>>>">


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;;;;;; -SOilS !!!!!!




::::::::«.::::::::















; AltftrnapYP: :



: JSC0:wlth : :

::ȴE:Near:::
:th«:BSjWte*::











:::::::»::::::::








Excavated Soil Options (Surface Cap)<3)
Excavated
Soil Option
I: Onsite
Landfilling


Excavated
Soil Option
II: Ex Situ
LTTD/
Incineration

.







: : IxeHv&tfed : :

' 'kMMl C/lMlCill '
:iH;:Ex:SitB::

;;;;BftJ|»lle::::
: : freatwaat : :


















Excavated
Soil Option
IV: Ex Situ
Soil
Washing

.
Note - Shaded alternatives have been eliminated from further consideration
(1) - Off site landfilling would only be used for disposal of demolition debris.
Standard Chlorine of Delaware Site Feasibility Study Report
                                                                                                            U.S. EPA Region 3
                                                                                                                                                                                                                       HydroGeoLogic, Inc. July 2009

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                                                               HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware
                                                                                                                                                                                                                                   Table 4.2
                                                                                                                                                                                                      Summary of Remedial Alternatives
                                                                                                                                                                                   for Standard Chlorine of Delaware Operable Unit 3
                                                                                                                                                                                                                                 Page 1 of 4
    General
No Action
     Alternative 1:
     No Action
                    Take no remedial action. Contaminated soil
                    will be subject to natural conditions and
                    processes;
                    Five year reviews will be conducted.	
                                          Rank  = 5
                                          Does   not  eliminate  human  health  or
                                          ecological risks;
                                          Fails to meet identified ARARs.
                                          Rank = 1
                                          No  construction  or operation and maintenance  (O&M)
                                          required.
                                                                                                                                                                                    Very Low
                                                                                         Retained as a baseline for other
                                                                                         alternatives
Institutional
Controls
Monitoring,  and
Containment
(Security Fencing
Only)
     Alternative IB:
     Limited Action
                    Take no remedial action. Contaminated soil
                    will be subject to natural conditions and
                    processes;
                    Zoning ordinances, restrictive covenants
                    used to restrict future site uses;
                    Public awareness programs used to alert
                    community of hazards related to site.
                    Fencing and warning signs used to limit
                    unauthorized access;
                    Revegetation of site to provide some
                    stabilization of surface soils;
                    Periodic monitoring of site conditions and
                    sampling of air;
                    Five year reviews will be conducted.	
                                          Rank  = 4
                                          Reduces  human  health risks but does not
                                          eliminate or reduce ecological risks;
                                          Does  not  address  soil  to  groundwater
                                          pathways.
                                          Future site use severely limited.
                                          Fails to meet identified ARARs.
                                                                                                                          Rank = 1
                                                                                                                          Minimal regrading and planting of site required. No O&M
                                                                                                                          required.
                                                                                                                                                                       Very Low
                                                                                                                                   Not retained because of failure
                                                                                                                                   to be protective of the
                                                                                                                                   environment and to meet
                                                                                                                                   ARARs
Containment
     Alternative
     2A: Surface
     Cap
                    ICs(2);
                    Horizontal surface barrier(3);
                    Treatment and disposal of excavated soil
                    that can not be reintegrated into area under
                    cap(4);
                    Off-site disposal of demolition debris.
                    Gas capture system under cap with
                    activated carbon off-gas treatment;
                    Security fencing to remain in place at least
                    until cap is completed;
                    Periodic monitoring of site conditions and
                    sampling of media;
                    Five year reviews will be conducted.	
                                          Rank  = 2
                                          Prevents human and wildlife contact with
                                          contaminated soils;
                                          Controls    spread    of    contamination
                                          addressing  all contaminant migration and
                                          exposure pathways;
                                          Does  not  permanently remove  or  treat
                                          contamination;
                                          Limits  the  allowable  future  uses  and
                                          construction alternatives;
                                          Allows  compliance with  most  identified
                                          ARARs.
                                          Rank = 2
                                          Relatively easy to construct;
                                          Compatible with IGR but some modifications  necessary to
                                          protect piezometers, extraction wells, and monitor wells;
                                          Might require treatment and disposal of 1 to 4 ft of soil from
                                          cap area;
                                          Monitoring and O&M required indefinitely.
                                                                                                                                                                                    Low to Medium
                                                                                                                                                                                    (Approx. $13.3 - $22.9 million)
                                                                                                                                                                                                      Retained for detailed analysis
Containment
Treatment
and
Alternative 2B:
Surface Cap
with In-Situ
SVE
ICs(2);
Horizontal surface barrier®;
Treatment and disposal of excavated soil
that can not be reintegrated into area under
cap(4);
SVE recovery wells in identified hot spots
and gas capture system under cap;
Activated carbon treatment system for
captured gas;
Security fencing to remain in place at least
until cap is completed;
Periodic monitoring of site conditions and
sampling of media;
Five year reviews will be conducted.	
Rank = 2
Same as Alternative  2A, with  additional
long-term benefits from removal of VOCs;
SVOCs,  dioxins, and PCBs will not be
removed;
Allows  compliance  with most  identified
ARARs.
Rank =3
Compatible with IGR but some modifications necessary to
protect piezometers, extraction wells, and monitor wells;
Might require treatment and disposal of 1 to 4 ft of soil from
cap area;
Requires pilot studies, construction, O&M of SVE system;
Monitoring and O&M of cap required indefinitely;
                                                                                                                                                                                    Medium to High
                                                                                                                                                                                    (Approx. $16.4 - $32.1 million)
                                                                                                                                                                                                      Retained for detailed analysis
Standard Chlorine of Delaware Site Feasibility Study Report
                                                                                                               U.S. EPA Region 3
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                                                               HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware
                                                                                                                                                                                                                                  Table 4.2
                                                                                                                                                                                                     Summary of Remedial Alternatives
                                                                                                                                                                                  for Standard Chlorine of Delaware Operable Unit 3
                                                                                                                                                                                                                                Page 2 of 4
    General
Response Action
       Alternative
                          Summary of Alternative
Effectiveness'1
                                                                                                      Implementability0
                                                                                                               Cost
                                                                                             Screening Conclusion
Containment
Treatment
and
Alternative
2C: Surface
Cap with ISTD
Enhanced SVE
ICs(2);
Horizontal surface barrier®;
Treatment and disposal of excavated soil
that cannot be reintegrated into area under
cap(4);
SVE recovery wells in identified hot spots
and gas capture system under cap;
Soil is heated using radio frequency
heating, electrical resistance, thermal
conductance, hot air injection, or steam
injection;
Activated carbon treatment system to treat
captured organics not destroyed by heating;
Security fencing to  remain in place at least
until cap is completed;
Periodic monitoring of site conditions and
sampling of media;
Five year reviews will be conducted.	
Rank = 1
Same as Alternative  2A, with additional
long-term benefits  from removal of COCs
in hot spots;
Potentially  capable of destroying/removing
most SVOCs, VOCs, PCBs and dioxins;
Non-VOC  contamination  will  remain in
areas adjacent to  bentonite containment
barrier;
Allows  compliance  with  most  identified
ARARs.
Rank = 3
Same as Alternative  2C  with  additional  effort for ISTD
construction,  higher  electrical  costs,  and  shorter  O&M
period for SVE;
Only unheated wells can be used within 10  ft of containment
barrier;
Might require treatment and disposal of 1 to 4 ft of soil from
cap area;
Reduces  long  term  carbon usage  and  SVE  O&M  as
compared to Alternative 2B, but requires higher short term
energy usage;
Monitoring and O&M of cap required indefinitely.
                                                                                                                                                                                   Very High
                                                                                                                                                                                   ($89.5 - $144.9 million)
                                                                                                                                                                                                     Retained for detailed analysis
Containment  and
Treatment
     Alternative
     2D: Surface
     Cap with ISCO
                    ICs(2);
                    Horizontal surface barrier(3);
                    Treatment and disposal of excavated soil
                    that cannot be reintegrated into area under
                    cap(4);
                    Use of Fenton's Reagent or persulfate
                    compound to oxidize organic contaminants;
                    ISCO prior to cap construction
                    Security fencing to remain in place at least
                    until cap is completed;
                    Periodic monitoring  of site conditions and
                    sampling of media;
                    Five year reviews will be conducted.
                                          Rank = 3
                                          Same  as Alternative 2A,  with additional
                                          long-term benefits from removal of COCs
                                          in hot spots;
                                          Potentially  capable  of destroying  most
                                          organic contaminants;
                                          Metals contamination could be mobilized;
                                          Contamination will remain in areas close to
                                          containment barrier;
                                          Oxidants and increased  chlorides  from
                                          treatment    could   negatively    impact
                                          containment barrier and/or GETS;
                                          Allows  compliance with most identified
                                          ARARs.
                                          Rank = 4
                                          Some  modifications   necessary  to  protect  piezometers,
                                          extraction wells, and monitor wells;
                                          Might require treatment and disposal of 1 to 4 ft of soil from
                                          cap area;
                                          Requires pilot studies, compatibility testing and injection or
                                          mixing of oxidants into soils;
                                          Monitoring and O&M of cap required indefinitely;
                                          Cannot be implemented close to the containment barrier and
                                          potentially incompatible with GETS.
                                                                                                                                                                                   High to Very High
                                                                                                                                                                                   ($31.6-$84.0 million)
                                                                                                                                                                                                     Not retained because of
                                                                                                                                                                                                     potential incompatibility with
                                                                                                                                                                                                     IGR and high costs
Standard Chlorine of Delaware Site Feasibility Study Report
                                                                                                              U.S. EPA Region 3
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                                                              HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware
                                                                                                                                                                                                                                 Table 4.2
                                                                                                                                                                                                    Summary of Remedial Alternatives
                                                                                                                                                                                 for Standard Chlorine of Delaware Operable Unit 3
                                                                                                                                                                                                                               Page 3 of 4
    General
Response Action
  Alternative
      Summary of Alternative
Effectiveness'1
Implementability0
Cost
Screening Conclusion
Treatment
Alternative
3A: ISTD with
SVE
ICs(2);
SVE recovery wells across entire 22.8 acre
former facility area and up to 1.4 acres of
Northern Area;
Soil is heated using radio frequency
heating, electrical resistance, thermal
conductance, hot air injection, or steam
injection;
Unheated SVE wells for locations within
10 ft of containment barrier;
Activated carbon treatment system to treat
recovered organic vapors not destroyed by
heating;
Security fencing to  remain in place at least
until treatment is completed;
Periodic monitoring of site conditions and
sampling of media;
Five year reviews will be conducted.	
                                                                                Rank = 3
                                                                                Potentially capable of destroying/removing
                                                                                most SVOCs, VOCs, PCBs and dioxins;
                                                                                Non-VOC contamination will remain in
                                                                                areas adjacent to soil bentonite containment
                                                                                barrier;
                                                                                No treatment of inorganics;
                                                                                Allows compliance with most ARARs.
                                                                                                       Rank = 3
                                                                                                       Same  as  Alternative 2C  with additional effort for ISTD
                                                                                                       construction and shorter O&M period for SVE;
                                                                                                       Only unheated wells can be used within 10 ft of containment
                                                                                                       barrier;
                                                                                                       Reduces long  term SVE  carbon usage  and SVE  O&M
                                                                                                       relative to Alternative  2C,  but requires substantially  higher
                                                                                                       short term energy usage;
                                      Very High
                                      ($124.2 - $162.2 million)
                   Not retained because of failure
                   to address risks related to
                   inorganic contaminants and
                   high costs
Treatment
Alternative 3B:
ISTD
Combined with
ISCO for
Select
Locations
ICs(2);
SVE recovery wells across entire 22.8 acre
former facility area and up to 1.4 acres of
Northern Area;
Soil is heated using radio frequency
heating, electrical resistance, thermal
conductance, hot air injection, or steam
injection;
Activated carbon treatment system to treat
recovered organic vapors not destroyed by
heating.
ISCO to treat areas recalcitrant to ISTD,
such as off-product/PCB concentration area
and portions of the  former process area;
Security fencing to  remain in place at least
until treatment is completed;
Periodic monitoring of site conditions and
sampling of media;
Five year reviews will be conducted.	
                                                                                Rank = 3
                                                                                Potentially capable of destroying/removing
                                                                                most SVOCs, VOCs, PCBs and dioxins;
                                                                                Non-VOC contamination might remain in
                                                                                areas adjacent to SB containment barrier;
                                                                                No  treatment of  inorganics  and  could
                                                                                mobilize metals contamination;
                                                                                Allows compliance with most ARARs.
                                                                                                       Rank = 4
                                                                                                       Same  as  Alternative 3A  with additional effort for ISCO
                                                                                                       implementation;
                                                                                                       Only unheated wells can be used within 10 ft of containment
                                                                                                       barrier;
                                                                                                       Potentially reduces temperature required for ISTD
                                      Very High
                                      ($104.6-$151.8 million)
                   Not retained because of failure
                   to address risks related to
                   inorganic contaminants and
                   high costs
Standard Chlorine of Delaware Site Feasibility Study Report
                                                                                                             U.S. EPA Region 3
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                                                                   HGL—Feasibility Study Report, Standard Chlorine of Delaware Site,  Operable Unit 3 (OU-3) — New Castle County, Delaware
                                                                                                                                                                                                                                                 Table 4.2
                                                                                                                                                                                                                  Summary of Remedial Alternatives
                                                                                                                                                                                              for Standard Chlorine of Delaware Operable Unit 3
                                                                                                                                                                                                                                               Page 4 of 4
     General
Response Action
  Alternative
       Summary of Alternative
Effectiveness'1
                                                                Implementability0
                                                                          Cost
Screening Conclusion
Treatment
Alternative
3C. ISTD with
Excavation and
Off Site
Incineration of
Dioxin-
Contaminated
Soils
ICs(2);
SVE recovery wells across entire 22.8 acre
former facility area and up to 1.4 acres of
Northern Area;
Soil is heated using radio frequency
heating,  electrical resistance, thermal
conductance, hot air injection, or steam
injection;
Activated carbon treatment system to treat
recovered organic vapors not destroyed by
heating;
Excavation, off-site transportation, and
incineration of dioxin-contaminated soils
with final disposal in an off-site landfill;
Security fencing to remain in place at least
until treatment is completed;
Periodic monitoring of site conditions and
sampling of media;
Five year reviews will be conducted.	
                                                                                     Rank = 3
                                                                                     Potentially capable of destroying/removing
                                                                                     most SVOCs, VOCs, PCBs and dioxins;
                                                                                     Non-VOC  contamination  will  remain in
                                                                                     areas adjacent to containment barrier;
                                                                                     No treatment of inorganics;
                                                                                     Allows compliance with most ARARs.
                                            Rank = 4
                                            Same effort for ISTD implementation as in Alternative 3A;
                                            Lower   electricity   requirements  than  Alternative   3 A;
                                            Additional effort for excavation and transportation of dioxin
                                            soils to off-site incinerator facility with final disposal in off-
                                            site landfill;
                                            Only unheated wells can be used within  10 ft of containment
                                            barrier;
                                            Transportation of hazardous material could cause regulatory
                                            and public relations issues;
                                            Potential to spread contamination during  transport.
                                                                                                                                                                           Very High
                                                                                                                                                                           ($226.9 - $264.9 million)
                                                                                               Not retained because of failure
                                                                                               to address risks related to
                                                                                               inorganic contaminants and
                                                                                               high costs
Treatment
Alternative
3D. ISCO with
SVE Near the
Wall
ICs(2);
Application of Fenton's reagent throughout
the contaminated vadose zone except near
the containment barrier;
Unheated SVE wells for locations within
10 ft of containment barrier;
Activated carbon treatment system to treat
SVE off-gas;
Security fencing to remain in place at least
until treatment is completed;
Periodic monitoring of site  conditions and
sampling of media;
Five year reviews will be conducted.	
Rank = 3
Potentially capable of destroying/removing
most SVOCs, VOCs, PCBs and dioxins;
Non-VOC contamination will  remain  in
areas adjacent to containment barrier;
No  treatment  of inorganics  and  could
mobilize metals;
Allows compliance with most ARARs.
Rank = 4
Requires pilot studies, construction, O&M of SVE system;
Previous pilot  studies for ISCO did not consider all  of the
COCs and their associated PRGs;
Injection of large volume of liquid oxidants might require
modification of  GETS,  construction of a new treatment
system, and/or changes to NPDES Permit equivalence.
                                                                                                                                                                                              High to Very High
                                                                                                                                                                                              ($25.8 million to $82.9 million)
                                                                                                                                                                                                            Not retained because of failure
                                                                                                                                                                                                            to address risks related to
                                                                                                                                                                                                            inorganic contaminants and
                                                                                                                                                                                                            high costs
    Alternatives are ranked qualitatively on effectiveness and implementability, with 1 representing the most effective/implementable, and 5 representing the least effective/implementable.
    ICs are part of Alternatives 2A-2D and 3A-3D. ICs include zoning ordinances, restrictive covenants and access agreements. Zoning ordinances will be applied to restrict uses of the property and/or limit site access to minimize exposure and protect site features. ICs to limit site use are required because the PRGs were
    developed for a restricted land use scenario. Restrictive covenants can be included to require that vapor intrusion control features are installed for all new buildings constructed on site. Access agreements would be provided to ensure access for monitoring and maintenance of existing and planned remedial systems.
    Surface cap will consist of a multilayer Subtitle C vegetated cap or a concrete/asphalt cap, and will be constructed over the entire portion of the On Facility area located within the containment barrier (22.8 acres). Depending on RD delineation of Northern Area, up to 1.4 additional acres will be included under the cap. The
    cap will be tied into the existing groundwater containment barrier on three sides, and it will be equipped with soil gas capture system.
    Potential treatment/disposal options for excavated soil include on site landfilling, ex situ LTTD/incineration, and ex-situ soil washing.
Standard Chlorine of Delaware Site Feasibility Study Report
                                                                                                                     U.S. EPA Region 3
                                                                                                                                                                                                                                          HydroGeoLogic, Inc. July 2009

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FIGURE


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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware
5.0 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES

This  Section  presents  a detailed  evaluation  and  comparison  of the potential  remedial
alternatives retained  as  a result of the screening process conducted in Section 4 of this FS
Report.  In this  Section, the  nine  CERCLA evaluation criteria are introduced,  and  each
alternative is described in detail and evaluated individually based on the CERCLA criteria. A
comparison of the  remaining remedial alternatives based on their relative performance against
each of the evaluation criteria will be conducted in Section 6. Table 5.1 summarizes the results
of individual evaluation of the final alternatives.

5.1 EVALUATION CRITERIA

According to  the  EPA  Guidance for Conducting Remedial  Investigations  and Feasibility
Studies Under CERCLA (RI/FS Guidance) (EPA, 1988), the detailed analysis of alternatives
should provide  decision-makers  with  sufficient  information  to  adequately  compare  the
alternatives,  select an appropriate  remedy,  and demonstrate  satisfaction  of the  CERCLA
remedy selection requirements in the ROD. Based on the RI/FS Guidance and in conformance
with the NCP, the  alternatives will be compared based on the first seven of the following nine
evaluation criteria:
   1) Overall protection of human health and the environment
   2) Compliance with ARARs
   3) Long-term effectiveness and permanence
   4) Reduction of toxicity, mobility or volume
   5) Short-term effectiveness
   6) Implementability
   7) Cost
   8) State acceptance
   9) Community acceptance

The  first two of these criteria (overall protection of human health and the  environment,  and
compliance with ARARs) reflect  statutory requirements to  the ROD. These two criteria are
categorized as threshold criteria,  because any alternative that is selected for implementation
must  meet them. Criteria 3 through  7 are  the  balancing criteria used  to  compare  retained
alternatives.  The  final  two  criteria  (state  or  support agency  acceptance and community
acceptance) are  modifying  criteria  used  to  identify and address concerns of the state  and
surrounding  community. Modifying criteria are not evaluated  in  the  FS, but are instead
addressed in the ROD based on comments received during the public comment period. Each of
the nine criteria,  as it applies to OU-3, is briefly discussed below.

5.1.1  Overall Protection of Human Health and the Environment

All retained  alternatives  must  achieve  the overall protection  of human  health  and  the
environment.  This evaluation  criterion provides an  overall assessment of  each alternative's
ability to protect  human health  and  the environment,  focusing on how each alternative
                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

addresses site risks from each exposure pathway through treatment, engineering controls,  or
ICs.

5.1.2   Compliance with Applicable or Relevant and Appropriate Requirements

The remedial alternatives are evaluated to determine whether they attain the ARARs that were
presented in Section 2.2.  To  be selected  for  implementation,  an  alternative must meet  all
ARARs or have a justifiable reason why a waiver is appropriate.
In addition to the evaluation presented below,  evaluation of each  alternative with  respect to
each of the relevant ARARs is summarized in Appendix B of this report.

5.1.3   Long-term Effectiveness and Permanence

This criterion evaluates the risk  from untreated waste or treatment residuals remaining at the
conclusion of remedial  activities.  This evaluation takes into account contaminant volume,
toxicity,  mobility, and propensity of the residuals to bioaccumulate.  This analysis also includes
assessment  of  the  uncertainties associated with an  alternative   for  providing   long-term
protection  from  wastes  and residuals; the  potential  need  to  maintain  or  replace technical
components of the alternative; and the potential exposure pathways  and risks posed should the
remedial action need replacement.

5.1.4   Reduction of Toxicity, Mobility or Volume

There is  a  statutory preference for remedies that permanently and significantly reduce toxicity,
mobility, or volume  of the  hazardous substances. This  criterion is used to  evaluate  the
anticipated performance of the specific technologies an alternative may employ. The factors to
be considered include the extent to which total mass, volume, and/or mobility of contaminants
are reduced; the toxicity of residuals resulting from the remedy; and to what extent the effects
of treatment are irreversible.

5.1.5   Short-Term Effectiveness

This criterion is used to measure the effects of the various alternatives on human health and the
environment during implementation  of the remedial action;  as well as  the effectiveness of the
proposed measures to protect the community,  workers, and the environment.

5.1.6   Implementability

This criterion  addresses the  technical and administrative feasibility  of  implementing  an
alternative, including the availability of services and materials required for its implementation,
the ease  of construction and operation, monitoring considerations,  the historical reliability of
selected  technologies,  and the ease  with which the  alternative can be integrated  with other
remedial actions that might be necessary at the site.

5.1.7   Cost
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

The total cost for the remedial action includes capital and O&M costs, both direct and indirect.
Capital costs consist of the  direct costs for  items  such as  labor, materials, equipment, and
services  plus  the  indirect  costs  for  engineering  management,  permits,   startup,  and
contingencies. A  15% contingency was utilized in all capital cost estimates for the alternatives.
O&M  costs are the  annual post-construction  costs necessary to maintain the remedial action.
O&M  costs  include  such items as operating labor, maintenance,  auxiliary materials, and
energy.

A present worth analysis is used to evaluate expenditures that occur over different time  periods
by discounting all future costs to a common base year.  In accordance with EPA guidance,
present worth estimates are calculated  at a 5% discount  rate over 30 years (EPA, 2000), with
2008 as a base year.

The cost estimates in this report  are order-of-magnitude level estimates, which are based on a
variety of information including quotes from suppliers, generic unit costs, vendor information,
conventional cost estimating guides,  and  professional judgment.

5.1.8   State Acceptance

This assessment  evaluates issues and concerns  the state  might  have regarding each of the
alternatives. State acceptance is not  discussed in this analysis, because it will be addressed in
the ROD based on the state's comments on the FS Report and the Proposed Plan.

5.1.9   Community Acceptance

Community  acceptance  is evaluated  based  on  issues  and  concerns the public may  have
regarding each of the alternatives. This criterion will also be addressed in the ROD once public
comments on the  Proposed Plan have been  received.

5.2 DEFINITION AND INDIVIDUAL ANALYSIS OF ALTERNATIVES

In this section all  the  alternatives retained for detailed analysis  are  further defined and
evaluated based on the first seven evaluation  criteria listed above. The following alternatives,
which  were summarized  in Table 4.1, were retained for detailed analysis:
   •   Alternative 1A: No Action
   •   Alternative 2A: Surface Cap
   •   Alternative 2B: Surface Cap with SVE
   •   Alternative 2C: Surface Cap with ISTD

5.2.1   Alternative 1A: No Action

5.2.1.1    Description

The no-action alternative is  included  as a baseline for  comparison of other alternatives. No
remedial activities or ICs would be implemented  under this alternative, although  some level of
natural attenuation might occur.  The performance of the no action alternative with respect to
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

each of the seven evaluation criteria is discussed below:

5.2.1.2    Overall Protection of Human Health and the Environment

Because no action would be performed, this alternative would not protect human health or the
environment.  Risks from soil and soil gas contamination at the site  would not be significantly
different from those identified in the baseline risk assessment.

5.2.1.3    Compliance with ARARs

Because no action would be  taken, the ARARs would not be met.

5.2.1.4    Long Term Effectiveness and Permanence

This alternative includes no  controls for exposure and no long-term management measures. All
current and potential future risks would remain under this alternative.

5.2.1.5    Reduction in Toxicity, Mobility, or Volume

This alternative provides no significant  reduction  in toxicity,  mobility, or volume  of the
contaminants in site soils or  soil gas.

5.2.1.6    Short Term Effectiveness

There would be no additional risks posed to the community, the workers, or the environment
as a result of this  alternative being implemented.

5.2.1.7    Implementability

There  are no implementability concerns posed by this remedy  because no action would be
taken.

5.2.1.8    Cost

There are no projected costs associated with Alternative 1A.

5.2.2   Alternatives 2A, 2B, and 2C: Common Elements

With the exception of the  No Action  alternative, all of the  proposed remedial alternatives
include some form of ICs in combination  with  other  treatment or containment  methods. The
proposed ICs include site use limitations that could be implemented through zoning ordinances,
restrictive covenants and access  agreements, in combination with air monitoring program and
continued use  and maintenance  of the  existing site fence  and warning  signs  to restrict
unauthorized access to the Site. The  ICs applicable to  the OU-3 are described in Section 3.3.2
of this report. In  addition, each of the remaining alternatives employs some form of a surface
cap to minimize  precipitation infiltration, vapor  intrusion risks, soil contact  risks, and the
potential spread of soil contaminants.  Alternative-specific differences in the implementation of
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

these common elements will be discussed for each remedial alternative.

Because a substantial portion of the On Facility area is covered with reinforced concrete and
asphalt, demolition and disposal costs for these materials make up a significant portion of the
total costs associated with implementing each of these alternatives.  If a cost-effective method
of grinding the concrete waste could be identified, then actual capital costs may be less than the
estimated values.

Although the Northern Area portion of OU-3 (or some part of it) could be included in each of
these alternatives, there is a lack of data showing  what (if any) portions of this  1.4 acre area
would  require remediation.  As a result, costs related to the Northern Area portion  of OU-3
are not included  in the  detailed costs presented in the  following alternative descriptions.
However, it is  expected that  the costs for capping the  entire Northern Area would range
between $430,000 and $827,000 depending on which type of cap was used.   Costs for the
treatment  components of Alternatives 2B  and 2C were not estimated for the  Northern Area
because the  greater uncertainty associated with  possible soil  volumes requiring  treatment
(anywhere between  0 and 111 ,000 cubic yards) would make the accuracy (and value)  of any
such evaluation questionable.

5.2.3  Alternative 2A: Surface Cap

5.2.3.1    Description

This alternative includes construction of a concrete, asphalt, or multilayer surface cap (such as
RCRA Subtitle C cap), as described in Section 4.1.3.1. Air monitoring, security fencing, and
ICs (site use limitations that could  be implemented through zoning, access agreements, and
restrictive covenants) described in that section are also a part of this alternative. The proposed
location and extent of the cap is shown in Figure 4.1. The surface  cap would be tied into the
previously constructed vertical groundwater containment barrier on the west, south,  and east
sides of the On-Facility Area.  On the north side,  the cap border would be the  southern
boundary  of the Northern Area, as shown in Figure 1.2. The approximate area to be covered
by the surface cap  is 22.8 acres. If it is  determined that some or  all of the  Northern Area
portion of OU-3 is contaminated at levels greater than the Off-Facility PRGs, the northern end
of the cap would be extended to incorporate those  areas. Prior to the construction of the cap,
substantial quantities of concrete, asphalt, and subsurface  utilities would have  to demolished
and removed from the cap area.

Although  all of the  proposed cap alternatives would include multiple layers, the concrete and
asphalt cap  options  are  somewhat  simpler to construct.  A soil-based multilayer cap would
typically include the following layers and is shown  schematically in Figure 5.1:
   •   An upper vegetative topsoil layer (approximately  3 ft in thickness);
   •   A sand or geonet drainage layer;
   •   A geosynthetic FML;
   •   A  low  permeability  barrier layer (approximately  2 feet  of compacted clay  and/or
       geosynthetic  clay with permeability not to exceed 10"7 cm/sec);
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    •   A gas extraction layer.

A concrete or asphalt cap would include the following layers, as shown schematically in Figure
5.2:
    •   Asphalt (wearing and binder courses) or concrete layer
    •   Crushed stone base layer
    •   Low permeability flexible membrane liner (FML);
    •   Gas extraction/venting layer.

One advantage of the concrete or asphalt cap is that it would more readily allow for installation
of additional extraction or monitoring wells if required in the future as compared to the multi-
layer cap.  Details on the specific type, materials and  thickness of the cap will be developed
during RD activities. The chosen surface cap type would depend on  the intended use for the
site. Regardless of the cap type,  subsurface and surface structures (i.e., piping, storm drains,
utilities,  extraction well  vaults,  concrete  containment pads,  demolition  debris) and mature
vegetation would need to be removed prior to cap construction.  This  demolition debris would
be sampled to determine whether it  can be sent off site for disposal in a  nonhazardous waste
landfill or recycled.  Debris that is determined to be hazardous would likely be decontaminated
and disposed of off site or ground up and incorporated into the  soils in the area to be capped.

To ensure cap integrity, the cap and the area around it would be graded to divert surface runoff
to the east and west stormwater basins or other stormwater management features that would be
built during the cap  construction. The stormwater control system would be designed to allow
for integration of the cap into the adjacent ecosystems.  The area to be capped would have to
be  compacted  (using  vibratory  rollers  or another standard  compaction device)  to provide
proper structural cap  support.   As discussed earlier,  it is possible  cap construction would
require the excavation of 37,000  cubic yards to 156,000 cubic yards of soil. Although various
options of treating and disposing  of these soils were presented in Section 4.1.4, the most cost-
effective method of dealing with these materials would be to  reintegrate them into the area to
be capped.   To minimize the potential for these materials to cause structural problems with the
completed cap, they  should be screened prior to being placed back in the  facility area.  If these
excavated soils cannot be reintegrated into  the soils  under the cap,  they would  need to be
treated or disposed using one of the treatment or disposal options introduced in Section 4.1.4.

Depending on  the type of cap employed,  the capped area could be available for compatible
land uses including park land, naturalized open space, warehousing, storage facilities, or other
low occupancy (as defined in 40 CFR 761.3) facilities. Performance  of Alternative 2A with
respect to the seven CERCLA evaluation criteria is discussed below.

5.2.3.2    Overall Protection of Human Health and the Environment

The surface cap alternative would adequately protect human  health and  the  environment by
minimizing human and wildlife contact with contaminants in soil and  soil  gas. If implemented
and maintained properly,  Alternative 2  would  virtually  eliminate   all  exposure  pathways
identified in the BLRA for human and ecological exposure. Surface cap,  in combination with
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the ongoing groundwater remedy,  would also minimize spread of contamination out of the
capped  area  by reducing  infiltration, decreasing volatile and  fugitive dust emissions, and
isolating contaminants from surface water runoff. The existing GETS would prevent spread of
contamination from the capped area via the groundwater pathway.

5.2.3.3    Compliance with ARARs

Compliance of Alternative 2A with the  relevant ARARs is summarized in Appendix B and
briefly discussed below.

Although Alternative 2A would not reduce the contaminant concentrations,  it would meet the
chemical-specific ARARs for soil and soil gas (expressed as the risk-based PRGs in Table 2.2
and 2.3) by preventing or limiting human and ecological exposure to contaminated soil and soil
gas.  Installation of a surface cap would also reduce or eliminate the potential for contaminants
to migrate from facility soils to groundwater, air, sediments, and off site soils.  ICs  such as
restrictive covenants and zoning ordinances  would further minimize  the potential for future
exposure.

Air emissions generated  by potential treatment and disposal of the  soil excavated  during cap
construction,  other excavation or soil moving activities, and the vapor collection system would
need to comply with Clean Air Act and the Delaware State Implementation Plan. The types
and  frequency of air  monitoring  activities  necessary to meet these requirements will  be
finalized during the RD activities. Dust suppression measures would be employed  during
surface  cap  construction  activities to  ensure  that  emissions  are minimized  to  meet the
requirements  of these regulations.

Solid waste and waste residuals (such as spent carbon) generated by the vapor collection and
treatment system,  and,  potentially, from  treatment of  any  excavated  soils,  would  be
categorized and disposed in compliance with the RCRA, as amended in 42 USC §§6901  et seq,
the associated RCRA regulations, and the DRGHW.

Any liquid wastes  generated during the cap construction would be treated in the GETS  so that
they meet that system's NPDES permit equivalence (which takes into account the Clean Water
Act, the Delaware Regulations  Governing the Control of Water, and the State of Delaware
Surface Water Quality Standards).  Construction and  other activities impacting stormwater  or
water quality  in the nearby wetlands would also comply with  these  regulations by utilizing
existing and constructing  new stormwater management features as needed.

Once constructed  and  stabilized,  the surface  cap  alternative would  reduce  the mobility  of
contaminated  surface  soils which  might otherwise migrate off site and impact  the wetlands
located on the east and west sides of the site.  This reduction in sediment discharge would meet
the requirements of the  EPA Protection of Wetlands Regulations.  Through  the use of, and
addition  to, existing sediment and  erosion controls, the wetlands would  also  be protected
during cap construction activities.
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Because  the  site is located  within  the  Delaware coastal zone,  all construction  and other
activities  would comply  with  Delaware's  coastal  zone  management  program.  Zoning
ordinances and restrictive covenants would  stipulate that the site may not be used for  heavy
industry in the future.

Construction of a surface cap to minimize  exposure to, and migration of, site contaminants
would  be consistent with the DRGSHW and RCRA landfill closure requirements,  as well as
the DRGHSC. Requiring that the surface cap have a permeability of less than 10~7 cm/sec and
incorporating the features of a RCRA Type  C Cap (depicted in the schematic shown in Figure
5.1) would ensure  compliance with these regulations.  The requirement to construct a liner
system, however, will not be met. Instead, any cap that is constructed will be tied into the soil
bentonite containment barrier that was installed as part of the IGR. This barrier is keyed into a
low permeability layer that lies between the contaminated soils of the Columbia Formation and
the underlying drinking water aquifer (the Potomac). This  method of construction will isolate
any contaminated OU-3 soils left under the  cap from surrounding uncontaminated areas. This
alternative will attain a standard of performance that is equivalent to the standard that would be
attained through the construction of a liner system. As a result, this  ARAR will be waived in
accordance with 40 CFR § 300.430(f)(l)(ii)(C)(4).

Under  Alternative 2A,  soil and soil gas contaminants would  remain in  OU-3 soils.    The
alternative would therefore fail to meet the PRGs that were  developed to meet the required 10~5
risk level required by the DRGHSC.  However, the surface cap would achieve the 10~5  risk
level eliminating the soil contact route of exposure and severely limiting the possible exposure
to contaminants in soil gas.

All liquid or solid waste generated during site activities would be categorized, handled,  and
disposed of in accordance with the  RCRA and DRGSHW requirements.  Depending  on the
method used to deal with soils excavated during the construction of the surface cap, several of
the RCRA and DRGSHW sections would be applicable to the selected remedy (as discussed in
Section 2.2).

None of the soil samples collected from the OU-3 areas had  PCB concentrations greater than
the 25  parts per million cleanup level specified for the "low occupancy areas".  The bulk of
these analyses were performed  using the EPA Method 8081  that is specified in  the TSCA
regulations. Data collected from the wetlands area suggest  that use of EPA Method 8081 may
underestimate the actual  presence of PCBs  in the  site soil. The available PCB data indicate
that containment through the use of a surface cap would meet the remedial  requirements listed
in TSCA as long as the facility is classified as a "low occupancy area" as  defined in 40 CFR
761.3.   The use of restrictive covenants to ensure this classification is  maintained and the
inclusion of deed notifications detailing the presence of PCB contamination on site would allow
a surface cap to meet the requirements of the TSCA detailed in Section 2.2.  Installation of a
surface cap would be compliant with the TSCA as long as  site soils  have PCB concentrations
of 100  mg/kg or less.
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To  meet the DSWA prohibitions on the disposal  of wastes from Superfund sites, demolition
debris and other wastes that require offsite disposal would be  shipped out of state to permitted
disposal or recycling facilities.

Because over 5,000 square feet of land would be  disturbed during the cap construction under
this  alternative,  the  substantive requirements  of the Delaware  Stormwater  and Sediment
regulations will be met.

To  comply  with the  Delaware  Air  Quality  Management  Regulations,  dust suppression
measures  would be utilized. Additionally, treatment (most likely  using carbon adsorption) and
permitting of emissions from the cap's soil gas collection system  would be necessary if it is
determined that more than 15 pounds of pollutants  would be emitted per day.

Any construction, modification, and abandonment  of monitoring wells,  extraction wells or
piezometers  would be  performed in accordance  with Delaware Regulations Governing the
Construction and Use  of Wells, as well as Delaware's statute regarding  Licensing of Water
Well  Contractors,  Pump Installer  Contractors,  Drillers,   Pump  Installers,  Septic   Tank
Installers, Liquid Waste Treatment Plant Operators and Liquid Waste  Haulers..

5.2.3.4    Long-Term Effectiveness and Permanence

The cap is expected to be effective  and reliable over  the  long term  if properly designed and
maintained.   Surface caps  can  be damaged by  such mechanisms as  erosion,  soil  settling,
maintenance activities,  and burrowing animals. Because  the contaminated soil would remain
onsite,  long-term monitoring,  maintenance,  and  control  would  be  required  under  this
alternative.  A review would be conducted at least  every 5  years to ensure that the remedy
continues  to provide adequate protection of human health and the  environment in accordance
with CERCLA 121(c).

Future construction activities and site use would be restricted to protect the integrity of the cap
through the use of ICs that  would remain in place over the long term. Because stormwater
would  continue  to infiltrate  through the  areas  to  the  north  of the  cap and could  raise
groundwater elevation  to  the  point that  groundwater  comes in contact with  the  residual
contamination,   this  alternative requires  that   the  GETS   or  some  other   groundwater
control/treatment system be operated for the foreseeable future.

5.2.3.5    Reduction of Toxicity, Mobility or Volume

This alternative would reduce the mobility of the contaminants through decreasing migration
via air blown soil particles, surface  runoff, seepage into groundwater, and escape of the soil
gases into the atmosphere. Toxicity and volume of the contaminated soil within the capped area
would  not  change  significantly  under  this  alternative,  with  the possible  exception  of
contaminants found in any soils  that are removed during the construction activities. These soils
would be  treated and disposed of if they can  not  be reintegrated into the  soils underlying the
capped area. Human and wildlife exposure to the toxicity would be  minimized as long  as the
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cap is  intact.  It is  estimated that 906,500 cubic yards of soil contaminated above the  PRGs
would  remain under the cap.

5.2.3.6   Short-Term Effectiveness

Construction of a surface cap would take approximately  4 to 8 months.  There is a substantial
risk that construction workers would be exposed to  the  contaminants  in surface soil and soil
gas during the associated grading and excavation activities. Some small increase in the risk to
the surrounding community  and  ecosystems  might  also occur  as  contaminated soils are
disturbed during excavation and construction activities. The potential for these short-term risks
would  be minimized through the use of dust control technologies such as water or foam sprays,
appropriate  training, fugitive emissions monitoring, and  use of personal protection equipment
for construction workers. Temporary decontamination pads would be required to minimize the
potential for the spread of contamination from excavation areas.

5.2.3.7   Implementability

A surface cap  can  be  constructed at the site using standard road construction equipment and
readily available materials  and labor. No  major  technical  difficulties are  anticipated in
implementing this alternative.  The security fence that surrounds the facility portion of the OU-
3 area would be left in place, although the northern end of the fence line might need to be
extended to  include the Northern Area.

Additional site preparation would be required for  cap  construction because of subsurface and
surface structures.  Care must be taken during construction activities  to avoid damaging the
previously installed containment barrier and other IGR components  (including piezometers,
monitoring  wells,  and extraction  wells).  The appropriate air emission approvals may  be
required prior to the start of work.

Long-term  administrative resources  would  be required  to ensure  enforcement  of the ICs,
maintenance of the cap, and conducting of the 5-year reviews. Implementation of additional
actions,  if required, could  be  complicated by the need  to preserve the cap.  Chemically and
physically intrusive activities conducted as part of further remedial actions might need to be
prohibited or conducted under more restrictive conditions.  Alternatively,  removal of portions
of the  cap  (with  subsequent  reinstallation/patching)  might  be necessary before  additional
intrusive remedial  actions  could be implemented.    Finally, construction  of a  multilayer,
concrete, or asphalt cap would limit future uses of the site.   In all  likelihood,  the previously
mentioned  "low occupancy"  restriction would eliminate  most commercial uses  of the site
although  storage  units,  warehousing  facilities,  and  other  similar operations  might  be
acceptable.

5.2.3.8   Cost

This section  presents  the  present worth analysis  for the  three  different  types of caps.
Uncertainties  that  could  impact the total cost of this  alternative  include:  the number and
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locations of subsurface obstructions that would require removal prior to installation of the cap;
the type of cap to be installed; the potential for damage to the  existing monitor wells and
extraction wells during construction; and the aforementioned  lack of data for the Northern
Area. Capital and O&M costs for the surface cap portion of this remedy would be impacted by
the type of cap selected.  As  a result, estimates are presented for each of the surface cap types
under consideration. The cost calculations for Alternative 2A are presented in Appendix C-l.
    •   The capital cost for Alternative 2A is estimated to  be
       0  Multilayer Cap                $17.5 Million
       0  Concrete Cap                  $17.2 Million
       0  Asphalt Cap                   $11.1 Million.
    •   The present worth O&M cost would be approximately
       0  Multilayer Cap                $949,000
       0  Concrete Cap                  $255,000
       0  Asphalt Cap                   $557,000.
    •   The total project cost (present worth) is estimated to be
       0  Multilayer Cap                $18.5 Million
       0  Concrete Cap                  $17.5 Million
       0  Asphalt Cap                   $11.6 Million.

5.2.4   Alternative 2B: Surface Cap with Soil Vapor Extraction

In this alternative, the surface cap in Alternative 2A would be supplemented with  an in-situ
SVE system, as described in Section 4.1.3.2. SVE wells would be placed at some or all of the
"hot spots" identified in Section 1.5.1.  The SVE system would be operated to treat VOCs
under the cap until the limitation of technology  is reached (i.e. the concentration of COCs in
the off gas remains very low). VOC extraction concentrations would be monitored weekly for
two months and monthly thereafter for two years or until no significant VOC removal is being
achieved.  After this time, the SVE wells would be sealed to provide for cap homogeneity. No
thermal enhancement/soil heating would be used  with the  SVE in this alternative.

Although the detailed design of the SVE system would be developed during the RD phase, it is
expected that the  SVE system  would consist of a series  of air extraction  and inlet wells
approximately 50 feet deep, connected to a vacuum extraction and treatment system through a
network of manifolds and  equipped with valves to  allow  flexibility of  operation.  The wells
would  likely be screened across the bottom  20 feet to facilitate movement of gas through the
soils.  Sample ports would be provided to allow monitoring of the extracted soil vapor as well
as in-situ conditions.

The SVE  system would likely include a programmable-logic based control system.  The area
for SVE implementation is anticipated to require the use of several hundred SVE wells, and
these wells  would be connected with main  headers to a central treatment area.  The control
system would actuate valves on main headers to allow extraction from one group of SVE wells
at time, thereby decreasing the size of process components and electrical power requirements.
This approach would  mimic 'pulsed' operation of the different remediation  areas, and is
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expected to achieve cleanup in a sufficient timeframe.

Because off gas from the SVE system would contain substantial levels of contamination, the
system may need to  comply  with the  substantive provisions  of the permit equivalence. In
accordance with the expected  requirements of this permit equivalence, off-gas  from the SVE
system would  need to be  treated before discharging it to the atmosphere.   Among the
technologies  that could  be  employed  to   achieve  treatment are  carbon adsorption  and
condensation.  Because the diversity of  contaminants would complicate  the management of
condensates, a vapor phase activated carbon adsorption system  with pretreatment for moisture
removal would most likely be  the best suited  treatment alternative. The spent carbon would be
regenerated (either on site or off site) for reuse or disposed of off site.

Based on the systems at other sites and the soil conditions at OU-3, radii of influence on the
order of  15-25  feet  are  expected.  Material,  radius  of  influence and  location  for the
injection/extraction wells will  be  finalized in the RD stage,  based on the results of the pilot
studies.  If in situ SVE is to be implemented  as a part of the final alternative, more extensive
sampling would be beneficial to further delineate the contaminated areas requiring treatment.

5.2.4.1    Overall Protection of Human Health and the Environment

This alternative provides overall protection of human health and the environment both through
minimizing contact with the contaminants and limiting contaminant mobility (surface cap) and
through removing some of the VOC contamination (SVE).  Total risks from the site would
decrease following the completion of the SVE treatment.

5.2.4.2    Compliance with ARARs

As  shown in Appendix B, Alternative 2B is expected to  comply with its relevant ARARs. In
addition to compliance with the ARARs  identified for the surface cap alternative (Alternative
2A), construction of  the SVE wells would  be  performed in accordance with  the Delaware
Regulations  Governing  the  Construction and Use of Wells,  as  well as Delaware's statute
regarding Licensing of Water Well Contractors, Pump Installer  Contractors,  Drillers,  Pump
Installers, Septic  Tank Installers,  Liquid Waste  Treatment Plant Operators and  Liquid Waste
Haulers.

Additionally, the  substantive  provisions of  permitting requirements  and off gas treatment
requirements would likely have to be met to achieve compliance with  federal and state air
quality regulations during  implementation of this alternative. These additional measures would
be required if more than 15 Ib/day of pollutants are generated by the SVE system. Monitoring
and sampling of the SVE system would be required to ensure compliance with the substantive
air permit requirements.

5.2.4.3    Long-term Effectiveness and Permanence

The SVE  portion of  this   alternative is  expected  to  decrease   permanently  the  VOC
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concentrations in soil and soil gas.  Decreased VOC concentrations would permanently reduce
the overall risk associated with the soil and soil gas beneath the cap. The cap portion of this
alternative would control residual risks by minimizing human and wildlife exposure to the OU-
3 soil and soil gas.  The decrease in VOC contaminant mass would also reduce permanently
the potential for the volatile COCs to migrate via  the  soil-to-air and soil-to-groundwater
pathways.

As described for Alternative 2A,  surface cap maintenance activities would  need to  continue
indefinitely. ICs would remain in place for protection of the GETS and the  surface cap.  The
operational  time  of the GETS might be shortened after implementation of this  alternative
because the SVE system would decrease the total mass of VOCs available for leaching from
the soil into the groundwater.  It is expected that the SVE system would operate for two years.
O&M activities would include maintaining and  repairing blowers, replacing activated carbon
(if used for off-gas treatment), and preventing fouling of the extraction wells.

5.2.4.4    Reduction of Toxicity, Mobility or Volume

The surface cap would reduce mobility of the contaminants through decreasing migration via
air-blown soil particles, surface runoff, seepage into groundwater; and escape of soil gases into
the atmosphere.  Operation of the  SVE system would  decrease  the  mass of  VOCs present at
OU-3.   The contamination would be transferred to the activated carbon.  Regeneration of the
activated carbon would result in contaminant destruction.  Pilot  studies  would be necessary to
better estimate the expected extent of VOC removal and remaining contaminant concentrations
at the site.

5.2.4.5    Short-Term Effectiveness

Short-term risks and mitigation measures related to the construction activities for the surface
cap would be the same as  described for Alternative 2A. Care would be taken to ensure that
additional  risks  resulting  from  the  construction  and  utilization  of  the  SVE  system  are
controlled. These measures would include monitoring of the treated vapor before it is released
into the atmosphere, as well as  proper treatment and  disposal of the spent  activated carbon,
condensates, or other concentrated wastes.

Surface cap and  SVE well construction,  including pilot study  activities, are expected to be
completed in approximately  1 to 2 years. Operation of SVE system is expected to  last two
years following system construction.

5.2.4.6    Implementability

Surface cap construction in Alternative 2B  would be somewhat complicated by the need to
allow for the SVE system extraction/injection wells.  However,  the  two  components  are
compatible and can be implemented with standard  construction  methods and equipment.  One
approach that would improve the constructability of the cap would be to  install the SVE system
first using manifolds to connect the SVE wells to horizontal conveyance piping laid in trenches
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installed into the pre-cap ground surface.   After the trenches are filled in  and compacted, the
cap can  be  constructed with the SVE system in  place.  This approach would eliminate the
drawbacks related to having  hundreds of wells penetrating the surface  cap and  potentially
providing pathways  for volatile compounds  to migrate to the  air  and  for precipitation to
infiltrate. If greater air flux is required to achieve effective  treatment in certain portions of the
site, additional inlet  wells could be  installed through the cap.  After the SVE system  is shut
down,  these wells  would have to be  abandoned in  accordance with DNREC requirements, and
the cap repaired in the areas of penetration.

The corrosive nature of the soils and groundwater  (from probable releases of hydrochloric acid
at the SCD facility and the sulfuric acid spill that occurred at the former Motiva refinery) could
cause operational problems  for  the  SVE system if carbon  steel is used for well casings and
screens.   Incompatibilities between  the many of the  COCs and plastics such as high density
polyethylene (HDPE)  might dictate the use  of stainless steel for  casing and screen. Final
material  selection  will  be made as part  of the  RD process,  but pilot testing  and material
compatibility would help determine  whether the wells and conveyance piping can be made of
low-cost HDPE or if stainless steel or carbon steel  must be used.

Technical feasibility of this treatment technology for the on-facility area at the SCD site is
improved by the lowered water  table and sandy soils. SVE technology has been identified by
USEPA  as a presumptive remedy for sites with  soils  contaminated by VOCs  (EPA,  1993).
Collection of confirmatory samples  of SVE performance would be complicated if the surface
cap is  installed prior to the  completion of SVE system operation, but the  cap would increase
the effectiveness of the SVE system by reducing the potential for short circuiting.

5.2.4.7    Cost

The cost estimate  for the cap portion of this  alternative is  affected  by the same uncertainties
identified for Alternative 2A.  Because of the relatively short  system lifespan  (approximately
two years) and the expected dilution of vapor concentrations in the SVE system, HDPE piping
was assumed for development of this cost estimate.  If it is determined during pilot testing or
material  compatibility testing that stainless steel casing and screen would be required, the costs
associated with the construction of the SVE system would be substantially  higher.  Another
uncertainty in the SVE cost  estimate is radius of influence that would be achieved by the SVE
wells.  This cost estimate was based on an assumed radius of influence of 18  feet.  Electrical
costs were calculated based on  a rate of $0.12/kilowatt-hour.  The cost  calculations for the
SVE portion of Alternative 2B are presented in Appendix C-2.
    •   The capital cost for Alternative 2B is estimated to be
       0  Multilayer Cap                 $24.3 Million
       0  Concrete Cap                  $24.0 Million
       0  Asphalt Cap                    $17.8 Million.
    •   The present worth of O&M costs would be  approximately
       0  Multilayer Cap                 $1,855,000
       0  Concrete Cap                  $1,161,000
       0  Asphalt Cap                    $1,336,000.
                                     U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report               5-14                           HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

    •   The total project cost (present worth) is estimated to be
       0  Multilayer Cap                 $26.2 Million
       0  Concrete Cap                  $25.2 Million
       0  Asphalt Cap                   $19.1 Million.

5.2.5   Alternative 2C: Surface Cap with In Situ Thermal Desorption

5.2.5.1    Description

Alternative 2C includes  all the  elements  of Alternative 2B (Surface Cap and SVE) with the
main difference being that the "hot  spot" soils would be heated to facilitate volatilization and
removal of SVOCs, PCBs, and dioxins. Alternative 2C includes the following components:
    •   Further sampling to delineate contamination;
    •   ISTD of "hot spot" areas more  than 10 feet away from the containment barrier;
    •   Unenhanced SVE for areas within  10 feet of the containment barrier;
    •   Treatment of collected soil vapor as presented in Alternative 2B;
    •   ICs as described in Section 4.1.3;
    •   Confirmatory sampling during and following operation of the ISTD system;
    •   Construction of Surface Cap as  presented in Alternative 2A.

Based on discussions with ISTD  vendors,  it is estimated that ISTD heaters and vapor extraction
wells  would be placed between 8  and 12 ft  apart over  the 330,000 square feet  area  that
comprises the "hot spots" in the site. Based on heater spacing and the area being addressed, it
is projected that a total of 2,800 heaters and 1,400 extraction wells would be installed on site.
In the event  that the Northern Area is determined to  be a "hot spot" in need of treatment in
addition to capping,  approximately 500 additional heaters  and 250 additional extraction wells
would be installed to address the 60,000 square feet area.

The heaters and extraction wells would extend through the  50 ft vadose zone to heat the soil to
temperatures close to or above the boiling points of the soil contaminants.  It is expected that
temperatures in excess of 570 to 650°F would be required to facilitate volatilization of most of
OU-3 organic  COCs.   These  temperatures should  be achieved using the  aforementioned
spacing. The volatilized organics would  then be extracted through an SVE system similar to
that described in Alternative 2B.

Soil heating for ISTD can be achieved  by  several methods,  including hot air or steam injection,
radio-frequency heating,  electrical resistance heating, and thermal  conduction heating.  The
method  to be used at OU-3, as well as  the actual well and heater spacing, would be determined
during  the RD stage  based on site-specific data including soil  bulk density,  soil moisture
content, VOC distribution, implementation costs, and results from pilot studies.

The ISTD system in Alternative 2C  would differ from the SVE system in Alternative 2B  in a
number of  ways. Extraction and  heater  wells  for the  ISTD  system  would  need  to  be
constructed from heat-resistant material (likely stainless steel).  Because of the number of wells
that would penetrate any cap and the difficulties that would be encountered if construction of a
                                     U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report               5-15                            HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

cap were attempted with the wells already in place, it is expected that the surface cap would
not be installed until the ISTD process is complete and the well casings have been removed.

5.2.5.2    Overall Protection of Human Health and the Environment

The ISTD  system would substantially reduce the concentrations of organic  soil and  soil gas
contaminants in the areas identified  as  "hot spots" on the facility portion of the site, and, if
necessary,  the  Northern Area.   By  reducing organic  COC  concentrations  of the  most
contaminated areas, contaminant migration and potential risks from chemical exposures would
be  decreased.   The risks associated with the  residual COCs would be addressed  through
completion of the surface cap that would prevent exposure by human and ecological receptors.
Additionally, the cap would minimize precipitation infiltration, and  in doing so substantially
limit the potential for contamination to be spread via the  soil to groundwater pathway.  The
soil to sediment migration pathway  would be eliminated because the cap would prevent the
contact of stormwater run off with site contaminants.  The use of an integrated soil gas capture
and treatment system would minimize the potential risks related to soil gas  and contaminant
migration via the soil to air pathway. Finally, ICs would further limit the potential future  risks
from vapor intrusion and soil contact by requiring that countermeasures be incorporated into
any building that is built on affected portions of the site  and establishing restrictions on future
construction activities.

5.2.5.3    Compliance with ARARs

Alternative 2C is expected to comply with the relevant ARARs. In addition to compliance with
the ARARs identified for the surface cap alternative (Alternative 2A), and the surface cap with
SVE alternative (Alternative 2B), the surface cap with ISTD approach is expected to comply
with the following regulations and requirements.

As stated in Alternative 2A, cap construction, maintenance, and closure would follow RCRA
requirements for a Type C Landfill cap, except that a liner system will not be constructed.

Because the heating of soils in the  "hot  spot" areas would increase the volatilization of the site
contaminants,   it  is  likely  that  compliance   with  the  substantive  provisions  of  permit
requirements and off gas treatment would be required. Treatment of the off gas in accordance
with the relevant air regulations would be achieved through the use of carbon adsorption or an
oxidizer.

5.2.5.4    Long-term Effectiveness and Permanence

ISTD is expected to remove sufficient quantities  of organic contaminants from soil and soil gas
to lower the concentrations  of these contaminants below their respective PRGs in the  "hot
spot" portions of the facility. This contaminant  removal  would result in a permanent reduction
in risk to human and ecological receptors, and a permanent reduction in the  total contaminant
mass available for migration via the  soil-to-air,  soil-to-groundwater, and surface water run off
pathways.  Organic contaminants  in other  portions  of OU-3  and  inorganic  contaminants
                                     U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report               5-16                            HydroGeoLogic, Inc. July 2009

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HGL— Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware

throughout OU-3 would  be unaffected by the ISTD  system.   To ensure that the surface cap
effectively  prevents   exposure  to  this  residual  contamination,   long-term  monitoring,
maintenance,  and control would  be required under this  alternative. If properly designed,
constructed, and maintained, the surface cap would provide an effective long-term remedy. A
review would be  conducted  at least every  5 years to ensure that the  remedy continues to
provide adequate protection of human health and the environment in accordance with CERCLA
5.2.5.5    Reduction of Toxicity, Mobility or Volume

As with Alternatives 2A and 2B, the surface cap would reduce the mobility of the contaminants
via air-blown soil particles, surface runoff, seepage into groundwater, or escape of soil gases
into  the  atmosphere. A higher degree  of reduction  in  contaminant toxicity,  mobility  and
volume is expected  from this alternative as  compared to Alternative 2A and 2B due to the
increased COC removal associated with  ISTD. The ISTD system would permanently remove
VOCs, SVOCs, PAHs,  PCBs, and dioxins from the soils and, in the  case of VOCs and some
SVOCs,  soil gas.  The compounds captured  by the gas collection system would be destroyed
either  within the oxidizer or through regeneration  of the spent carbon,  depending  on the
treatment approach  selected for  the off-gas.  The COCs  likely to  remain after treatment
(including inorganics) are expected to be non-volatile and relatively immobile.

5.2.5.6    Short-term effectiveness

Short-term risks and mitigation measures related to the construction  activities for the surface
cap would be the same as described for Alternative 2A.  The potential short-term risks during
ISTD implementation are similar to those described for SVE.  These  risks would be mitigated
through control  of emissions from the off-gas treatment unit, air monitoring, use of PPE by
workers, and  implementation  of engineering controls.   Treatment of the "hot spots"  is
expected to take less than one year to complete.  Construction of the surface cap is expected to
require 4 to  8 months.

5.2.5.7    Implementability

ISTD technology is fully developed and has been applied at Superfund sites.  Steam heating of
the contaminated soils would not  provide the temperatures necessary to volatilize the COCs
from the identified "hot spots".   As a result it  is more likely that  some form of electrical
heating would be required.  Electricity and water for soil heating  and  treatment is available on
site although a higher wattage electrical supply would  likely be required.  Natural gas (which
might be needed for the ISTD) would be  available from a main that runs along Governor Lea
Road.

While an SVE system could be integrated under the  surface cap by connecting  the vertical
extraction wells  to horizontal conveyance piping that channel the extracted vapors to an off gas
treatment system, it  would not be  practical to route all of the wiring  for approximately 4,200
heating elements under the cap. Attempting to install the ISTD system after construction of the
                                     U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report              5-17                           HydroGeoLogic, Inc. July 2009

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

cap would severely reduce the effectiveness of the cap.  Additionally, the heating of the ISTD
could damage the surface cap if operated after the cap's construction. Consequently, although
the timing and sequencing of the remedy will be finalized during the RD, it is expected that
ISTD would occur following the removal of the demolition debris but before the construction
of the surface cap.

Materials used in the construction  of the ISTD system must be able  to withstand the  heat
generated  by the system.    Consequently,  neither PVC  nor  HOPE  can  be  used  in  the
construction of the  ISTD  wells.    Furthermore,  the  corrosive nature of the  soils  and
groundwater (from probable releases of hydrochloric acid at the SCO facility and the sulfuric
acid spill that occurred at the former Motiva refinery) could also result in operational problems
for the ISTD system unless proper materials are selected.  Well casings and heating elements
would likely be made of stainless steel, although final material selection will be performed as
part of the RD process.

Pilot studies will be necessary to optimize well placement and gain a better  understanding of
the extent of contaminant removal that can be  expected.  Additional characterization sampling
would be helpful to further delineate those areas that would benefit most from the application
of ISTD  before the installation of a surface cap.

5.2.5.8     Cost

Because  ISTD  treatment should be completed  within the first year,  costs related to the ISTD
system's O&M and removal have been included in the capital costs for this alternative. Capital
and  O&M costs for the surface cap should be  equal  to those observed in Alternatives 2A.  In
addition  to the cost uncertainties identified for Alternative 2A, issues that could impact the  total
cost of this alternative include potential increases in  electrical  costs, and the material required
for the well casings and heating elements.  Electrical costs were calculated using a rate of
$0.12/kilowatt-hour.  The cost calculations for Alternative 2C are presented in Appendix C-3.
    •  The capital cost for Alternative 2C is estimated to be
       0    Multilayer Cap                $98.8 Million
       0    Concrete Cap                  $98.3 Million
       0    Asphalt Cap                     $92.4 Million.
    •  The present worth O&M cost would be  approximately
       0    Multilayer Cap                $949,000
       0    Concrete Cap                  $255,000
       0    Asphalt Cap                    $557,000.
    •  The total project cost (present worth) is estimated to be
       0    Multilayer Cap                $99.8 Million
       0    Concrete Cap                  $98.6 Million
       0    Asphalt Cap                     $92.8 Million.
                                     U.S. EPA Region 3
Standard Chlorine of Delaware Site Feasibility Study Report               5-18                            HydroGeoLogic, Inc. July 2009

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TABLE

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                                                                Table 5.1
                                           Individual Evaluation of Remedial Alternatives
                                         for Standard Chlorine of Delaware Operable Unit 3
                                                               Page 1 of 7
          Criteria
    1. OVERALL PROTECTIVENESS
Human Health Protection
Soil: direct contact/inhalation/
ingestion
No significant
reduction in
risk.
Contamination
would remain
above the target
risk levels.
Cap would reduce risk from contact,
inhalation and digestion of soil to below
target risk level
See Alternative 2A;
SVE would reduce VOCs
and some SVOCs in vadose
zone soils in "hot spot"
areas reducing risks for
future construction workers
See Alternative 2A;
ISTD would reduce or
eliminate organic
contaminants from vadose
zone soils in "hot spot" areas
reducing risks for future
construction workers
Soil gas inhalation
No significant
reduction in
risk.
Contamination
would remain
above the target
risk levels.
Cap equipped with a gas collection system
would reduce risk from soil gas to below
target risk level
See Alternative 2A;
SVE would reduce VOCs
and SVOCs in "hot spot"
area soil gas
See Alternative 2A;
ISTD would reduce organic
contaminants in "hot spot"
area soil gas
Contact with contaminated
surface or ground water
No significant
reduction in
risk.
Contamination
would remain
above the target
risk levels.
Cap would eliminate stormwater contact
with contaminated soil and minimize
precipitation infiltration thereby reducing
health risks
See Alternative 2A;
SVE would reduce or
eliminate VOCs from
vadose zone soils in "hot
spot" areas reducing
potential spread of
contaminants to
groundwater	
See Alternative 2A;
ISTD would reduce or
eliminate organic
contaminants from vadose
zone soils in "hot spot" areas
reducing potential spread of
contaminants to groundwater
Environmental Protection
No significant
reduction in
risk.
Contamination
would remain
above the target
risk levels.
Surface cap would reduce risk from
contact, inhalation and digestion of soil and
soil gas to below target risk levels by
preventing or minimizing exposure.
See Alternative 2A
Same as Alternative 2A

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                                                                Table 5.1
                                           Individual Evaluation of Remedial Alternatives
                                         for Standard Chlorine of Delaware Operable Unit 3
                                                               Page 2 of 7
    2. COMPLIANCE WITH ARARs
Does Alternative Comply with
ARARs?
Does not meet
ARARs for soil
and soil gas
Construction of a surface cap to minimize
exposure to, and migration of, site
contaminants would be consistent with the
DRGSHW and RCRA landfill closure
requirements, as well as the DRGHSC.
Requiring that the surface cap have a
permeability of less than 107 cm/sec and
incorporating  the features of a RCRA Type
C Cap would ensure compliance with these
regulations. The requirement to construct a
liner system, however, will not be met.
Instead,  any cap that is constructed will be
tied into the soil bentonite containment
barrier that was installed as part of the
IGR. This barrier is keyed into a low
permeability layer that lies between the
contaminated soils of the Columbia
Formation and the underlying drinking
water aquifer  (the Potomac). This method
of construction will isolate any
contaminated OU-3 soils left under the cap
from surrounding uncontaminated areas.
This alternative will attain a standard of
performance that is  equivalent to the
standard that would be attained through the
construction of a liner system. As  a result,
this ARAR will be waived in accordance
with 40  CFR § 300.430(f)(l)(ii)(c)(4).
Otherwise, the Alternative is expected to
comply with the all identified ARARs	
See Alternative 2A
See Alternative 2A

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                                                                Table 5.1
                                           Individual Evaluation of Remedial Alternatives
                                        for Standard Chlorine of Delaware Operable Unit 3
                                                               Page 3 of 7
    3. LONG-TERM EFFECTIVENESS AND PERMANENCE
Magnitude of residual risk;
adequacy and reliability of
controls; need of 5-year review
Existing risk
would remain.
Contaminants
would continue
to migrate to
the surface
water, infiltrate
into deeper soil
and
groundwater,
and be
transported via
airborne soil
particles.	
Risks from direct contact, soil ingestion,
and soil gas inhalation would be reduced/
eliminated as long as cap integrity is
maintained.
Surface cap would prevent precipitation
infiltration,  reduce the potential for further
groundwater contamination and would
reduce  volume of groundwater requiring
treatment by GETS.
See Alternative 2A.
Removal of VOCs from
some areas by SVE would
reduce contamination
remaining under the cap.
Metals and most organic
contamination would
remain.
See Alternative 2A.
Removal of organics from
some areas by ISTD would
reduce contamination
remaining under the cap.
Metals contamination would
remain;  VOCs, SVOCs,
dioxin, pesticide, and PCB
contamination would remain
in some  areas.
Magnitude of residual risk;
adequacy and reliability of
controls; need of 5-year review
(continued)
Five year
reviews
required
indefinitely.
Contaminants would not be removed
except through soil gas collection system.
Five year reviews, cap maintenance,
institutional controls and GETS operation
would be required indefinitely.
Five year reviews, cap
maintenance, institutional
controls would be required
indefinitely.
Some form of groundwater
extraction and treatment
would be required
indefinitely,
GETS operational costs
might be reduced by
removing a portion of
VOCs and SVOCs from
soils and through reduction
in GETS treatment volume.
Five year reviews, cap
maintenance, and institutional
controls would be required
indefinitely.
GETS operational costs might
be reduced by removing a
portion of VOCs, SVOCs,
pesticides, and PCBs from
soils and through reduction in
GETS treatment volume.

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                   Table 5.1
  Individual Evaluation of Remedial Alternatives
for Standard Chlorine of Delaware Operable Unit 3
                  Page 4 of 7





4. REDUCTION OF CONTAMINANT MOBILITY, TOXICITY, OR VOLUME
Reduction of toxicity, mobility
or volume
Irreversible treatment
Type and quantity of residuals
remaining after treatment.
Statutory preference for
treatment
None
None
Original
contamination
remains.
Does not satisfy
Mobility of contaminants under capped
area would be controlled;
Toxicity and volume of contamination
under the cap would remain the same with
the exception of minimal soil gas
contaminant reduction.
Minimal soil gas contaminant removal
through gas collection system
Most of the original contamination would
remain under the cap;
Minimal soil gas contaminant removal
through gas collection system
Does not satisfy
Mobility of the
contaminants under the cap
would be controlled as in
Alternative 2A.
Removal of VOCs from
some areas reduces
contamination toxicity and
volume under the cap.
Organic contaminants are
irreversibly removed from
soils and soil gas in "hot
spot" areas.
SVOCs, PCBs/dioxins, and
metals remain in soil under
cap; VOCs from
contaminated groundwater
in soil gas; Carbon from
SVE vapor treatment
requires regeneration or
disposal.
Satisfies
Mobility of the contaminants
under the cap would be
controlled as in Alternative
2A.
Total toxicity and volume of
contamination under cap is
reduced.
Organic contaminants are
irreversibly removed from
soils and soil gas in "hot
spot" areas.
Metals contamination
remains; SVOCs,
PCBs/dioxins, and metals
remain in soil near the soil
bentonite barrier; Carbon
from vapor treatment requires
regeneration or disposal.
Satisfies

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                   Table 5.1
  Individual Evaluation of Remedial Alternatives
for Standard Chlorine of Delaware Operable Unit 3
                  Page 5 of 7





5. SHORT-TERM EFFECTIVENESS
Community Protection
Worker Protection
Environmental Impacts
Time Until Action is Completed
Continued
impact from
existing
conditions
No significant
risk to workers.
Continued
impact from
existing
conditions.
Not applicable
Temporary increase in contaminated dust
production and VOC escape would be
expected during cap construction; Dust and
vapor suppression measures would be
employed.
PPE required for protection from dust and
vapor during construction.
Wildlife exposure would remain at current
level of contamination during cap
construction;
Stormwater controls, dust and vapor
controls, and contamination pads could be
used to prevent spread of contamination
from the cap construction area;
Approximately 6 months to complete cap
(depending on cap type) .
Dust and vapor controls as
in Alternative 2A;
Incorporating SVE wells
into cap design would result
in longer exposure to
contamination during
construction.
PPE required for protection
from dust and vapor during
construction and SVE
operation.
See Alternative 2A
6-9 months to complete cap
and SVE system
construction;
2-3 years to complete SVE
Dust and vapor controls as in
Alternative 2A; Duration of
potential exposure during
construction and ISTD
treatment would be
approximately two to three
years); Contaminants would
be mobilized into soil vapor
as the soil is heated by ISTD.
Additional controls would be
employed to ensure the
contaminated soil vapor is
captured
PPE required for protection
from dust and vapor during
construction and ISTD
operation.
See Alternative 2A
2 to 3 years to complete
ISTD;
Approximately 6 months to
complete cap following ISTD.

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                                                                 Table 5.1
                                            Individual Evaluation of Remedial Alternatives
                                         for Standard Chlorine of Delaware Operable Unit 3
                                                                Page 6 of 7
    6. IMPLEMENTABILITY
Ability to obtain approvals and
coordinate with other agencies
Not applicable
Coordination would be required with
DNREC to determine compliance with
ARARs;
Compliance with the substantive
requirements of the well permitting
program would be required.
Qualified personnel and appropriate
coordination with other agencies  would be
required for construction activities.	
See Alternative 2A.
Additionally, air permit
equivalence and sampling
would likely be required for
SVE discharge.
Appropriate coordination
with State well permitting
office would be required
for hundreds of SVE wells.
See Alternative 2A.
Additionally, air permit
equivalence and sampling
would likely be required for
ISTD discharge.
Appropriate coordination with
State well permitting office
would be required for
thousands of ISTD wells.
Implementability at the site
Not applicable
Surface cap can be easily constructed at the
site; Care would be needed so as not to
damage IGR features and to tie the surface
cap to the soil bentonite walls; Substantial
demolition of surface and subsurface
structures and debris removal/disposal
would be required; GETS building potable
water line would have to be rerouted
around capped area.	
See Alternative 2A.
SVE can be implemented at
the site; Pilot testing
required for SVE; SVE
piping could be installed
under the cap and used as
passive soil vapor capture
system after SVE is
completed.	
See Alternative 2A.
ISTD can be implemented at
the site; ISTD would be
completed before cap is
constructed; Pilot testing
required for ISTD
ISTD piping and soil heating
elements would be removed
upon ISTD completion.	
Availability of services and
capacities
Not applicable
Required services are readily available
Required services are
readily available
Required services are readily
available; Higher voltage
electrical supply and natural
gas supply would need to be
brought onto site.	

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                        Table 5.1
   Individual Evaluation of Remedial Alternatives
for Standard Chlorine of Delaware Operable Unit 3
                       Page 7 of 7
Criteria
Availability of equipment,
specialists, and materials
Availability of technologies
Alternative 1:
No Action
Not applicable
Not applicable
Alternative 2A : Surface Cap
Standard construction equipment and
materials are required.
Cap technology is readily available and
widely used.
Alternative 2B: Surface
Cap with Soil Vapor
Extraction
Equipment, specialists and
materials needed for cap
construction and SVE
construction and operation
are readily available from
local vendors.
Cap and SVE technologies
are readily available and
widely used.
Alternative 2C: Surface Cap
with In Situ Thermal
Desorption
Equipment, specialists and
materials needed for cap
construction and ISTD
construction and operation are
readily available from local
vendors.
Cap and ISTD technologies
are readily available and have
been used for remediation
sites.
7. COST
Capital Cost
Present Worth of O&M Cost
Alternative Present Worth Cost
$0
$0
$0
$11.1 to $17. 5 Million
$255,000 to $949,000
$11.6to$18.5Million(1)
$17.8 to $24.3 Million
$1,161,000 to $1,855,000
$19.1 to $26.2 Million
(i)
$92.4 to $98.8 Million
$255,000 to $949,000
$92.8 to $99.8 Million(1)
(1) - The lowest O&M cost for a cap would be for the concrete cap, but the lowest capital cost for a cap is for an asphalt cap.
    listed O&M Cost do not equal the Alternative Present Worth Cost.
                                                      a result, the sum of the lowest listed capital cost and the lowest

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FIGURES

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                             HGL— Feasibility Study Report, Standard Chlorine of Delaware Site—

                                                New Castle County, Delaware
                                                      Gas vent
      Drain layer -


Membrane



       Vent layer -
                                                                                           -  Top layer
_  Low permeability
   geomembrane/soil layer
                                                                                            Waste
Filename: S:\EPA 010'fROJECTS - WORK ASSIGNMENTS\002
Standard Chlorine RIFS\FS Files\FS Report\Figures\
Figure 5-1. doc
Revised: 06/02/08 CW
Project: El 0002. 12.01
Source:
v HGL

Source:
Figure A-ll. USEPA 1998.
"Evaluation of Subsurface
Engineered Barriers at Waste Sites. "
EPA-542-R-98-005. August 1998
Figure 5.1
Typical Multilayer Cap Design
Schematic
Standard Chlorine of Delaware

              SCO FS Report
                                                  U.S. EPA Region 3
                                                                                        HydioGeoLogic, Inc. 5/15/09

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                                 HGL—Feasibility Study Report, Standard Chlorine of Delaware Site—
                                                New Castle County, Delaware
                                                                                  3" Asphalt Binding Layer
           9" Concrete Layer
                                                  9" Crushed Stone
                                                  Base Layer
                                             —I  30 mm Low
                                             -**  Permeability Layer
                                                 V Sand Vent Layer
                                                                                6" Asphalt Base Layer
          Concrete Surface Cap
Asphalt Surface Cap
                                                                                                 Figure 5.2

                                                                                   Typical Asphalt and Concrete Cap Schematic
                                                                                         Standard Chlorine of Delaware
                                                                                         New Castle County, Delaware
SCO FS Report
                                                    U.S. EPA Region 3
                                                                                                        HydroGeoLogic, Inc. 5/15/09

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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                       Delaware
6.0    COMPARATIVE ANALYSIS OF ALTERNATIVES

In this Section,  remedial  alternatives are compared to  each other  based  on the evaluation
criteria presented in Section 5.1.

6.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

Alternatives 2A, 2B, and 2C would all reduce human health and ecological risks from soil and
soil gas to the levels specified in Section 2 of this FS Report by  containing, and preventing
contact with, contamination through the use of a surface cap which would be tied into the soil
bentonite containment barrier that was constructed as part of the IGR.  Alternative 2C  would
improve on the level of human health protection (specifically the health of future construction
workers or others  performing intrusive site work)  afforded by the surface cap by removing
almost all organic contamination from vadose zone soils  in the "hot  spot" areas.  Alternative
2B would also provide some measure of added protection,  but would only remove VOCs and
some  SVOCs from vadose  zone "hot spot" soils. Alternative 1A  (No Action)  would not
provide protection of the environment or human health.

6.2 COMPLIANCE WITH ARARS

Alternative 1A (No Action) would not meet the ARARs that were identified in Section 2.2.
Alternatives 2A, 2B, and 2C  would meet all ARARs, with the exception that the requirement
to construct a liner system  will be waived. Instead, any cap that is constructed will be tied into
the soil bentonite containment barrier that was installed as part of  the IGR. This barrier  is
keyed into a low permeability layer that lies between the contaminated soils of the Columbia
Formation and  the  underlying  drinking water  aquifer  (the  Potomac).  This  method of
construction will isolate any  contaminated  OU-3 soils left under  the cap  from surrounding
uncontaminated areas. This alternative will  therefore attain a standard of performance  that  is
equivalent to the standard that would be attained through the construction of a liner system. As
a result,  this ARAR will  be waived in accordance with 40  CFR § 300.430(f)(l)(ii)(C)(4).
Alternatives 2A, 2B, and 2C can all be designed and implemented to comply with the all of the
remaining identified ARARs. Although none  of these alternatives  would reduce organic and
inorganic contaminant concentrations  throughout OU-3 soil  or soil gas to the PRGs established
in Section 2.3, the installation of a surface cap would eliminate the exposure  pathways and
thereby manage the potential risks effectively when combined with appropriate ICs.

6.3 LONG-TERM EFFECTIVENESS AND PERMANENCE

Alternative 2A would provide effective containment of all contaminants located in the soil and
soil gas of OU-3. This would substantially reduce the risks related to, and the potential  spread
of,  site contaminants.   To  remain  effective over the  long  term, maintenance activities,
including management of vegetation and burrowing  animals and repairs of crack and erosional
features, would be required into perpetuity.

Alternatives 2B (SVE plus surface cap) and 2C (ISTD plus  surface  cap) would improve  on the
                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware

effectiveness of Alternative 2A by  reducing or eliminating organic contaminants in the vadose
zone of the previously identified "hot spot" areas.  Because  SVE would only address VOCs
and ISTD would reduce or eliminate all of the organic contaminants  in vadose  zone  soils in
these areas, Alternative 2C would  be the most effective over  the long term.  Confirmation of
the effectiveness of the SVE and  ISTD treatment systems would most likely  be checked by
collecting and analyzing  vapor samples to determine  whether the  concentrations  in the
extracted  vapor have  leveled off or  been  reduced  to acceptable levels.    The  identified
concentrations would then be compared to the soil gas PRGs.   In the case of the  ISTD, which
will most likely be  operated  prior  to the construction of the  cap, soil samples could  also be
collected and  analyzed to determine whether the treatment  has reduced  contaminant levels
below those of the soil PRGs. As with Alternative 2A, perpetual maintenance will be required
to ensure the continued effectiveness of Alternatives 2B and 2C.

Alternative 1A (No Action) would  not reduce the risks from, or the potential migration of, site
contaminants.  As a result, Alternative 1A will not be effective over the long term.

6.4 REDUCTION OF TOXICITY, MOBILITY OR VOLUME

Alternatives 2A, 2B, and 2C will all reduce the mobility of the contaminants through the use of
a surface  cap  to reduce infiltration (eliminating the soil to groundwater pathway),  eliminate
contact of contaminated materials with stormwater (eliminating the soil to sediment pathway),
and containing soil gas (eliminating the soil to ambient air pathway).  Alternatives 2B  and 2C
also  include treatment technologies (SVE and ISTD,  respectively)  that would reduce the
volume and toxicity of OU-3 contaminants.  The greatest reduction of contaminant toxicity and
volume  is expected from  Alternative 2C (combination  of the surface cap and  ISTD),  as  it
would remove VOCs,  SVOCs, PCBs,  and dioxins from vadose  zone soils in the "hot spot"
areas. Alternative 2B (surface cap  with SVE) would remove VOCs and some SVOCs from the
"hot  spot"  areas  but would  not  address  dioxins,  pesticides,  and  other  less  volatile
contaminants.  Alternative 2A (surface cap alone) would not reduce the toxicity or volume of
the OU-3 contaminants.

Alternative  1A (No Action) would not reduce  the toxicity, mobility or volume  of OU-3
contaminants.

6.5 SHORT-TERM EFFECTIVENESS

Alternative  1A (no action) would have the highest short-term effectiveness (lowest short-term
risk) because no disturbance  of OU-3 soils would occur  with this alternative,  minimizing the
potential for release of contaminants.

Short-term risks to  construction  workers, surrounding  communities and the environment are
expected to occur from the  implementation of Alternatives  2A,  2B, and  2C.  These  risks
include exposure to dust and vapor  during cap construction activities, as well as continued risks
from the current site conditions before the alternatives are fully implemented. Alternatives 2B
and 2C would be somewhat less effective than Alternative 2A in the short term because of the
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

increased site activities (well construction, trenching, wiring and piping installation) required
to construct  the SVE  and ISTD systems. Additionally,  the SVE and ISTD  systems would
increase  the mobility of organic contaminants over the short term.  Short term risks associated
with Alternatives 2A, 2B, and  2C can be managed by a combination of institutional controls,
PPE, and vapor and dust suppression measures to be employed during construction activities.
Vapor capture and  treatment  systems  would  address any increase in  the  off-gassing  of
contaminants under Alternatives 2B and 2C.

6.6 EMPLEMENTABILITY

Alternative 1A requires no action and is therefore the most easily implemented.

Of the remaining  alternatives,  construction of a surface cap by itself would  be most easily
implemented. Although  the potable water line  to the treatment building would need to  be
rerouted  so  it does not pass  under  the  cap,  this  could be  accomplished  using  standard
construction  equipment,  materials,  and methods.  Care would  also have to be taken to avoid
damage  to  the  existing  GETS, piezometers,  and monitoring  wells,  but the overall cap
construction could similarly be  performed using standard construction equipment and methods.
Additionally, no further delineation (aside from possibly in the Northern Area)  or pilot studies
would be needed  before construction of a surface cap covering all  of OU-3.  Activities  to
maintain the  surface cap would  be similar under Alternatives 2A, 2B, and 2C. These activities
would be partially dependent upon  the type of cap selected, but they would generally include
vegetation and  burrowing  animal  control,  repair of  cracks  and  erosional  features,  and
monitoring of site conditions.

The   proposed   treatment   technologies  (SVE   and   ISTD)  would   require   additional
characterization sampling to further delineate the "hot spot areas" and the Northern Area,  as
well as pilot studies to optimize well placement, blower and pipe sizing,  and, in the case  of
ISTD, determination of temperatures that  will be required to achieve treatment of the OU-3
contaminants. The time  required to construct Alternatives 2B  and 2C would also be greater
than that needed to complete the surface cap alone.  The SVE and ISTD  systems would also
require compliance  with the  substantive  provisions  of permit  requirements to  cover the
installation of hundreds to  thousands of wells and  compliance with substantive  air permit
requirements to cover  the off-gas discharge, whereas Alternative 2A  would only require the
installation of a small number of monitoring wells.  Alternative 2A might also require that the
off-gas from the  soil  gas  capture  system  comply with  substantive air discharge  permit
requirements. While SVE could be implemented using the utilities already available on site, it
is likely  that a higher voltage electrical supply and  a natural gas supply will need to be routed
to the site if ISTD is selected as part of the  site remedy.

6.7 COST

Alternative 1A requires no action and would therefore incur no costs.

Alternative 2A would  be the least  expensive of the remaining alternatives, with an expected
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                         Delaware

present value (taken over 30 years at a discount  rate of 5%)  of between  $11.6 and $18.5
million, depending on the type of cap selected.  An asphalt cap would be the least expensive to
install  ($11.5 million), followed by  a concrete  cap ($17.5 million)  and the  multilayer cap
($18.5  million).

Adding an SVE system to the surface cap (Alternative 2B) to address VOC contamination in
"hot spots" would cost (from a 30 year present  value perspective) an estimated $7.7 million
more to implement and  maintain than using a surface cap by  itself (Alternative 2A).   It is
expected that, by installing the SVE system first and using trenches to route conveyance piping
below  the ground surface upon  which the  cap  would  be installed,  impacts on the cap
construction costs shown above would be minimized or eliminated.

If an ISTD system is used prior to surface cap construction (Alternative 2C) to remove organic
contamination in "hot spots", it is projected  that the 30 year present value of the remedial
action would be in the  range of $92.8 million to $99.8 million. As is the case for the other two
containment  alternatives,  asphalt would  be  the least  expensive capping  material choice,
followed by concrete and multilayer soil.

6.8 STATE AND COMMUNITY ACCEPTANCE

As  stated earlier, the  state and community acceptance criteria  will be addressed during and
following the issuance of the proposed plan and the subsequent public comment period.

6.9 PREFERRED ALTERNATIVE

Based  on evaluation of the four retained alternatives using the seven evaluation criteria, it
appears that Alternative  2A (Surface  Cap)  would be the most cost-effective approach for
addressing the risks from  the soil and  soil gas contamination that is present in OU-3.   This
alternative would be consistent  with  the  identified ARARs and would provide protection  of
human health and the environment over  the long term by eliminating the soil and sediment
exposure pathways and substantially reducing the soil gas  exposure pathways.   ICs would  be
used to restrict land use,  prevent the use of site groundwater, require the inclusion of vapor
intrusion protection in future building construction, ensure that remedial measures  remain in
good functional condition, require that  any construction activities minimize the  impact on and
repair any damage to the cap, and keep the public informed of site developments and hazards.
These controls could be implemented through zoning ordinances, access agreements,  restrictive
covenants, and public  awareness efforts and would be  required  to increase the level  of
protection  and ensure that the surface cap continues to be effective  over the long term.
Alternatives 2B and 2C would offer some increased protection of human health during future
intrusive  activities  (e.g., construction,   well  installation,  and  cap  repair)   by   reducing
contaminant  levels  in  "hot spot" soils and soil  gas, but  any increased  risk associated  with
Alternative 2A could be managed through the use of PPE, vapor and dust suppression, worker
training and other precautions.

The installation  of  a surface cap  will  not  reduce  the  toxicity or volume  of the OU-3
                                     U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                          Delaware

contaminants, but it would reduce the mobility of the contaminants by reducing/eliminating
precipitation infiltration, preventing stormwater contact with contaminated soils, preventing the
airborne transport of contaminated soil particles, and minimizing the potential off-gassing of
soil  gases.   While each  of  the containment  alternatives  could  be  readily  constructed,
implementation of Alternative 2A would be the easiest of the three and could be accomplished
in the shortest period of time  for the lowest overall cost.

Although asphalt would be  the least expensive option and would provide protection that should
be (if properly maintained) equal to that offered by the concrete and multilayer soil options, a
choice must be made as to the possible  future uses of the  capped area and the importance of
site appearance. While the  concrete and asphalt caps would be preferable if redevelopment of
the site for some low occupancy business purpose is envisioned,  a multilayer soil cap would
likely be more visually appealing and more amenable to conversion of the land to park space or
naturalized open space.
                                      U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                       Delaware
7.0    REFERENCES

Air Force Center for Engineering and the Environment (AFCEE),  1999.   "Survey of Air
   Force  Landfills,  Their  Characteristics,  and Remediation Strategies". Prepared for Air
   Force Center for Environmental Excellence by Mitretek Systems. July 1999.

Black  &  Veatch,  2007.  "Final Baseline Risk Assessment Report, Standard Chlorine of
   Delaware Site,  New  Castle  County,  Delaware".  Black  & Veatch  Special  Projects
   Corporation.  August 2007.

Black & Veatch, 2007a. "Remedial Investigation Report, Standard Chlorine of Delaware Site,
   New Castle County, Delaware".  Black &  Veatch Special Projects Corporation.  August
   2007.

Black & Veatch, 2005. Final Groundwater Basis of Design/Design Criteria Report, Standard
   Chlorine of  Delaware  Site, New  Castle County, Delaware.  Black and Veatch  Special
   Projects Corporation. September 2005.

Black  & Veatch, 2003.  "Soil/Sediment  Design Comparison Study, Standard Chlorine of
   Delaware Site,  New  Castle  County,  Delaware".  Black  & Veatch  Special  Projects
   Corporation.  June 2003.

Brayton,  2009.  E-mail communication  regarding USGS  Potomac  Formation investigation
   findings from Michael Brayton,  received May 11, 2009.

Conestoga Rovers & Associates (CRA), 2000.  "Work  Plan for Site Investigation, Step 4 of
   Ecological Risk Assessment, Standard Chlorine of Delaware Superfund Site". Conestoga-
   Rovers & Associates.  March 2000.

Delaware  Department  of Natural  Resources and Environmental Control (DNREC), 2004.
   "State  of Delaware Surface Water Quality  Standards", Delaware Department of  Natural
   Resources and Environmental Control. July 11, 2004.

U.S.  Environmental  Protection Agency  (EPA), 2008. "Ecological Soil  Screening Levels".
   http://www.epa.gov/ecotox/ecossl/.

EPA, 2006.  "In Situ Treatment Technologies for Contaminated Soil: Engineering Forum Issue
   Paper." U.S. Environmental Protection Agency. EPA 542/F-06/013.  November 2006.

EPA, 2001.  "Remediation Technology Cost Compendium - Year 2000". EPA-542-R-01-009.
   U.S. Environmental Protection Agency. September 2001.
                                    U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                       Delaware

EPA, 2001a.  "EPA Risk Assessment Guidance for Superfund (RAGS) - Volume I Human
   Health Evaluation Manual,  Part D,  Standardized  Planning, Reporting and  Review of
   Superfund Risk Assessments". U.S. Environmental Protection Agency. December 2001.

EPA 2000.  "A Guide to Developing and Documenting Cost Estimates during the Feasibility
   Study". EPA 540-R-00-002 / OSWER 9355.0-75. U.S.  Environmental Protection Agency.
   July 2000.

EPA  1993.  "Presumptive Remedies:  Site Characterization and  Technology Selection  for
   CERCLA Sites with  Volatile Organic Compounds in Soils".  USEPA 540-F-93-048. U.S.
   Environmental Protection Agency. 1993.

EPA,  1992.   "CERCLA/SUPERFUND   Orientation  Manual."   EPA/542/R-92/005.  U.S.
   Environmental Protection  Agency  -  Office of  Solid  Waste and  Emergency Response
   Technology Innovation Office.  October 1992.

EPA, 1989. "EPA Risk Assessment Guidance for  Superfund (RAGS) - Volume I Human
   Health Evaluation Manual, Part  A".  EPA/540/1-89/002. U.S.  Environmental Protection
   Agency. December 1989.

EPA 1988, "Guidance for Conducting  Remedial Investigations and Feasibility Studies Under
   CERCLA."  U.S.  Environmental  Protection  Agency.  EPA/540/G-89/004,  OSWER
   Directive 9355.3-01.  October 1988.

Federal Remediation Technologies Roundtable (FRTR), 2002.  "Remediation Technologies
   Screening Matrix and Reference  Guide, Version 4.0".   Federal Remediation Technology
   Roundtable. http: //www. frtr. gov/matrix2/top_page. html.

Interstate  Technology &  Regulatory  Council  (ITRC), 2005.  "Technical  and  Regulatory
   Guidance  for In Situ Chemical Oxidation of  Contaminated  Soil and Groundwater",  2nd
   Edition. Interstate Technology and Regulatory Council. January 2005.

ITRC,  2003.  "Technical  and Regulatory Guidance  for  Surfactant/Cosolvent  Flushing of
   DNAPL Source  Zones",  DNAPLs-3.  Washington,  D.C.:  Interstate  Technology &
   Regulatory Council, DNAPLs Team. Available on the Internet at http://www.itrcweb.org.

ITRC,  1997.  "Technical and Regulatory  Guidance for Soil Washing." Interstate Technology
   and Regulatory Council - Metals in Soil Work Team. December 1997.

Hydrogeologic, Inc.  (HGL), 2009. "Wetlands Remedial Approach and Pilot Study Summary
   Report  for The  Standard  Chlorine  of  Delaware Site -  New  Castle,  Delaware".
   HydroGeoLogic, Inc. February, 2009.
                                   U.S. EPA Region 3
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HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County,
                                        Delaware

HGL, 2008.  "Final Sampling and Analysis Plan - Standard Chlorine of Delaware Site,  New
   Castle, Delaware".  Hydrogeologic, Inc. February 2008.

Jordan and Talley,  1976.  Guidebook, Columbia Deposits of Delaware: Delaware Geological
   Survey Open File Report No. 8, Jordan, R.R., and  Talley J.H.  1976.

Oak  Ridge   National  Laboratory  (ORNL),   1997.  "Preliminary  Remediation  Goals  for
   Ecological Endpoints".  U.S. Department of Energy - Oak Ridge National Laboratory,
   ES/ER/TM-162/R2. August 1997.

P2Pays,  1998.  "It's Electric- Battelle and TerraTherm Team Up to Deploy Six-Phase Soil
   Heating." http://www.p2pays.org/ref/14/13975.htm. Spring 1998.

Spoljarac, 1967. "Pleistocene Channels  of New Castle County, Delaware". Nenad Spoljaric,
   Delaware Geological Survey. May 1967.

TerraTherm, 2008.  Vendor quote letter  from TerraTherm, Inc. received June 3, 2008.

TerraTherm, 2007.    "TerraTherm Pretreatment  Design  Consideration Frequently Asked
   Questions", http://www.terratherm.com/technology/faq.htm.

Weston.   1993.  "Feasibility Study  (FS)  Report,  Standard Chlorine of Delaware Inc.  Site,
   Delaware City Delaware". Roy F. Weston, Inc.  May 1993.

Weston.   1992.  "Remedial  Investigation (RI) Report, Standard  Chlorine of Delaware Inc.
   Site, Delaware City Delaware".  Roy F. Weston, Inc. September 1992.
                                    U.S. EPA Region 3
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   Appendix A



PRG Detail Tables

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                                                              HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                               Table A-l. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On Facility Soil
I. Site-specific Human Health Risk Parameters from BLRA

Benzene
1 ,2-Dichlorobenzene
1 , 3 -Dichlorobenzene
1 ,4-Dichlorobenzene
Total Dichlorobenzene
Chlorobenzene
1,2,3,4-Tetrachlorobenzene
1,2,4,5-Tetrachlorobenzene
Total Tetrachlorobenzene
Pentachlorobenzene
Hexachlorobenzene
1 ,2,3 -Trichlorobenzene
1,2,4-Trichlorobenzene
1 , 3 ,5 -Trichlorobenzene
Total Trichlorobenzene
2,3,7,8-TCDD

na
na
na
1070
na
na
204
258
na
na
16.8
na
na
na
na
0.114

na
na
na
Liver,
Development
na
na
Kidney
Kidney
na
na
Liver
na
na
na
na
na

na
na
na
0.05
na
na
1
2
na
na
0.04
na
na
na
na
na

na
na
na
0.4
na
na
10
13
na
na
0.3
na
na
na
na
na

na
na
na
4.20E-05
na
na
na
na
na
na
5.20E-05
na
na
na
na
0.027

na
na
na
0.02
na
na
0.8
1
na
na
0.02
na
na
na
na
na

na
na
na
6.30E-06
na
na
na
na
na
na
1.10E-05
na
na
na
na
4.20E-03

na
na
na
0.1
na
na
3
4
na
na
0.09
na
na
na
na
na

na
na
na
1.30E-06
na
na
na
na
na
na
1.70E-06
na
na
na
na
8.90E-04

na
na
na
7
na
na
4
4
na
na
7
na
na
na
na
na
                                                                                                  NOTES:

                                                                                      EPC - Exposure Point Concentration
                                                                                              HI - Hazard Index
                                                                                              CR - Cancer Risk
HGL
                                                                                                                                                                                       Page 1 of 9

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                                                              HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                               Table A-l. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On Facility Soil



Benzene
1 ,2-Dichlorobenzene
1 , 3 -Dichlorobenzene
1 ,4-Dichlorobenzene
Total Dichlorobenzene
Chlorobenzene
1,2,3,4-Tetrachlorobenzene
1,2,4,5-Tetrachlorobenzene
Total Tetrachlorobenzene
Pentachlorobenzene
Hexachlorobenzene
1 ,2,3 -Trichlorobenzene
1,2,4-Trichlorobenzene
1 , 3 ,5 -Trichlorobenzene
Total Trichlorobenzene
2,3,7,8-TCDD
carbon tetrachloride
chloroform
Trichloroethylene (PCE)
Tetrachloroethylene (TCE)
2-Methylphenol
4,4'-DDD
4,4'-DDE
4,4'-DDT

Acenaphthene





























na
na
na
7643
na
na
64
65
na
na
120
na
na
na
na
na
na
na
na
na
na
na
na
na

na

na
na
na
1529
na
na
17
16
na
na
27
na
na
na
na
na
na
na
na
na
na
na
na
na

na















































































































na
na
na
1.11E-05
na
na
na
na
na
na
1.11E-05
na
na
na
na
1.11E-05
na
na
na
na
na
na
na
na

na




























na
na
na
1,887
na
na
na
na
na
na
17
na
na
na
na
3.02E-04
na
na
na
na
na
na
na
na

na

na
na
na
9,145
na
na
na
na
na
na
110
na
na
na
na
1.42E-03
na
na
na
na
na
na
na
na

na





























na
na
na
188.7125
na
na
na
na
na
na
1.69697
na
na
na
na
3.02E-05
na
na
na
na
na
na
na
na

na

na
na
na
914.52991
na
na
na
na
na
na
10.980392
na
na
na
na
0.0001423
na
na
na
na
na
na
na
na

na
HGL
                                                                                                                                                                                        Page 2 of 9

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                                                              HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                               Table A-l. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On Facility Soil
II. Considered Human Health PRGs

Units (mg/kg)
Acenaphthylene
Anthracene
Fluoranthene
Fluorene
Naphthalene
Phenanthrene
Total Low Molecular Weight
PAHs

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Chrysene
Dibenz(a,h)anthracene
Indeno( 1 ,2,3-c,d)pyrene
Pyrene
Total High Molecular Weight
PAHs
Pentachlorophenol

Aluminum
Antimony
Beryllium
Chromium
Cobalt
Copper
Iron
Human Health Non-Cancer PRGs
Non-
Cancer
Child
Resident
PRG



























Non-Cancer
Industrial
Worker PRG
na
na
na
na
na
na
na

na
na
na
na
na
na
na
na
na
na
na

na
na
na
na
na
na
na
Non-Cancer
Construc-
tion Worker
PRG
na
na
na
na
na
na
na

na
na
na
na
na
na
na
na
na
na
na

na
na
na
na
na
na
na
Human Health Cancer PRG (10-6 cancer risk)
Individual
Chemical
Cancer
Risks



























10-6
Cancer
Risk
Resident!
alPRG



























10-6
Cancer
Risk
Indus-
trial
Worker
PRG



























10-6 Cancer
Risk
Construc-
tion Worker
PRG



























Human Health Cancer PRG (10-4 cancer risk)
Individual
Chemical
Cancer
Risks
na
na
na
na
na
na
na

na
na
na
na
na
na
na
na
na
na
na

na
na
na
na
na
na
na
Residential
PRG, 10-4



























Industrial
Worker
PRG,
CR=10-4
na
na
na
na
na
na
na

na
na
na
na
na
na
na
na
na
na
na

na
na
na
na
na
na
na
Cons-
truction
Worker
PRG,
CR=10-4
na
na
na
na
na
na
na

na
na
na
na
na
na
na
na
na
na
na

na
na
na
na
na
na
na
Human Health Cancer PRG (10-5
cancer risk)
Residen-
tial PRG,
10-5



























Indus-
trial
Worker
PRG,
CR=10-5
na
na
na
na
na
na
na

na
na
na
na
na
na
na
na
na
na
na

na
na
na
na
na
na
na
Cons-
truction
Worker
PRG,
CR=10-5
na
na
na
na
na
na
na

na
na
na
na
na
na
na
na
na
na
na

na
na
na
na
na
na
na
HGL
                                                                                                                                                                                        Page 3 of 9

-------
                                                                    HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                                     Table A-l. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On Facility Soil
II. Considered Human Health PRGs








Units (mg/kg)
Lead
Manganese
Mercury
Nickel
Thallium
Vanadium
Zinc

Human Health Non-Cancer PRGs


Non-
Cancer
Child
Resident
PRG











Non-Cancer
Industrial
Worker PRG
na
na
na
na
na
na
na



Non-Cancer
Construc-
tion Worker
PRG
na
na
na
na
na
na
na

Human Health Cancer PRG (10-6 cancer risk)



Individual
Chemical
Cancer
Risks









10-6
Cancer
Risk
Resident!
alPRG







10-6
Cancer
Risk
Indus-
trial
Worker
PRG









10-6 Cancer
Risk
Construc-
tion Worker
PRG








Human Health Cancer PRG (10-4 cancer risk)



Individual
Chemical
Cancer
Risks
na
na
na
na
na
na
na





Residential
PRG, 10-4










Industrial
Worker
PRG,
CR=10-4
na
na
na
na
na
na
na


Cons-
truction
Worker
PRG,
CR=10-4
na
na
na
na
na
na
na
Human Health Cancer PRG (10-5
cancer risk)




Residen-
tial PRG,
10-5









Indus-
trial
Worker
PRG,
CR=10-5
na
na
na
na
na
na
na


Cons-
truction
Worker
PRG,
CR=10-5
na
na
na
na
na
na
na
NOTES:




Metals were not included in human health calculations




For noncarcinogens, the target hazard quotient (THQ) of 1 was divided by the number of chemicals in that medium that affected the same target organ.




Grayed out PRGs are not used in calculation of the most limiting PRG




Per-Chemical Cancer risks for 10-6 cancer risk were calculated by using CR = 10-6 for each individual chemical




Per-Chemical Cancer Risks for 10-4 cumulative cancer risks were  calculated by dividing 10-4 by total number of cancer-causing chemicals in this media (9 for on facility soil and soil gas)
    HGL
                                                                                                                                                                                                 Page 4 of 9

-------
                                                              HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                               Table A-l. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On Facility Soil

Benzene
1 ,2-Dichlorobenzene
1 ,3 -Dichlorobenzene
1 ,4-Dichlorobenzene
Total Dichlorobenzene
Chlorobenzene
1,2,3,4-Tetrachlorobenzene
1 ,2,4,5-Tetrachlorobenzene
Total Tetrachlorobenzene
Pentachlorobenzene
Hexachlorobenzene
1 ,2,3 -Trichlorobenzene
1 ,2,4-Trichlorobenzene
1 ,3 ,5 -Trichlorobenzene
Total Trichlorobenzene
2,3,7,8-TCDD
carbon tetrachloride
chloroform
Trichloroethylene (PCE)
Tetrachloroethylene (TCE)
2-Methylphenol
4,4'-DDD
4,4'-DDE
4,4'-DDT

Acenaphthene
Acenaphthylene
Anthracene
NA
NA
NA
NA

NA
NA
NA

NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA




NA
NA
NA
NA

NA
NA
NA

NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA




NA
NA
NA
NA

NA
NA
NA

NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

20
NA
NA
NA
NA
NA
20
20
40
10
NA
10
20
NA
20
20
NA
20
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA

NA
1000
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
7.0E-05
NA
NA
NA
NA
1.4E-05
NA
NA
NA
NA
NA
0.005
NA
0.005

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.4E-04
NA
NA
NA
NA
NA
0.046
NA
0.043

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
HGL
                                                                                                                                                                                        Page 5 of 9

-------
                                                              HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                               Table A-l. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On Facility Soil
III. Considered Ecological PRGs
Units (mg/kg)
Fluoranthene
Fluorene
Naphthalene
Phenanthrene
Total Low Molecular Weight
PAHs

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Chrysene
Dibenz(a,h)anthracene
Indeno( 1 ,2,3-c,d)pyrene
Pyrene
Total High Molecular Weight
PAHs
Pentachlorophenol

Aluminum
Antimony
Beryllium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Eco-
SSL
for
Plants




NA










NA
5

NA
NA
NA
NA
13
70
NA
120
220
NA
38
Eco-SSLs for
Terrestrial
Invertebrates




29










18
31

NA
78
40
NA
NA
80
NA
1700
450
NA
280
ORNL
Benchmark
Concentration
for Plants
NA
NA
NA
NA


NA
NA
NA
NA
NA

NA
NA
NA

3

50
5
10
1
20
100
NA
50
500
0.3
30
ORNL
Benchmark
Concentration
for
Earthworms
NA
30
NA
NA


NA
NA
NA
NA
NA
NA
NA
NA
NA

6

NA
NA
NA
0.4
NA
50
NA
500
NA
0.1
200
ORNL
Benchmark
Concentration
for Soil
Microorganisms
and Microbial
Processes
NA
NA
NA
NA


NA
NA
NA
NA
NA
NA
NA
NA
NA

400

600
NA
NA
10
1000
100
200
900
100
30
90
Robin
NOAEL
PRG
(mg/kg)
0.192
NA
NA
0.210
NA

NA
NA
NA
NA
NA
NA
NA
NA
0.193
NA
1.6E-04

NA
NA
NA
NA
NA
1179
NA
39.80
NA
NA
NA
Robin
LOAEL
PRG
(mg/kg)
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
1548
NA
408.86
NA
NA
NA
Vole
NOAEL
PRG
(mg/kg)
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
234.8
NA
NA
NA
0.196
NA
Vole
LOAEL
PRG
(mg/kg)
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
303.9
NA
NA
NA
1.96
NA
HGL
                                                                                                                                                                                        Page 6 of 9

-------
                                                              HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                               Table A-l. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On Facility Soil
III. Considered Ecological PRGs






Units (mg/kg)
Thallium
Vanadium
Zinc



Eco-
SSL
for
Plants
NA
NA
160




Eco-SSLs for
Terrestrial
Invertebrates
NA
NA
120



ORNL
Benchmark
Concentration
for Plants
1
2
50


ORNL
Benchmark
Concentration
for
Earthworms
NA
NA
200
ORNL
Benchmark
Concentration
for Soil
Microorganisms
and Microbial
Processes
NA
20
100



Robin
NOAEL
PRG
(mg/kg)
NA
NA
39.96



Robin
LOAEL
PRG
(mg/kg)
NA
NA
360.98



Vole
NOAEL
PRG
(mg/kg)
NA
NA
6667



Vole
LOAEL
PRG
(mg/kg)
NA
NA
13333
HGL
                                                                                                                                                                                        Page 7 of 9

-------
                                                                  HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                                   Table A-l. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On Facility Soil


Benzene
1 ,2-Dichlorobenzene
1 ,3 -Dichlorobenzene
1 ,4-Dichlorobenzene
Total Dichlorobenzene
Chlorobenzene
1 ,2,3,4-Tetrachlorobenzene
1,2,4,5-Tetrachlorobenzene
Total Tetrachlorobenzene
Pentachlorobenzene
Hexachlorobenzene
1,2,3-Trichlorobenzene
1 ,2,4-Trichlorobenzene
1,3,5 -Trichlorobenzene
Total Trichlorobenzene
2,3,7,8-TCDD
carbon tetrachloride
chloroform
Trichloroethylene (PCE)
Tetrachloroethylene (TCE)
2-Methylphenol
4,4'-DDD
4,4'-DDE
4,4'-DDT

na
na
na
20
20
40
10
16
10
20
7.01E-05
20
20
na
20
1.4E-05
na
na
na
na
na
4.9E-03
na
4.6E-03

na
na
na
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
Construction Worker PRG, Non-Cancer (1)
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
Robin NOAEL PRG
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Earthworms
na
ORNL Benchmark Concentration for Earthworms
Robin NOAEL PRG
na
na
na
na
na
Robin NOAEL PRG
na
Robin NOAEL PRG

Acenaphthene
Acenaphthylene
Anthracene
Fluoranthene
Fluorene
Naphthalene
Phenanthrene
Total Low Molecular Weight PAHs
20
na
na
0.192
30
na
0.210
29
ORNL Benchmark Concentration for Plants
na
na
Robin NOAEL PRG
ORNL Benchmark Concentration for Earthworms
na
Robin NOAEL PRG
Eco-SSLs for Terrestrial Invertebrates

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Chrysene
na
na
na
na
na
na
na
na
na
na
na
na
v HGL
                                                                                                                                                                                            Page 8 of 9

-------
                                                                      HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                                      Table A-l. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On Facility Soil
IV. On-Facility Soil Limiting PRGs
(mg/kg)
Chemicals of Potential Concern
Dihen/(a 1i)anthracene
Indeno( 1 ,2,3 -c,d)pyrene
Pyrene
Total High Molecular Weight PAHs
Pentachlorophenol
Lowest PRG,
mg/kg
na
na
1.9E-01
18
1.6E-04
Limiting PRG Receptor
na
na
Robin NOAEL PRG
Eco-SSLs for Terrestrial Invertebrates
Robin NOAEL PRG
Metals
Aluminum
Antimony
Beryllium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Thallium
Vanadium
Zinc
50
5
10
0.4
13
50
200
39.801
100
0.1
30
1
2
40.0
ORNL Benchmark Concentration for Plants
ORNL Benchmark Concentration for Plants
ORNL Benchmark Concentration for Plants
ORNL Benchmark Concentration for Earthworms
Eco-SSL for Plants
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Soil Microorganisms and Microbial
Processes
Robin NOAEL PRG
ORNL Benchmark Concentration for Soil Microorganisms and Microbial
Processes
ORNL Benchmark Concentration for Earthworms
ORNL Benchmark Concentration for Plants
ORNL Benchmark Concentration for Plants
ORNL Benchmark Concentration for Plants
Robin NOAEL PRG
                                                            NOTES: PRGs for the 10~6 target cancer risk and PRGs for residential receptor were not used in the calculation of limiting PRGs



                                                        (1) - The PRG for total tetrachlorobenzenes would supercede the PRG for 1,2,4,5-tetrachlorobenzene because the total number is lower.
v  HGL
                                                                                                                                                                                                         Page 9 of 9

-------
                                                        HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                       Table A-2. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On-Facility Soil Gas
I. Site-specific Parameters from BLRA

Benzene
1 ,4-Dichlorobenzene
Chlorobenzene
carbon tetrachloride
chloroform
PCE
TCE
1 ,2-Dichlorobenzene

22000
23900
96600
4280
23700
1000
123
10800

Blood, Immune
Liver
Liver ,Kidney
Liver
CNS, Liver, Kidney
CNS
CNS, Liver,
Endocrine
Body weight

7
0.5
30
0.4
8
0.07
0.05
1

20
1
60
1
20
0.2
0.1
3

9.31E-04
1.40E-03
na
6.71E-04
4.91E-03
6.41E-05
1.24E-04
na

3
0.2
10
0.2
3
0.03
0.02
0.5

2.50E-04
3.80E-04
na
1.80E-04
1.30E-03
1.80E-05
3.40E-05
na

0.005
3.00E-04
0.02
3.00E-04
0.006
4.00E-05
3.00E-05
8.00E-04

1.70E-08
2.20E-08
na
1.10E-08
9.90E-08
l.OOE-09
2.10E-09
na

1
7
7
7
7
3
7
1
                                                                                            NOTES:

                                                                                EPC - Exposure Point Concentration
                                                                                        HI - Hazard Index
                                                                                        CR - Cancer Risk
HGL
                                                                                                        Page lof 2

-------
                                                              HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                            Table A-2. Summary of Receptors and Target Risks Considered in Calculation of PRGs for the On-Facility Soil Gas

Units (soil gas,
ppb)
Benzene
1,4-
Dichlorobenzene
Chlorobenzene
carbon
tetrachloride
chloroform
PCE
TCE
1,2-
Dichlorobenzene
Human Health PRG, Non-
Cancer
Non-
Cancer
Child
Residen
tPRG
LI 00
3.414
230
611
169
1.667
176
3.600
Non-
Cancer
Indus-
trial
Worker
PRG
7,333
17,071
1,380
3,057
1,129
11,111
879
21,600
Non-
Cancer
Construc-
tion
Worker
PRG
4,400,000
11,380,952
690,000
2,038,095
564,286
8,333,333
585,714
13,500,000
Human Health Cancer PRG (10-6
cancer risk)
10-6
Cancer
Risk
Resident!
alPRG
24
1?
na
6
5
16
1
na
10-6
Cancer
Risk
Indus-
trial
Worker
PRG
88
63
na
24
18
56
4
na
10-6
Cancer
Risk
Construc-
tion
Worker
PRG
L294J18
1.086.364
na
389,091
239,394
1.000.000
58.571
na
Human Health Cancer PRG (10-4 cancer risk)
Individu
al
Chemical
Cancer
Risks
1.11E-05
1.11E-05
na
1.11E-05
1.11E-05
1.11E-05
1.11E-05
na
Resident!
al PRG,
10-4
263
190

71
54
173
11
na
Indus-
trial
Worker
PRG,
CR=10-4
977
698
na
264
202
617
40
na
Construction
Worker
PRG,
CR=10-4
14,379,085
12,070,707
na
4,323,232
2,659,933
11,111,111
650,794
na
Human Health Cancer
cancer risk
Resident!
alPRG,
10-5
26
19

7
5
17
1
na
Industrial
Worker
PRG,
CR=10-5
98
70
na
26
20
62
4
na
PRG (10-5
Construc-
tion
Worker
PRG,
CR=10-5
1,437,908
1,207,071
na
432,323
265,993
1,111,111
65,079
na
Limiting PRG
Lowest
PRG,
ppb
98
70
1,380
26
20
62
4
21,600
Limiting PRG
Receptor
Industrial Worker
PRG, CR=10-5
Industrial Worker
PRG, CR=10-5
Non-Cancer Industrial
Worker PRG
Industrial Worker
PRG, CR=10-5
Industrial Worker
PRG, CR=10-5
Industrial Worker
PRG, CR=10-5
Industrial Worker
PRG, CR=10-5
Non-Cancer Industrial
Worker PRG
NOTES:




Metals were not included in human health calculations




For noncarcinogens, the target hazard quotient (THQ) of 1 was divided by the number of chemicals in that medium that affected the same target organ.




Grayed out receptors and target risks are not used in calculation of the most limiting PRG




Per-Chemical Cancer risks for 10-6 cancer risk were calculated by using CR = 10-6 for each individual chemical




Per-Chemical Cancer Risks for 10-4 cumulative cancer risks were calculated by dividing 10-4 by total number of cancer-causing chemicals in this media  (9 for on facility soil and soil gas)
    HI3L
                                                                                                               Page 2of 2

-------
                                                              HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                                   Table A-3. Summary of Receptors and Target Risks Considered in Calculation of Off Facility Soil PRGs
I. Site-specific Parameters from BLRA
Units (soil gas, ppb)
1 ,4-Dichlorobenzene
1,2,3,4-
Tetrachlorobenzene
1,2,4,5-
Tetrachlorobenzene
Hexachlorobenzene
2,3,7,8-TCDD
4,4'-DDD
4,4'-DDT
Fluoranthene
Pentachlorophenol *
Phenanthrene
Pyrene
Copper
Lead
Mercury
Zinc
EPC, mg/kg
1410
2750
45.5
na
1.28E-04
na
na
na
na
na
na
na
na
na
na
Target Organ
Liver, Development
Kidney
Kidney
na
na
na
na
na
na
na
na
na
na
na
na
Adult
Resident HI
0.07
20
0.3
na
na
na
na
na
na
na
na
na
na
na
na
Child
Resident
HI
0.6
130
2
na
na
na
na
na
na
na
na
na
na
na
na
Resident
Age-Adj
CR
5.40E-05
na
na
na
3.00E-05
na
na
na
na
na
na
na
na
na
na
Industrial
Worker
HI
0.03
10
0.2
na
na
na
na
na
na
na
na
na
na
na
na
Industrial
Worker
CR
8.30E-06
na
na
na
4.70E-06
na
na
na
na
na
na
na
na
na
na
Construction
Worker HI
0.2
40
0.6
na
na
na
na
na
na
na
na
na
na
na
na
Construction
Worker CR
1.80E-06
na
na
na
l.OOE-06
na
na
na
na
na
na
na
na
na
na
Number
of
chemicals
affecting
target
organ
3
3
3
na
na
na
na
na
na
na
na
na
na
na
na
                                                                                                   NOTES:

                                                                                       EPC - Exposure Point Concentration
                                                                                              HI - Hazard Index
                                                                                               CR - Cancer Risk
HGL
                                                                                                                                                                                                  Page 1 of4

-------
                                                                    HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                                         Table A-3. Summary of Receptors and Target Risks Considered in Calculation of Off Facility Soil PRGs
II. Human Health PRGs

Units (soil gas, ppb)
1 ,4-Dichlorobenzene
1 ,2,3,4-Tetrachlorobenzene
1,2,4,5-Tetrachlorobenzene
Hexachlorobenzene
2,3,7,8-TCDD
4,4'-DDD
4,4'-DDT
Fluoranthene
Pentachlorophenol*
Phenanthrene
Pyrene
Copper
Lead
Mercury
Zinc
Human Health Non-Cancer PRGs
Non-
Cancer
Child
Resident
PRG
783
7.05
7.58
na
na
na
na
na
na
na
na
na
na
na
na
Non-
Cancer
Industrial
Worker
PRG
15,667
92
76
na
na
na
na
na
na
na
na
na
na
na
na
Non-Cancer
Construction
Worker PRG
2,350
23
25
na
na
na
na
na
na
na
na
na
na
na
na
Human Health Cancer PRG (10-6 cancer risk)
Individual
Chemical
Cancer Risks
l.E-06
l.E-06
l.E-06
na
l.E-06
na
na
na
na
na
na
na
na
na
na
10-6 Cancer
Risk
Residential
PRG
26
na
na
na
4.E-06
na
na
na
na
na
na
na
na
na
na
10-6 Cancer
Risk
Industrial
Worker
PRG
170
na
na
na
3.E-05
na
na
na
na
na
na
na
na
na
na
10-6 Cancer
Risk
Construction
Worker
PRG
783
na
na
na
l.E-04
na
na
na
na
na
na
na
na
na
na
Human Health Cancer PRG (10-4 cancer risk)
Individual
Chemical
Cancer
Risks
3.33E-05
na
na
na
3.33E-05
na
na
na
na
na
na
na
na
na
na
Residential
PRG, 10-4
870
na
na
na
1.42E-04
na
na
na
na
na
na
na
na
na
na
Industrial
Worker
PRG,
CR=10-4
5,663
na
na
na
9.08E-04
na
na
na
na
na
na
na
na
na
na
Construction
Worker
PRG,
CR=10-4
26,111
na
na
na
4.27E-03
na
na
na
na
na
na
na
na
na
na
Human Health Cancer PRG
(10-5 cancer risk)
Residential
PRG, 10-5
87.0
na
na
na
1.42E-05
na
na
na
na
na
na
na
na
na
na
Industrial
Worker
PRG,
CR=10-5
566
na
na
na
9.08E-05
na
na
na
na
na
na
na
na
na
na
Construction
Worker PRG,
CR=10-5
2,611
na
na
na
4.27E-04
na
na
na
na
na
na
na
na
na
na
NOTES:
Metals were not included in human health calculations
For noncarcinogens, the target hazard quotient (THQ) of 1 was divided by the number of chemicals in that medium that affected the same target organ.
Grayed out target risks and receptors are not used in calculation of the most limiting PRG
Per-Chemical Cancer risks for 10-6 cancer risk were calculated by using CR = 10-6 for each individual chemical
Per-Chemical Cancer Risks for 10-4 cumulative cancer risks were calculated by dividing 10-4 by total number of cancer-causing chemicals in this media (3 for off-facility soil and soil gas)
    HGL
                                                                                                                                                                                                            Page 2 of4

-------
                                                               HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                                    Table A-3. Summary of Receptors and Target Risks Considered in Calculation of Off Facility Soil PRGs
III. Ecological PRGs
Units (mg/kg)
1 ,4-Dichlorobenzene
1,2,3,4-Tetrachlorobenzene
1, 2,4,5 -Tetrachlorobenzene
Hexachlorobenzene
2,3,7,8-TCDD
4,4'-DDD
4,4'-DDT
Fluoranthene
Pentachlorophenol
Phenanthrene
Pyrene
Copper
Lead
Mercury
Zinc
Robin
NOAEL
PRG

na
na
0.00
0.00
0.00
0.00
0.19
0.00
0.21
0.19
1,179.42
39.80
na
39.96
Robin
LOAEL
PRG
na
na
na

0.00
0.05
0.04




1,548.31
408.86
na
360.98
Vole
NOAEL
PRG
na
na
na
na
na
na
na
na
na
na
na
234.85
na
0.20
6,666.67
Vole
LOAEL
PRG
na
na
na
na
na
na
na
na
na
na
na
303.90
na
1.96
13,333.33
HGL
                                                                                                                                                                                                    Page 3 of4

-------
                                                               HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                                    Table A-3. Summary of Receptors and Target Risks Considered in Calculation of Off Facility Soil PRGs
IV. Limiting PRGs (Off-Facility Soil)
Units (mg/kg)
1 ,4-Dichlorobenzene
1,2,3,4-Tetrachlorobenzene
1,2,4,5-Tetrachlorobenzene
Hexachlorobenzene
2,3,7,8-TCDD
4,4'-DDD
4,4'-DDT
Fluoranthene
Pentachlorophenol*
Phenanthrene
Pyrene
Copper
Lead
Mercury
Zinc
Lowest
PRG, mg/kg
566
23
25
7.01E-05
1.40E-05
4.94E-03
4.62E-03
1.92E-01
1.56E-04
2.10E-01
1.93E-01
235
40
1.96E-01
40
Limiting PRG Receptor
Industrial Worker PRG, CR=10-5
Non-Cancer Construction Worker
PRG
Non-Cancer Construction Worker
PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Robin NOAEL PRG
Vole NOAEL PRG
Robin NOAEL PRG
Vole NOAEL PRG
Robin NOAEL PRG
HGL
                                                                                                                                                                                                    Page 4 of4

-------
                                                                    HGL—Feasibility Study Report, Standard Chlorine of Delaware Super/and Site—New Castle, Delaware
                                                     Table A-4. Summary of Receptors and Target Risks Considered in Calculation of Off-Facility Soil Gas PRGs
I. Site-specific Parameters from BLRA

1 ,4-Dichlorobenzene
Chlorobenzene

280
970

Liver
Liver,
Kidney

0.02
0.3

0.04
0.7

5.00E-05
na

0.008
0.1

1.40E-05
na

l.OOE-05
2.00E-04

7.90E-10
na
                                                                                                         NOTES:

                                                                                            EPC - Exposure Point Concentration
                                                                                                    HI - Hazard Index
                                                                                                    CR - Cancer Risk



1 ,4-Dichlorobenzene
Chlorobenzene


3
3

0.33
0.33




1.17E+04
3.23E+03

9.33E+06
1.62E+06















3.33E-05
3.33E-05




666
na

1.18E+07
na





67
na

1.18E+06
na
NOTES:
Metals were not included in human health calculations
For noncarcinogens, the target hazard quotient (THQ) of 1 was divided by the number of chemicals in that medium that affected the same target organ.
Grayed out PRGs are not used in calculation of the most limiting PRG
Per-Chemical Cancer risks for 10-6 cancer risk were calculated by using CR = 10-6 for each individual chemical
Per-Chemical Cancer Risks for 10-4 cumulative cancer risks were calculated by dividing 10-4 by total number of cancer-causing chemicals in this media (3 for off-facility soil and soil gas)


1 ,4-Dichlorobenzene
Chlorobenzene

67
3,233

Industrial Worker PRG, CR=10-5
Non-Cancer Industrial Worker PRG
    HGL
                                                                                                                                                                                                         Page 1 of 1

-------
                     Appendix B



SCD NPDES Permit Equivalence Documentation from DNREC

-------
                                             STATE OF DELAWARE
                                     DEPARTMENT OF NATURAL RESOURCES &
                                          ENVIRONMENTAL CONTROL
                                   DIVISION OF WATER RESOURCES
                                             89 KINGS HIGHWAY
                                          DOVER, DELAWARE 199O1
iURFACf WATER DISCHARGES SECTION
TMPHONE: {302)?39-9946
 FACSIMILE; (302)739-8369
                                                         December 17,2008
       Mr. Hilary M. Thornton
       Remedial Project Manager
       DE/VA/WV Remedial Branch
       U.S. EPA Region lit (3HS23)
       1650 Arch Street, Philadelphia, PA 19103-2029
                                                         Re:    Metachem Site
                                                                NPDES Equivalence
       Dear Mr. Thornton,
       You had asked for Delaware's requirements if a NPDES permit were issued for the treated
       groundwater and stormwater discharges from the old Metachem site1,

       I reviewed the submitted analytical results regarding compliance with Delaware State water
       quality and technology-based standards, as well as with federal ELG's. That review is based on
       procedures in the "Technical Support Document for Water Quality-based Toxics Control"2. The
       table below summarizes the results of that analysis. For each discharge, the table lists

          Parameters to be monitored
          MQnitoring frequency for those parameters,
          Waste Load Allocations (WLA), and
          Limit numbers for parameters where limits would be required.
       1   Formerly Delaware NPDES permit No. DE0020001.  The individual NPDES permit for this site was
          voided on May 2,2002.
       1   U.S.E.P.A., Office of Water (EN-336), March, 1991, EPA/505/2-90-001, PB9H27415

-------
 Mr. Hilary Thornton
 December 1.7,2008
Page 2 of3
Parameters To Be Monitored
Treated Groundwater
Copper, Total
Zinc, Total
Lead, Total
Hardness (as CaCO3)
Benzene
Chlorobenzene
Ethylbenzene
1,2-Dichlorobenzene
1,3-Dlchlorobenzene
1,4-Dlchlorobenzene
Hexachlorobenzene
Nitrobenzene
Outfall 002 (Stormwater Runoff)
iron, Total
Copper, Total
Zinc, Total
Lead, Total
Hardness (as CaCO3)
Outfall 001 (Stormwater Runoff)
Iron, Total
Copper, Total
Zinc, Total
Lead, Total
Hardness (as CaCO3)
Waste Load
Allocation (ppb)

. • 15 ' •
128
72
— .






0.033


2,000
16
138
44
—

2,000
7.4
68
32
-
Monitoring
Frequency

Monthly
Monthly
Monthly
Monthly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly

Annual
Annual
Annual
Annual
Annual

Annual
Annual
Annual
Annual
Annual
Avg, Limit
(ppb)

6.2
50
	 aid""7"





















Maximum
Limit {ppb)

15
130
70





















For the treated groundwater discharge, the monitoring for organics should be primarily to
detect break-through for the carbon filters. If that is adequately checked, the parameter-
specific monitoring as specified above can be relatively infrequent, ie., quarterly.

Monitoring methods should be sufficiently sensitive to ensure that the discharge meets the
WLAs: All calculated WLAs are shown in the enclosed CD, labeled "Metachem Delaware, NPDES
Equivalence", containing calculations spreadsheets for each discharge.

There is a PCBTMDL for the receiving waters In the vicinity of the referenced discharges. The
DRBC is helping with initial implementation of that TMDL As Gregory Cavallo of the DRBC has
told you, the discharges from this site have been identified as needing additional high-resolution
   Non-detected, but likely present

-------
Mr. Hilary Thornton                                                                Page 3 of 3
December 17, 2008

PCB congener monitoring with method 1668A, as modified by the DRBC. Please see
http://www.5tate.nj.us/drbc/PCB  info. htm for further details regarding those requirements,

Please contact me at 302-739-9946 or via John.DeFriece@State.DE. US if you have questions or
would like to discuss this further.

                                                  Sincerely,
                                                 John R. DeFriece, P.E.
                                                 Program Manager
                                                 Discharge. Permits Program
Enclosure

Cc: R. Peder Hansen

-------
           Appendix C



Remedial Technology Cost Estimates

-------
             Appendix C-l



Multilayer Soil Surface Cap Cost Estimate

-------
                                                          Appendix C-l
                                              Multilayer Surface Cap Cost Estimate
Soil Cover Alternative # 2A

On Facility Cap Area

Northern Area Cap Area
Line Item
Mobilization
Work Plans
Equip. / Contractor Mobilization
Install Runoff Controls(silt fence)

Site Preparation
Demolition of Surface Structures
Concrete Removal
Asphalt Removal
Concrete /Asphalt Crush
Soil Removal
Storage and Replacement
Subsurface Infrastructure Removal
Overhead Utility
Dust Suppression
Materials Salvage / Recycle
Non-Haz Debris Transport/Dispose
Hazardous Debris Disposal
Soil Characterization
Soil Storage / Non-Haz Disposal
Soil Storage / Haz Disposal

Grading
Compaction

Cap Placement
Upper Layer(s)
Top Cover
Burrow Barrier

993,168
110,352
60,984
6,776
Unit
Lump Sum
Lump Sum
Linear Feet


Square Foot
Cubic Yard
Square Yard
Cubic Yard
Cubic Yard
Cubic Yard
Linear Feet
Each
Square Foot
Lump Sum
Cubic Yard
Cubic Yard
Each
Cubic Yard
Cubic Yard

Cubic Yard
Cubic Yard



Cubic Yard
Cubic Yard

sqft
sqyd
sqft
sqyd
Quantity
1
1
3,986


50,000
19,248
39,357
63,000
71,455
71,455
6,290
10
993,168
0
7,700
0
0
0
0

309,950
309,950



23,719
20,929

22.8

1.4
Unit Cost
$ 75,000
$ 40,000
$ 0.79


$ 1.00
$ 14.05
$ 6.70
$ 22.28
$ 1.87
$ 8.04
$ 3.77
$ 3,200
$ 0.01
1,000
$ 57.00
$ 198.00
$ 1,000.00
$ 46.15
$ 152.31

$ 1.40
$ 0.58



$ 22.37
$ 20.00

acres

acres
Cost
$75,000
$40,000
$3,149


$50,000
$270,432
$263,690
$1,403,640
$133,943
$574,501
$23,713
$32,000
$9,932
-
$438,900
$0
$0
$0
$0

$433,931
$179,771



$530,596
$418,572




2008 Cost
$75,000
$40,000
$3,739


$50,000
$321,078
$313,073
$1,403,640
$159,027
$682,092
$25,152
$33,942
$11,792
$0
$521,096
$0
$0
$0
$0

$515,196
$213,438



$629,965
$418,572
Estimated Cost Escalation Factors
2004
2005
2006
Reference
10.0%
6.0%
5.6%

Engineering Judgment
Engineering Judgment
2007
2008




0227007041000 Means (2005)




See tab Demolition Qtys



0205505542000 Means (2005)
0205505541750 Means (2005)

4.5%
1.5%
Factor =









2004 - 08
2005 - 08
2006 - 08
2007 - 08









Vendor Quotes for Unit Price with Crushed Concrete to be spread (
0222002380260 Means (2005)
0222002660040 Means (2005) times two
See tab Utilities
See tab Utilities




33080585 Means (2005) water by truck
No salvageable materials present












RBirdSection4_cost_tables_w_S7[(S3)Excavation_offsite]
Assume same rate as for haz soil and 1 cy = 1.3 tons

RBirdSection4_cost_tables_w_S7[(S3)Excavation_offsite]
RBirdSection4 cost tables w S7[(S3)Excavation offsite]
RBirdSection4_cost_tables_w_S7[(S3)Excavation_offsite]





0222002661600 Means (2005);Dig and Cap Qty for amounts
0222002267200 Means (2005); Dig and Cap Qty for amounts






18050301 Means (2005)
Engineering Judgment
















130.6%
118.7%
112.0%
106.1%
Cost Base
2008
2008
2005


2008
2005
2005
2008
2005
2005
2007
2007
2005
2008
2005
2005
2005
2005
2005

2005
2005



2005
2008
Appendix C-l Cap Costs Soil Alt 2A
Cost-Soil Cap 2A
Page 1 of 9

-------
                                                          Appendix C-l
                                              Multilayer Surface Cap Cost Estimate
Line Item
Soil Cover
Concrete
Asphalt
Membrane Layer
Drainage Layer
Membrane Layer
Low Permeability Barrier - Clay
Low Permeability Barrier Membrane
Vapor Vent Layer - Soil
Vapor Vent Layer - Engineered
Foundation Layer
Imported Fill

Vent Piping System

Dust Suppression
Grading
Compaction
Extraction Well Modifications
Monitoring Well Modifications
Well Abandonment

Cap Completion
Re-route potable water line
Interconnection with Barrier
Surface Runoff Controls
Establish Vegetation Cover
Access Controls - Fence Modification
Access Controls - Signs
Monitoring Network
Demobilization
Project Support
Engineering Design
Unit
Cubic Yard
Square Yard
Square Yard
Square Yard
Cubic Yard
Square Yard
Cubic Yard
Square Yard
Cubic Yard
Square Feet
Cubic Yard
Cubic Yard

Lump Sum

Square Foot
Acres
Cubic Yard
Each
Each
Each


Linear Feet
Linear Feet
Linear Feet
Square Foot
Linear Feet
Linear Feet
Lump Sum
Lump Sum

12%
Quantity
71,157
0
0
110,352
47,438
110,352
94,876
110,352
47,438
0
0
15,600

1

993,168
22.8
284,629
3
11
0


2,000
3,986
1
993,168
3,941
3941
0
1

of Subtotal
Unit Cost
$ 6.97
$ 10.86
$ 9.60
$ 1.60
$ 10.55
$ 4.31
$ 21.56
$ 4.31
$ 10.55
$ 0.54
$ 6.97
$ 18.00

$ 431,700.00

$ 0.01
$ 5,000.00
$ 0.58
$ 20,000
$ 4,000
$ 700


$ 38.51
$ 7.60
$ 214,000
$ 0.05
$ 2.00
$ 0.20
$ 10,000
$ 10,000
Subtotal

Cost
$495,966
$0
$0
$176,563
$500,473
$475,617
$2,045,535
$475,617
$500,473
$0
$0
$280,795

—

$9,932
$114,000
$165,085
$60,000
$44,000
$0


$77,022
$30,296
$214,000
$48,665
$7,882
$788
$0
$15,000
S 10,619,479
$1,274,337
2008 Cost
$588,849
$0
$0
$209,629
$594,200
$564,689
$2,428,617
$564,689
$594,200
$0
$0
$280,795

$ 431,700.00

$11,792
$135,350
$196,002
$60,000
$44,000
$0

$0
$81,695
$35,970
$226,984
$57,779
$7,882
$788
$0
$15,000
S 12,547,412
$1,274,337
Reference
17030422 Means (2005)
18010314 Means (2005)


0251001040160&0380 Means (2005)






8 oz BoomEnviro (.80); 0.80 labor (2005 Means rate = .74)
17030430 Means (2005)



30 mil BoomEnviro (3.51); 0.80 labor (Means rate = .74)
33080507 Means (2005)



30 mil BoomEnviro (3.51); 0.80 labor (Means rate = .74)
17030430 Means (2005)
33080523 Means (2005)
17030422 Means (2005)
Engineering Judgment


2008 Vendor Quote









33080585 Means (2005) water by truck
















RBirdSection4_cost_tables_w_S7[(S3)Excavation_offsite]
0222002267200 Means (2005)
Engineering Judgment
Engineering Judgment
Engineering Judgment


See tab Utilities
















10 x Poly Liner Anchor Trench 33080503 Means
See tab Runoff


0293003080400 Means (2005)
Engineering Judgment




1 sign / 500 ft of perimeter; $100 installed = $0.20/ft


Engineering Judgment


Past Project Experience
























Cost Base
2005
2005
2005
2005
2005
2005
2005
2005
2005
2005
2005
2008



2005
2005
2005
2008
2008
2008


2007
2005
2007
2005
2008
2008
2008
2008

2008
Appendix C-l Cap Costs Soil Alt 2A
Cost-Soil Cap 2A
Page 2 of 9

-------
                                                          Appendix C-l
                                              Multilayer Surface Cap Cost Estimate
Line Item
Project Management
Construction Management
Waste Management
Contingencies
Completion Reports
Operation and Maintenance
Air Quality Monitoring, 4/y, 2 hr ea
Periodic Inspection (4/yr, engr, 8 hr ea)
Burrowing Animal Control, allowance
Mowing (6x/yr)
Hydroseeding, repair veg cover (10%/yr)
Cap Repairs/Fill/Regrading/Compaction (5
Fence Repairs (10%)
Reporting (1/yr)

Total

Present Value of O&M


Unit
10%
8%
2%
15%
Lump Sum
TOTAL IN
hrs
hrs
each
Acre
Acre
cy
Linear Feet
hrs






Quantity
of Subtotal
of Subtotal
of Subtotal
of Subtotal
STALLED C
8
32
1
136.8
2.42
2616
399
24






Unit Cost



Subtotal
OST
$ 100.00
$ 100.00
$ 2,500.00
$ 28.98
$ 537.62
$ 11.16
$ 15.00
$ 100.00






Northern Area Costing Estimation
Demolition Charges

Demolition Charges with Project Support
Cap Construction Charges w/o Demolition
Per Acre Cap Construction Costs w/o Demolition
Estimated Northern Area Cap Construction Cost




$2,761,468
$4,059,357.28
$13,479,209.67
$591,193.41
$827,670.77
Cost
$1,061,948
$849,558
$212,390
$1,592,922
$4,991,155
$15,610,634
$ 800
$ 3,200
$ 2,500.00
$3,964
$1,301
$29,193
$5,979
$ 2,400

$ 49,338

$ 758,445








2008 Cost
$1,061,948
$849,558
$212,390
$1,592,922
$4,991,155
$17,538,567
$ 800
$ 3,200
$ 2,500
$ 5,178
$ 1,699
$ 38,126
$ 7,809
$ 2,400
-
$ 61,712

$ 948,667


$ 18,487,234





Reference
Past Project Experience
Past Project Experience
Past Project Experience
EPA 540-R-98-045



engg estimate
engg estimate
guesswork
















18050415029734000 Means (2004)
180504028102002 Means (2004)
17030429 Means (2004)














17020701 Means + $4/ft material allowance
engg estimate














































































Cost Base
2008
2008
2008




2008
2008
2008
2004
2004
2004
2004
2008












Appendix C-l Cap Costs Soil Alt 2A
Cost-Soil Cap 2A
Page 3 of 9

-------
                                                          Appendix C-l
                                              Multilayer Surface Cap Cost Estimate
Excav
Length
1200







ition Geome
Depth
4







;try (ft)
Width
o
3







Means gave cost for 6" line =



Excavation Geometry (ft)
Length
2000





Excav
Length
5090







Depth
4





ition Geome
Depth
4







Width
o
3





;try (ft)
Width
o
J







Volume
CY
533







$ 36.00

Volume
CY
889





Volume
CY
2,262







Cost
$/CY
$ 5.65
$ 2.83
$ 8.48

$ 4,520

$ 3.77

/LF

Cost
$/CY
$ 5.65

$ 5,022
$ 2.51

$ 38.51
Cost
$/CY
$ 5.65
$ 2.83
$ 8.48

$ 19,172

$ 3.77

Potable Wat

er Line Rem

oval





General excavation from Means for 0.5 CY Excavator
Added cost for buried pipe as a percentage =
Sum











Above sum divided by linear feet
Potable Water




Line RePlac




ement

























General excavation from Means for 0.5 CY Excavator

Excavation Cost
Excavation $/LF

Total $/LF
Potable Wat






er Line Rem






oval















General excavation from Means for 0.5 CY Excavator
Added cost for buried pipe as a percentage =
Sum











Above sum divided by linear feet
Overhead
Power / Phoi
ic
















50%



















50%












Eng Judgment






































Eng Judgment












Appendix C-l Cap Costs Soil Alt 2A
Utilities
Page 4 of 9

-------
                                                          Appendix C-l
                                              Multilayer Surface Cap Cost Estimate




Means gives installation cost for 25' pole as
Assume removal and replacement of each pole
Assume removal at same rate as installation =
Cost factor to re-install within landfill =








3


$ 800.00

$ 800.00
$ 2,400.00
$ 3,200.00

each

each





10 power poles




Total cost per pole used in estimate




13.7 kva and phone


















Appendix C-l Cap Costs Soil Alt 2A
Utilities
Page 5 of 9

-------
                                                         Appendix C-l
                                              Multilayer Surface Cap Cost Estimate
Desig
Cover thickness - total (b)
Cover slope (%)

11 Paran

Equivalent radius of area covered













icter

=
=



s
6.5
3.00%
560



ft

ft
























Soil
Stone


Quantity Assumptions
Excavation Swell Factor (%) :
Compaction Shrink Factor (%):
Excavation Swell Factor (%) :
Compaction Shrink Factor (%):






25%
25%
15%
15%
















Base case - No excavation
Maximum height ( h )
Fill Height (k)

e value to calculate cap vol
f-radius to calculate cap vol
Fill Volume

23.3
16.8
217
777
ft
ft
ft
ft

Cap material volume
Maximum
height ( 1
Fill Height (k)
i)

e value to calculate cap vol
f-radius to
calculate cap vol
Fill Volume

17.8
11.3
322
882
ft
ft
ft
ft

Cap material volume
Perimeter dig depth (d)
Excavation width
Fill Radius
Excavation Volume



Site- wide dig depth (w)
5.5
183
377
1
ft
ft
ft

ft
Site- wide dig volume






Soil Cap Layer
Surface

Burrow Barrier
Protection
Geomembrane










Thick
ft
0.5
0.5
1.5









Cover thickness + (slope * equivalent radius)
Sope * esuivalent radius

Eq radius * cover thickness / fill height
Eq radius + e- value




Fill Volume = 0.333 TI (Fill ht)(Fill radius squared)





.337ih*fradiusA2 - .337ik*radiusA2 - 0.57ib(fradiusA2-radiusA2)
Cover thickn
3ss + (slope *
Sope * esuivalent radius
Sel
equivalent ra

Eq radius * cover thickness / fill height
Eq radius + e- value

ected Seen;
dius)



Fill Volume = 0.333 n (Fill ht)(Fill radius squared)
irio for Co




.337ih*fradiusA2 - .337ik*radiusA2 - 0.57ib(fradiusA2-radiusA2)



perimeter dig depth / slope
Equivalent radius - excavation width






Cap
Volume

(cy)
231,261
sting
Cap
Volume

(cy)
231,261



.337id*eqradiusA2 - .337id*fill radiusA2 - 0.57id(eqradiusA2-fill radiusA2)


7rw*fradiusA2


Material

Topsoil
cobble
Sandy loam













Estimated
Vol (cy)
17,789
17,789
53,368
0


















Vol (cy) Corrected
Perimeter
Excavate
Volume
(cy)


Perimeter
Excavate
Volume
(cy)
54,947









For Compaction Shrink
23,719
20,929
71,157









Site-wide
Excavate
Volume
(cy)


Site-wide
Excavate
Volume
(cy)
16,508














Interior
Excavate
Volume
(cy)
0

Adjust
Excavate
Volume
(cy)
66,989















Fill
Volume

(cy)
204,338
Fill
Volume

(cy)
78,689














Fill
Export (-)
Import (+)
(cy)


Fill
Export (-)
Import (+)
(cy)
11,700















Excavtn
to Fill
Ratio

0.00

Excavtn
to Fill
Ratio

0.85















Appendix C-l Cap Costs Soil Alt 2A
Dig and Cap Qty
Page 6 of 9

-------
                                                         Appendix C-l
                                              Multilayer Surface Cap Cost Estimate
Drainage
Geomembrane


Infiltration Barrier
Geomembrane
Gas Collection


Maximum


height ( 1
Fill Height (k)



Total =
i)

e value to calculate cap vol
f-radius to calculate cap vol
Fill Volume

1.0

2.0

1.0

6.5
17.8
11.3
322
882







ft
ft
ft
ft

Cap material volume
Perimeter dig depth (d)
Excavation width
Fill Radius
Excavation Volume



Site- wide dig depth (w)
5.5
183
377
1
ft
ft
ft

ft
Site- wide dig volume
Sand and gravel

Soil

Sand


Cover thickn






3ss + (slope *
Sope * esuivalent radius
35,579
0
71,157
0
35,579

231,261
Alter
equivalent ra

Eq radius * cover thickness / fill height
Eq radius + e- value








native Exci
dius)



Fill Volume = 0.333 TI (Fill ht)(Fill radius squared)
47,438

94,876

47,438

308,348
ivation Sc«




.337ih*fradiusA2 - .337ik*radiusA2 - 0.57ib(fradiusA2-radiusA2)



perimeter dig depth / slope
Equivalent radius - excavation width













narios
Cap
Volume

(cy)
231,261



.337id*eqradiusA2 - .337id*fill radiusA2 - 0.57id(eqradiusA2-fill radiusA2)


7rw*fradiusA2















Perimeter
Excavate
Volume
(cy)
54,947













Site-wide
Excavate
Volume
(cy)
16,508













Adjust
Excavate
Volume
(cy)
66,989














Fill
Volume

(cy)
78,689













Fill
Export (-)
Import (+)
(cy)
11,700














Excavtn
to Fill
Ratio

0.85







Appendix C-l Cap Costs Soil Alt 2A
Dig and Cap Qty
Page 7 of 9

-------
                                                                  Appendix C-l
                                                     Multilayer Surface Cap Cost Estimate
         Design Rainfall (in/hr)
         Target Velocity (ft/sec)
           Area
             ac
            11.4

            11.4
 C       Rainfall
          (in/hr)
0.45       1.5
0.95
1.5
              1.5
              2.5

                 Target
           Q         Vel
           cfs        ft/sec
         7.695       2.5
16.245
                   Estimated linear feet of pipe
                   Number of manholes
                   Manhole spaciing (ft)
2.5
Req'd
   Area
   (sqft)
   3.078

   6.498
                             Req'd     Req'd
                              Diameter    Diameter
                                 (ft)         (in)
                                 2.0         23.8
2.9
34.5
                               4000
                                10     at unit price of
                               400
                                                                                                          Cost/LF
                                                      53.5
96
                                                 $    500.00  equates to per foot
Cost


 214,000    Means

 384,000    Means


     1.25
                                                             manholes at 1 per 400 feet
                                                                       $500 per manhole =
                                                                        S1.25/LF
Appendix C-l Cap Costs Soil Alt 2A
                                                 Runoff
                                                                                                         Page 8 of 9

-------
                                                        Appendix C-l
                                            Multilayer Surface Cap Cost Estimate
Total Area

Acres
22.8
SqFt
970,824


Acreage
tated in FS
Screening
Report
1 	
1 	
Demolition Quantities

Item
Warehouse
NE Tank Farm
Tank Farm Bldg
WWTP

Maint/Locker Bldg
Main Process Area
Rail Siding
Loading Area Tanks
Eastern Process/Glycol
Western Road
Center Road
Road to WWTP










Remaining Area











Length
250
266
100
200
150
200
400
400
300
800
800
1300


Total
Area
SqFt
647,024






Width
200
200
40
200
40
300
60
80
50
15
15
12
Subtotal

Structure
Footprint
%
10

Totals



Bldg
?
1
0
0
0
0
0
0
0
0
0
0
0
50,000
Demo
Area
SqFt
64,702





Area
SqFt
50,000
53,200
4,000
40,000
6,000
60,000
24,000
32,000
15,000
12,000
12,000
15,600
323,800





388,502



Concrete
Thick(ft)
5
2
0.5
1.5
0.5
1.5

1.5
1.5





% Cover
100
100
100
70
100
60
0
70
70
0
0
0


CY
9,259
3,941
74
1,556
111
2,000
0
1,244
583
0
0
0
18,769
Concrete
Thick(ft)
1





% Cover
20





Cubic Yd
479

19,248



Asphalt
% Cover |Sq Yard
0
0
0
0
0
0
0
0
0
90
90
100
0
0
0
0
0
0
0
0
0
10800
10800
15600
37,200
Asphalt
% Cover
30





Sq Yard
2,157

39,357



Disposal Quantities



Assume all debris is non-hazardous.
Assume all tanks are recycled.



















Debris Volume Expansion Factors (Ratio of Disposal Volume to In-Place Volume)


Material
Concrete
Wood


Tile


Based on Pilot
Factor
2.3
4.0
3.5
5.0
1.2

demolition


Average
Project Roc



iy Mountai



Light Wood (Offices, etc)
Significant Structure Support






Estimated Cubic Yards based on Square Footage:

Type

Warehouse




NE Tank Farm
Tank Farm Bldg
WWTP

Maint/Locker Bldg
Main Process Area
Rail Siding
Loading Area Tanks
Eastern Process/Glycol
Western Road
Center Road
Road to WWTP

Concrete
Asphalt




Ratio:
cy/sqft
0.10
0.02
0.05
0.10
0.05
0.05
0.01
0.05
0.05
0.05
0.05
0.05

Assume thick (ft)=



















0.5
























n Arsenal










Disposal
Qty (cy)
5,000
0
0
0
0
0
0
0
0
0
0
0

19,248
6,559


Reductio
0
40
40
50
40



Expand
Factor
2.4
2.0
2.1
2.1
2.1
2.1
2.5
2.1
2.1
2.1
2.1
2.1
Bldg
2.3
2 2













i (%) < Transport























Sub- total


Total =









Landfill
Qty (cy)
12,000
0
0
0
0
0
0
0
0
0
0
0
12,000
44,270
14,431
70,701














Net Factor
2.3
2.4
2.1
2.5
0.72

















































Appendix C-l Cap Costs Soil Alt 2A
Demolition Qtys
Page 9 of 9

-------
          Appendix C-2



Concrete Surface Cap Cost Estimate

-------
                                                        Appendix C-2
                                             Concrete Surface Cap Cost Estimate
Concrete Cap Alternative # 2A

Area to be covered

Line Item
Mobilization
Work Plans
Equip. / Contractor Mobilization
Install Runoff Controls(silt fence)

Site Preparation
Demolition of Surface Structures
Concrete Removal
Asphalt Removal
Concrete / Asphalt Crush
Soil Removal
Storage and Replacement
Subsurface Infrastructure Removal
Overhead Utility
Dust Suppression
Materials Salvage / Recycle
Non-Haz Debris Transport/Dispose
Hazardous Debris Disposal
Soil Characterization
Soil Storage / Non-Haz Disposal
Soil Storage / Haz Disposal

Grading
Compaction

Cap Placement
Upper Layer(s)
Top Cover
Burrow Barrier
Soil Cover

993,168
110,352
Unit
Lump Sum
Lump Sum
Linear Feet


Square Foot
Cubic Yard
Square Yard
Cubic Yard
Cubic Yard
Cubic Yard
Linear Feet
Each
Square Foot
Lump Sum
Cubic Yard
Cubic Yard
Each
Tons
Tons

Cubic Yard
Cubic Yard



Cubic Yard
Cubic Yard
Cubic Yard

sqft
sqyd
Quantity
1
1
3,986


50,000
19,248
39,357
63,000
25,784
25,784
6,290
10
993,168
0
7,700
0
0
0
0

100,978
91,405



0
0
0

22.8

Unit Cost
$ 50,000
$ 80,000
$ 0.79


$ 1.00
$ 14.05
$ 6.70
$ 22.28
$ 1.87
$ 8.04
$ 3.77
$ 3,200
$ 0.01
1,000
$ 57.00
$ 257.40
$ 1,000.00
$ 60.00
$ 198.00

$ 1.40
$ 0.58



$ 22.37
$ 20.00
$ 6.97

acres

Cost
$50,000
$80,000
$3,149


$50,000
$270,432
$263,690
$1,403,640
$48,333
$207,306
$23,713
$32,000
$9,932
-
$438,900
$0
$0
$0
$0

$141,369
$53,015



$0
$0
$0



2008 Costs
$50,000
$80,000
$3,739


$50,000
$321,078
$313,073
$1,403,640
$57,385
$246,130
$25,152
$33,942
$11,792
$0
$521,096
$0
$0
$0
$0

$167,844
$62,943



$0
$0
$0
Estimated Cost Escalation Factors
2004
2005
2006
Reference
10.0%
6.0%
5.6%
Engineering Judgment
Engineering Judgment
2007
2008



0227007041000 Means (2005)




See tab Demolition Qtys



0205505542000 Means (2005)
0205505541750 Means (2005)

4.5%
1.5%
Factor =








2004 - 08
2005 - 08
2006 - 08
2007 - 08








Vendor Quotes for Unit Price with Crushed Concrete to be sprea
0222002380260 Means (2005)

0222002660040 Means (2005) times two
See tab Utilities
See tab Utilities




33080585 Means (2005) water by truck
No salvageable materials present







RBirdSection4 cost tables w S7[(S3)Excavation offsite]
Assume same rate as for haz soil and 1 cy = 1.3 tons
RBirdSection4 cost tables w S7[(S3)Excavation offsite]
RBirdSection4_cost_tables_w_S7[(S3)Excavation_offsite]
RBirdSection4 cost tables w S7[(S3)Excavation offsite]





0222002661600 Means (2005); see Dig and Cap Qty tab for amc
0222002267200 Means (2005); see Dig and Cap Qty tab for amc






18050301 Means (2005)
Engineering Judgment
17030422 Means (2005)



















130.6%
118.7%
112.0%
106.1%
Cost Base
2008
2008
2005


2008
2005
2005
2008
2005
2005
2007
2007
2005
2008
2005
2005
2005
2005
2005

2005
2005



2005
2008
2005
Appendix C-2 Cap Costs Concrete Alt 2A
Cost-Cement Cap 2A
lof 9

-------
                                                        Appendix C-2
                                             Concrete Surface Cap Cost Estimate
Line Item
Concrete
Asphalt
Membrane Layer
Drainage Layer / Base Course
Membrane Layer
Low Permeability Barrier - Clay
Low Permeability Barrier Membrane
Vapor Vent Layer - Soil
Vapor Vent Layer - Engineered
Foundation Layer

Vent Piping System

Dust Suppression
Grading
Compaction
Extraction Well Modifications
Monitoring Well Modifications
Well Abandonment

Cap Completion
Re-route potable water line
Interconnection with Barrier
Surface Runoff Controls
Establish Vegetation Cover
Access Controls - Fence Modification
Access Controls - Signs
Monitoring Network
Demobilization
Project Support
Engineering Design
Project Management
Construction Management
Unit
Square Yard
Square Yard
Square Yard
Square Yard
Square Yard
Cubic Yard
Square Yard
Cubic Yard
Square Feet
Cubic Yard

Lump Sum

Square Foot
Acres
Cubic Yard
Each
Each
Each


Linear Feet
Linear Feet
Linear Feet
Square Foot
Linear Feet
Linear Feet
Lump Sum
Lump Sum

12%
10%
8%
Quantity
110,352
0
0
110,352
0
0
110,352
42,517
0
0

1

993,168
0.0
152,869
3
11
0


2,000
3,986
1
0
3,941
3,941
0
1

of Subtotal
of Subtotal
of Subtotal
Unit Cost
$ 37.63
$ 9.60
$ 1.60
$ 11.90
$ 4.31
$ 21.56
$ 4.31
$ 10.55
$ 0.54
$ 6.97

$ 431,700.00

$ 0.01
$ 5,000.00
$ 0.58
$ 20,000
$ 4,000
$ 700


$ 38.51
$ 7.60
$ 389,000
$ 0.05
$ 2.00
$ 0.20
$ 10,000
$ 15,000
Subtotal



Cost
$4,152,075
$0
$0
$1,313,094
$0
$0
$475,617
$448,559
$0
$0

—

$9,932
$0
$88,664
$60,000
$44,000
$0


$77,022
$30,296
$389,000
$0
$7,882
$788
$0
$15,000
S 10,187,408
$1,222,489
$1,018,741
$814,993
2008 Costs
$4,929,664
$0
$0
$1,559,007
$0
$0
$564,689
$532,564
$0
$0

$ 431,700.00

$11,792
$0
$105,269
$60,000
$44,000
$0


$81,695
$35,970
$412,603
$0
$7,882
$788
$0
$15,000
S 12,140,435
$1,222,489
$1,018,741
$814,993
Reference
02750 300 0200 Means (2005) 230 mm (~9 inch) concrete
0251001040160&0380 Means (2005)

8 oz BoomEnviro (.80); 0.80 labor (Means = .74)


Adjusted 02720 200 0200 Means (2005) 200 mm (~9 inch) 40mi
30 mil BoomEnviro (3.51); 0.80 labor (Means rate = .74)
33080507 Means (2005)



30 mil BoomEnviro (3.51); 0.80 labor (Means rate = .74)
17030430 Means (2005)
33080523 Means (2005)
17030422 Means (2005)


2008 Vendor Quote














33080585 Means (2005) water by truck







RBirdSection4_cost_tables_w_S7[(S3)Excavation_offsite]
0222002267200 Means (2005)
Engineering
Engineering
Engineering


Judgment
Judgment
Judgment


See tab Utilities













10 x Poly Liner Anchor Trench 33080503 Means
See tab Runoff

0293003080400 Means (2005)
Engineering
Judgment















1 sign / 500 ft of perimeter; $100 installed = $0.20/ft

Engineering


Judgment

Past Project Experience
Past Project Experience
Past Project Experience


















Cost Base
2005
2005
2005
2005
2005
2005
2005
2005
2005
2005



2005
2005
2005
2008
2008
2008


2007
2005
2007
2005
2008
2008
2008
2008

2008
2008
2008
Appendix C-2 Cap Costs Concrete Alt 2A
Cost-Cement Cap 2A
2 of 9

-------
                                                        Appendix C-2
                                             Concrete Surface Cap Cost Estimate
Line Item
Waste Management
Contingencies
Completion Reports
Operation and Maintenance
Air Quality Monitoring, 4/y, 2 hr ea
Periodic Inspection (4/yr, engr, 8 hr ea)
Burrowing Animal Control
Mowing / Vegetation Support
Cap Repairs (concrete repair, 2%/yr)
Fence Repairs (10%)
Reporting (1/yr)

Total

Present Value of O&M


Unit
2%
15%
Lump Sum
TOTAL INST

hrs
hrs
Acre
Acre
cy
Linear Feet
hrs






Quantity
of Subtotal
of Subtotal
ALLED C(

8
32


728
399
24






Unit Cost

Subtotal
)ST

$ 100.00
$ 100.00


$ 2.30
$ 15.00
$ 100.00






Northern Area Costing Estimation
Demolition Charges

Demolition Charges with Project Support
Cap Construction Charges w/o Demolition
Per Acre Cap Construction Costs w/o Demolition
Estimated Northern Area Cap Construction Cost




$2,761,468
$4,059,357
$13,162,114
$577,286
$808,200
Cost
$203,748
$1,528,111
$4,788,082
$14,975,490

$ 800
$ 3,200


$1,675
$5,979
$ 2,400

$ 14,055

$216,054








2008 Costs
$203,748
$1,821,065
$5,081,036
$17,221,471

$ 800
$ 3,200


$ 1,675
$ 7,809
$ 3,134

$ 16,619

$255,471








Reference
Past Project Experience
EPA 540-R-98-045








engg estimate
engg estimate














Emmons, Sordyl paper, 2006






















17020701 Means (2004) + $4/ft material allowance
engg estimate































































Cost Base
2008






2008
2008

2008
2004
2008












Appendix C-2 Cap Costs Concrete Alt 2A
Cost-Cement Cap 2A
3 of 9

-------
                                                         Appendix C-2
                                              Concrete Surface Cap Cost Estimate
Excav;
Length
1200







ition Geonw
Depth
4







rtry (ft)
Width
3







Means gave cost for 6" line =



Excavation Geometry (ft)
Length
2000





Excav;
Length
5090







Depth
4





ition Geonw
Depth
4







Width
3





rtry (ft)
Width
3







Volume
CY
533







$ 36.00

Volume
CY
889





Volume
CY
2,262







Cost
$/CY
$ 5.65
$ 2.83
$ 8.48

$ 4,520

$ 3.77

/LF

Cost
$/CY
$ 5.65

$ 5,022
$ 2.51

$ 38.51
Cost
$/CY
$ 5.65
$ 2.83
$ 8.48

$ 19,172

$ 3.77

Potable V

fater Line R

emoval





General excavation from Means for 0.5 CY Excavator
Added cost for buried pipe as a percentage =
Sum











Above sum divided by linear feet
Potable Wa




ter Line ReP




lacement

























General excavation from Means for 0.5 CY Excavator


Excavation Cost
Excavation $/LF

Total $/LF
Abandoned



Utility Line






Removal















General excavation from Means for 0.5 CY Excavator
Added cost for buried pipe as a percentage =
Sum











Above sum divided by linear feet
Overhe
ad Power / P
hone
















50%



















50%












Eng Judgment






































Eng Judgment












Appendix C-2 Cap Costs Concrete Alt 2A
Utilities
Page 4 of 9

-------
                                                         Appendix C-2
                                              Concrete Surface Cap Cost Estimate




Means gives installation cost for 25' pole as


Assume removal and replacement of each pole
Assume removal at same rate as installation =
Cost factor to re-install within landfill =





3


$ 800.00

$ 800.00
$ 2,400.00
$ 3,200.00

each

each





10 power poles




Total cost per pole used in estimate




13.7 kva and phone


















Appendix C-2 Cap Costs Concrete Alt 2A
Utilities
Page 5 of 9

-------
                                                        Appendix C-2
                                              Concrete Surface Cap Cost Estimate
Desij
Cover thickness - total (b)
Cover slope (%)
*n Paran

Equivalent radius of area covered













icter

=
=



s
2.4
0.50%
560



ft

ft
























Soil
Stone


Quantity Assumptions
Excavation Swell Factor (%) :
Compaction Shrink Factor (%):
Excavation Swell Factor (%) :
Compaction Shrink Factor (%):






25%
25%
15%
15%
















Base case - No excavation
Maximum height ( h )
Fill Height (k)

e value to calculate cap vol
f-radius to calculate cap vol
Fill Volume

5.2
2.8
480
1040
ft
ft
ft
ft

Cap material volume
Maximui
n height (
Fill Height (k)
h)

e value to calculate cap vol
f-radius to calculate cap vol
Fill Volume

4.2
1.8
747
1307
ft
ft
ft
ft

Cap material volume
Perimeter dig depth (d)
Excavation width
Fill Radius


1
200
360
ft
ft
ft
Excavation Volume
Site-wide dig depth (w)
1
ft
Site-wide dig volume






Soil Cap Layer
Surface
Burrow

Barrier
Base Course
Geomembrane
Drainage






Thick
ft
0.75
0.0
0.66

0.0






X

Cover thickness + (slope * equivalent radius)
Sope * esuivalent radius

Eq radius * cover thickness / fill height
Eq radius + e- value




Fill Volume = 0.333 it (Fill ht)(Fill radius squared)





.337ih*fradiusA2 - .337ik*radiusA2 - 0.57ib(fradiusA2-radiusA2)
Cover thickn
3ss + (slope *
Sope * esuivalent radius
Se
equivalent ra

Eq radius * cover thickness / fill height
Eq radius + e- value

lected Seen
dius)



Fill Volume = 0.333 n (Fill ht)(Fill radius squared)
ario for Co




.337ih*fradiusA2 - .337ik*radiusA2 - 0.57ib(fradiusA2-radiusA2)



perimeter dig depth / slope
Equivalent radius - excavation width






Cap
Volume

(cy)
76,850
sting
Cap
Volume

(cy)
76,850



.337id*eqradiusA2 - .337id*fill radiusA2 - 0.57id(eqradiusA2-fill radiusA2)


7rw*fradiusA2

Material

Concrete
cobble





(~9 inch) 40mm stone


Sand and gravel



Estimated
Vol (cy)
23,916
0
21,046
0
0














Vol (cy) Corrected
For Compa
23,916
0
24,760

0
ction Shrink



Perimeter
Excavate
Volume
(cy)


Perimeter
Excavate
Volume
(cy)
10,705








Note - com



Site-wide
Excavate
Volume
(cy)


Site-wide
Excavate
Volume
(cy)
15,080








:rete costec



Interior
Excavate
Volume
(cy)
0

Adjust
Excavate
Volume
(cy)
24,173









1 in sq yd b



Fill
Volume

(cy)
34,056
Fill
Volume

(cy)
24,127








ased on site



Fill
Export (-)
Import (+)
(cy)


Fill
Export (-)
Import (+)
(cy)
(45)









area



Excavtn
to Fill
Ratio

0.00

Excavtn
to Fill
Ratio

1.00















Appendix C-2 Cap Costs Concrete Alt 2A
Dig and Cap Qty
Page 6 of 9

-------
                                                        Appendix C-2
                                              Concrete Surface Cap Cost Estimate
Geomembrane

Infiltration Barrier
Geomembrane
Gas Collection



Maximur



n height (
Fill Height (k)



Total -


h)

e value to calculate cap vol
f-radius to calculate cap vol
Fill Volume


0.0

1.0
2.4


3.95
1.55
867
1427
-

-


-
X
ft
ft
ft
ft

Cap material volume
Perimeter dig depth (d)
Excavation width
Fill Radius


1.25
250
310
ft
ft
ft
Excavation Volume
Site-wide dig depth (w)
0
ft
Site-wide dig volume

Soil




Sand and gravel

absent
included
Cover thickn



3ss + (slope *
Sope * esuivalent radius
0
0
0
31,888
76,850


Alte
equivalent ra

Eq radius * cover thickness / fill height
Eq radius + e- value








rnative Exc
dius)



Fill Volume = 0.333 n (Fill ht)(Fill radius squared)

0

42,517
76,850


avation Sc<




.337ih*fradiusA2 - .337ik*radiusA2 - 0.57ib(fradiusA2-radiusA2)



perimeter dig depth / slope
Equivalent radius - excavation width













marios
Cap
Volume

(cy)
76,850



.337id*eqradiusA2 - .337id*fill radiusA2 - 0.57id(eqradiusA2-fill radiusA2)


7rw*fradiusA2















Perimeter
Excavate
Volume
(cy)
15,817













Site-wide
Excavate
Volume
(cy)
0













Adjust
Excavate
Volume
(cy)
14,828














Fill
Volume

(cy)
5,777













Fill
Export (-)
Import (+)
(cy)
(9,051)














Excavtn
to Fill
Ratio

2.57







Appendix C-2 Cap Costs Concrete Alt 2A
Dig and Cap Qty
Page 7 of 9

-------
                                                                Appendix C-2
                                                    Concrete Surface Cap  Cost Estimate
            Design Rainfall (in/hr)
            Target Velocity (ft/sec)
1.5
2.5
Area
ac
11.4
11.4
C

0.45
0.95
Rainfall
(in/hr)
1.5
1.5
Q
cfs
7.695
16.245
Vel
ft/sei
2.5
2.5
   Target    Req'd     Req'd     Req'd      Cost/LF  Total /LF
                Area    Diameter  Diameter    Pipe    w/mhole
                (sqft)       (ft)       (in)
                3.078       2.0       23.8
                      Estimated linear feet  of pipe
                      Number of manholes
                      Manhole spaciing (ft)
                                                                                                                  Cost
                6.498       2.9
      4000
       10    at unit price of
      400
                                                                                    34.5
            53.5     $  54.75   $219,000   Means

             96     $  97.25   $389,000   Means
                 Manhole Costs
$ 500.00   equates to per foot     $    1.25
Appendix C-2 Cap Costs Concrete Alt 2A
                    Runoff
                                                    Page 8 of 9

-------
                                                                                                                             Appendix C-2
                                                                                                                 Concrete Surface Cap Cost Estimate
                                                                                 On Facility Area
                                                                                                                                             Acreage stated in FS Screening Report
                                                                                                                           Demolition Quantities

Item
Warehouse
NE Tank Farm
TankFarmBldg
WWTP
Maint/Locker Bldg
Main Process Area
Rail Siding
Loading Area Tanks
Eastern Process/ Glyco]
Western Road
Center Road
Road to WWTP



Remaining Area


Length
250
266
100
200
150
200
400
400
300
800
800
1300

Total
Area
SqFt
647,024


Width
200
200
40
200
40
300
60
80
50
15
15
12
Subtotal
Structure
Footprint
%
10
Totals
Bldg
?
1
0
0
0
0
0
0
0
0
0
0
0
50,000
Demo
Area
SqFt
64,702

Area
SqFt
50,000
53,200
4,000
40,000
6,000
60,000
24,000
32,000
15,000
12,000
12,000
15,600
323,800



388,502
Concrete
Thick(ft) % Cover
5 100
2 100
0.5 100
1.5 70
0.5 100
1.5 60
0
1.5 70
1.5 70
0
0
0

Concrete
Thick(ft) % Cover
1 20


CY %
9,259
3,941
74
1,556
111
2,000
0
1,244
583
0
0
0
18,769

Cubic Yd %
479
19,248
Asphalt
Cover SqYard
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
90 10800
90 10800
100 15600
37,200
Asphalt
Cover SqYard
30 2,157
39,357
                                                                                                                            Disposal Quantities
                                                                                 Assume all demolition debris is non-hazardous.
                                                                                 Assume all process columns are removed and recycled by IPP.
                                                                                 Debris Volume Expansion Factors (Ratio of Disposal Volume to In-Place Volume)
                                                                                           Based on Pilot Demolition Proj ect Rocky Mountain Arsenal
Material   Factor
Concrete
Wood
                                                                                                  2.3
                                                                                                  4.0 Average
                                                                                                  3.5 Light Wood (Offices, etc)
                                                                                                  5.0 Significant Structure Support
                                                                                                  1.2
Reduction (%) < Transport
       0
     40
     40
     50
     40
Net Factor
     2.3
     2.4
     2.1
     2.5
    0.72
                                                                                 Estimated Cubic Yards based on Square Footage:
                                                                                  Type

                                                                                  Warehouse
                                                                                  NE Tank Farm
                                                                                  TankFarmBldg
                                                                                  WWTP
                                                                                  Maint/Locker Bldg
                                                                                  Main Process Area
                                                                                  Rail Siding
                                                                                  Loading Area Tanks
                                                                                  Eastern Process/Glycol
                                                                                  Western Road
                                                                                  Center Road
                                                                                  Road to WWTP
                                                                                  Concrete
                                                                                  Asphalt    Assume thick (ft)=
                                                 Disposal  Expand
                                                 Qty (cy)  Factor
                                                     19,248
                                                     6,559
                                                                                                                                                Bldg Sub-total
                  Landfill
                  Qty(cy)
                    12,000
                         0
                         0
                         0
                         0
                         0
                         0
                         0
                         0
                         0
                         0
                  	0_
                    12,000
                    44,270
                    14.431
                    70,701
Appendix C-2 Cap Costs Concrete Alt 2A
                                                                                                                             Demolition Qtys
                                                                                                                                                                                                                                                                Page 9 of 9

-------
         Appendix C-3



Asphalt Surface Cap Cost Estimate

-------
                                                           Appendix C-3
                                                 Asphalt Surface Cap Cost Estimate
Asphalt Cap Alternative # 2A

Area to be covered

Line Item
Mobilization
Work Plans
Equip. / Contractor Mobilization
Install Runoff Controls(silt fence)

Site Preparation
Demolition of Surface Structures
Concrete Removal
Asphalt Removal
Concrete / Asphalt Crush
Soil Removal
Storage and Replacement
Subsurface Infrastructure Removal
Overhead Utility
Dust Suppression
Materials Salvage / Recycle
Non-Haz Debris Transport/Dispose
Hazardous Debris Disposal
Soil Characterization
Soil Storage / Non-Haz Disposal
Soil Storage / Haz Disposal

Grading
Compaction

Cap Placement
Upper Layer(s)
Top Cover
Burrow Barrier
Soil Cover
Concrete
Asphalt (Binder + Wearing)

993,168
110,352
Unit
Lump Sum
Lump Sum
Linear Feet


Square Foot
Cubic Yard
Square Yard
Cubic Yard
Cubic Yard
Cubic Yard
Linear Feet
Each
Square Foot
Lump Sum
Cubic Yard
Cubic Yard
Each
Tons
Tons

Cubic Yard
Cubic Yard



Cubic Yard
Cubic Yard
Cubic Yard
Square Yard
Square Yard

sqft
sqyd
Quantity
1
1
3,986


50,000
19,248
39,357
63,000
25,784
25,784
6,290
10
993,168
0
7,700
0
0
0
0

82,521
89,571



0
0
0
0
110,352

22.8

Unit Cost
$ 50,000
$ 80,000
$ 0.79


$ 1.00
$ 14.05
$ 6.70
$ 22.28
$ 1.87
$ 8.04
$ 3.77
$ 3,200
$ 0.01
1,000
$ 57.00
$ 257.40
$ 1,000.00
$ 60.00
$ 198.00

$ 1.40
$ 0.58



$ 22.37
$ 20.00
$ 6.97
$ 37.63
$ 6.36

acres

Cost
$50,000
$80,000
$3,149


$50,000
$270,432
$263,690
$1,403,640
$48,333
$207,306
$23,713
$32,000
$9,932
-
$438,900
$0
$0
$0
$0

$115,530
$51,951



$0
$0
$0
$0
$702,162



2008 Cost
$50,000
$80,000
$3,739


$50,000
$321,078
$313,073
$1,403,640
$57,385
$246,130
$25,152
$33,942
$11,792
$0
$521,096
$0
$0
$0
$0

$137,166
$61,680



$0
$0
$0
$0
$833,661
Estimated Cost Escalation Factors
2004
2005
2006
Reference
10.0%
6.0%
5.6%
Engineering Judgment
Engineering Judgment
2007
2008



0227007041000 Means (2005)




See tab Demolition Qtys



0205505542000 Means (2005)
0205505541750 Means (2005)

4.5%
1.5%
Factor =








2004 - 08
2005 - 08
2006 - 08
2007 - 08








Vendor Quotes for Unit Price with Crushed Concrete to be spread onsite
0222002380260 Means (2005)
0222002660040 Means (2005) times two
See tab Utilities
See tab Utilities




33080585 Means (2005) water by truck
No salvageable materials present












RBirdSection4 cost tables w S7[(S3)Excavation offsite]
Assume same rate as for haz soil and 1 cy = 1.3 tons

RBirdSection4 cost tables w S7[(S3)Excavation offsite]
RBirdSection4 cost tables w S7[(S3)Excavation offsite]
RBirdSection4 cost tables w S7[(S3)Excavation offsite]





0222002661600 Means (2005);Dig and Cap Qty for amnts
0222002267200 Means (2005);Dig and Cap Qty tab amnts






18050301 Means (2005)
Engineering Judgment
17030422 Means (2005)


















02750 300 0200 Means (2005) 230 mm (~9 inch) concrete
027403100080 + 027403100300 Means (2005)


130.6%
118.7%
112.0%
106.1%
Cost Base
2008
2008
2005


2008
2005
2005
2008
2005
2005
2007
2007
2005
2008
2005
2005
2005
2005
2005

2005
2005



2005
2008
2005
2005
2005
Appendix C-3 Cap Costs Asphalt Alt 2A
Cost-Asphalt Cap 2A
Page 1 of 10

-------
                                                           Appendix C-3
                                                 Asphalt Surface Cap Cost Estimate
Line Item
Membrane Layer
Drainage Layer / Base Course
Membrane Layer
Low Permeability Barrier - Clay
Low Permeability Barrier Membrane
Vapor Vent Layer - Soil
Vapor Vent Layer - Engineered
Foundation Layer

Vent Piping System

Dust Suppression
Grading
Compaction
Extraction Well Modifications
Monitoring Well Modifications
Well Abandonment

Cap Completion
Re-route potable water line
Interconnection with Barrier
Surface Runoff Controls
Establish Vegetation Cover
Access Controls - Fence Modification
Access Controls - Signs
Monitoring Network
Demobilization
Project Support
Engineering Design
Project Management
Construction Management
Waste Management
Contingencies
Completion Reports
Unit
Square Yard
Square Yard
Square Yard
Cubic Yard
Square Yard
Cubic Yard
Square Feet
Cubic Yard

Lump Sum

Square Foot
Acres
Cubic Yard
Each
Each
Each


Linear Feet
Linear Feet
Linear Feet
Square Foot
Linear Feet
Linear Feet
Lump Sum
Lump Sum

12%
10%
8%
2%
15%
Lump Sum
Quantity
0
110,352
0
0
110,352
45,642
0
0

1

993,168
0.0
155,994
3
11
0


2,000
3,986
1
0
3,941
3941
0
1

of Subtotal
of Subtotal
of Subtotal
of Subtotal
of Subtotal

Unit Cost
$ 1.60
$ 9.99
$ 4.31
$ 21.56
$ 4.31
$ 10.55
$ 0.54
$ 6.97

$ 431,700.00

$ 0.01
$ 5,000.00
$ 0.58
$ 20,000
$ 4,000
$ 700


$ 38.51
$ 7.60
$ 389,000
$ 0.05
$ 2.00
$ 0.20
$ 10,000
$ 10,000
Subtotal





Subtotal
Cost
$0
$1,102,607
$0
$0
$475,617
$481,528
$0
$0

—

$9,932
$0
$90,477
$60,000
$44,000
$0


$77,022
$30,296
$389,000
$0
$7,882
$788
$0
$15,000
S 6,534,887
$784,186
$653,489
$522,791
$130,698
$980,233
$3,071,397
2008 Cost
$0
$1,309,100
$0
$0
$564,689
$571,707
$0
$0

$ 431,700.00

$11,792
$0
$107,421
$60,000
$44,000
$0


$81,695
$35,970
$412,603
$0
$7,882
$936
$0
$15,000
S 7,804,028
$784,186
$653,489
$522,791
$130,698
$1,170,604
$3,261,768
Reference
8 oz BoomEnviro (.80); 0.80 labor (Means (2005) = .74)
02700 200 1 100 Means 150 mm crushed stone


30 mil BoomEnviro (3.51); 0.80 labor (Means (2005)= .74)
33080507 Means (2005)



30 mil BoomEnviro (3.51); 0.80 labor (Means (2005)= .74)
17030430 Means (2005)
33080523 Means (2005)
17030422 Means (2005)


2008 Vendor Quote








33080585 Means (2005) water by truck














RBirdSection4 cost tables w S7[(S3)Excavation offsite]
0222002267200 Means (2005)
Engineering Judgment
Engineering Judgment
Engineering Judgment


See tab Utilities
















10 x PolyLineAnchor Trench 33080503 Means (2005)
See tab Runoff


0293003080400 Means (2005)
Engineering Judgment




1 sign / 500 ft of perimeter; $100 installed = $0.20/ft


Engineering Judgment


Past Project Experience
Past Project Experience
Past Project Experience
Past Project Experience
EPA 540-R-98-045









































Cost Base
2005
2005
2005
2005
2005
2005
2005
2005



2005
2005
2005
2008
2008
2008


2007
2005
2007
2005
2008
2005
2008
2008

2008
2008
2008
2008


Appendix C-3 Cap Costs Asphalt Alt 2A
Cost-Asphalt Cap 2A
Page 2 of 10

-------
                                                           Appendix C-3
                                                 Asphalt Surface Cap Cost Estimate
Line Item

Operation and Maintenance
Air Quality Monitoring, 4/y, 2 hr ea
Periodic Inspection (4/yr, engr, 8 hr ea)
Burrowing Animal Control
Mowing / Vegetation Support
Cap Repairs (asphalt patch, 10%/yr)
Fence Repairs (10%)
Reporting (1/yr)

Total

Present Value of O&M


Unit
TOTAL IN


hrs
hrs
Acre
Acre
sqyd
Linear Feet
hrs






Quantity
STALLED


8
32


11,035
399
24






Unit Cost
COST


$ 100.00
$ 100.00


$ 2.00
$ 15.00
$ 100.00






Northern Area Costing Estimation
Demolition Charges

Demolition Charges with Project Support
Cap Construction Charges w/o Demolition
Per Acre Cap Construction Costs w/o Demolition
Estimated Northern Area Cap Construction Cos



t
$2,761,468
$4,059,357.28
$7,006,438.35
$307,299.93
$430,219.90
Cost
$9,606,284


$ 800
$ 3,200


$22,070
$5,979
$ 2,400

$ 34,450

$529,579








2008 Cost
$11,065,796


$ 800
$ 3,200


$ 22,070
$ 7,809
$ 2,400

$ 36,280

$557,707

$11,623,502






Reference




engg estimate
engg estimate


engg estimate






























17020701 Means (2004) + $4/ft material allowance
engg estimate











































































Cost Base




2008
2008


2008
2004
2008












Appendix C-3 Cap Costs Asphalt Alt 2A
Cost-Asphalt Cap 2A
Page 3 of 10

-------
                                                         Appendix C-3
                                               Asphalt Surface Cap Cost Estimate
Excav
Length
1200







ition Geome
Depth
4







;try (ft)
Width
o
3







Means gave cost for 6" line =



Excavation Geometry (ft)
Length
2000





Excav
Length
5090







Depth
4





ition Geome
Depth
4







Width
o
3





;try (ft)
Width
o
J







Volume
CY
533







$ 36.00

Volume
CY
889





Volume
CY
2,262







Cost
$/CY
$ 5.65
$ 2.83
$ 8.48

$ 4,520

$ 3.77

/LF

Cost
$/CY
$ 5.65

$ 5,022
$ 2.51

$ 38.51
Cost
$/CY
$ 5.65
$ 2.83
$ 8.48

$ 19,172

$ 3.77

Potable Wat

er Line Rem

oval





General excavation from Means for 0.5 CY Excavator
Added cost for buried pipe as a percentage =
Sum











Above sum divided by linear feet
Potable Water




Line RePlac




ement

























General excavation from Means for 0.5 CY Excavator

Excavation Cost
Excavation $/LF

Total $/LF
Abandoned Ut






ility Line Re






moval















General excavation from Means for 0.5 CY Excavator
Added cost for buried pipe as a percentage =
Sum











Above sum divided by linear feet



















50%



















50%












Eng Judgment






































Eng Judgment












Appendix C-3 Cap Costs Asphalt Alt 2A
Utilities
Page 4 of 10

-------
                                                         Appendix C-3
                                               Asphalt Surface Cap Cost Estimate




Means gives installation cost for 25' pole as
Assume removal and replacement of each pole
Assume removal at same rate as installation =
Cost factor to re-install within landfill =








o
J

Overhead
$ 800.00

$ 800.00
$ 2,400.00
$ 3,200.00
Power / Phor
each

each

ic



10 power poles




Total cost per pole used in estimate




13.7kvaandphone


















Appendix C-3 Cap Costs Asphalt Alt 2A
Utilities
Page 5 of 10

-------
                                                        Appendix C-3
                                              Asphalt Surface Cap Cost Estimate
Desij
Cover thickness - total (b)
Cover slope (%)
*n Paran

Equivalent radius of area covered













icter

=
=



s
1.71
0.50%
560



ft

ft
























Soil
Stone


Quantity Assumptions
Excavation Swell Factor (%) :
Compaction Shrink Factor (%):
Excavation Swell Factor (%) :
Compaction Shrink Factor (%):






25%
25%
15%
15%
















Base case - No excavation
Maximum height ( h )
Fill Height (k)

e value to calculate cap vol
f-radius to calculate cap vol
Fill Volume

4.51
2.80
341
901
ft
ft
ft
ft

Cap material volume
Maximui
n height (
Fill Height (k)
h)

e value to calculate cap vol
f-radius to calculate cap vol
Fill Volume

3.51
1.80
531
1091
ft
ft
ft
ft

Cap material volume
Perimeter dig depth (d)
Excavation width
Fill Radius


1
200
360
ft
ft
ft
Excavation Volume
Site-wide dig depth (w)
1
ft
Site-wide dig volume






Soil Cap Layer
Surface

Hot Mix Base
Base Course
Geomembrane
Drainage
Geomembrane
25mm
40mm
150mm




Thick
ft
0.083
0.131
0.492

0.0







X

-
Cover thickness + (slope * equivalent radius)
Sope * esuivalent radius

Eq radius * cover thickness / fill height
Eq radius + e- value




Fill Volume = 0.333 it (Fill ht)(Fill radius squared)





.337ih*fradiusA2 - .337ik*radiusA2 - 0.57ib(fradiusA2-radiusA2)
Cover thickn
3ss + (slope *
Sope * esuivalent radius
Se
equivalent ra

Eq radius * cover thickness / fill height
Eq radius + e- value

lected Seen
dius)



Fill Volume = 0.333 n (Fill ht)(Fill radius squared)
ario for Co




.337ih*fradiusA2 - .337ik*radiusA2 - 0.57ib(fradiusA2-radiusA2)



perimeter dig depth / slope
Equivalent radius - excavation width






Cap
Volume

(cy)
58,394
sting
Cap
Volume

(cy)
58,394



.337id*eqradiusA2 - .337id*fill radiusA2 - 0.57id(eqradiusA2-fill radiusA2)


7rw*fradiusA2

Material




Aphalt surface 1 inch
~ 1.6-inch asphalt
aphlt-tretd permble base


Sand and gravel





Estimated
Vol (cy)
2,853
4,479
16,831
0
0
0










Vol (cy) Corrected
Perimeter
Excavate
Volume
(cy)


Perimeter
Excavate
Volume
(cy)
10,705








Site-wide
Excavate
Volume
(cy)


Site-wide
Excavate
Volume
(cy)
15,080








Interior
Excavate
Volume
(cy)
0

Adjust
Excavate
Volume
(cy)
24,173









For Compaction Shrink
Fill
Volume

(cy)
34,056
Fill
Volume

(cy)
24,127









2,853 Note - asphalt costed in sq yd based on site area
4,479 Note - asphalt costed in sq yd based on site area
19,801 Note - asphalt costed in sq yd based on site .


0









irea


Fill
Export (-)
Import (+)
(cy)


Fill
Export (-)
Import (+)
(cy)
(45)
















Excavtn
to Fill
Ratio

0.00

Excavtn
to Fill
Ratio

1.00
















Appendix C-3 Cap Costs Asphalt Alt 2A
Dig and Cap Qty
Page 6 of 10

-------
                                                        Appendix C-3
                                              Asphalt Surface Cap Cost Estimate
Infiltration Barrier
Geomembrane
Gas Collection



Maximm



n height (
Fill Height (k)


Total =


h)

e value to calculate cap vol
f-radius to calculate cap vol
Fill Volume

0.0

1.0
1.71


3.2558
1.55
616
1176

-


-
X
ft
ft
ft
ft

Cap material volume
Perimeter dig depth (d)
Excavation width
Fill Radius


1.25
250
310
ft
ft
ft
Excavation Volume
Site-wide dig depth (w)
0
ft
Site-wide dig volume
Soil



Sand and gravel

absent
included
Cover thickn



sss + (slope *
Sope * esuivalent radius
0
0
34,232
58,394


Alte
equivalent ra

Eq radius * cover thickness / fill height
Eq radius + e- value







rnative Exc
dius)



Fill Volume = 0.333 TI (Fill ht)(Fill radius squared)
0

45,642
58,394


avation Sc<




.337ih*fradiusA2 - .337ik*radiusA2 - 0.57ib(fradiusA2-radiusA2)



perimeter dig depth / slope
Equivalent radius - excavation width












marios
Cap
Volume

(cy)
58,394



.337id*eqradiusA2 - .337id*fill radiusA2 - 0.57id(eqradiusA2-fill radiusA2)


7rw*fradiusA2














Perimeter
Excavate
Volume
(cy)
15,817












Site-wide
Excavate
Volume
(cy)
0












Adjust
Excavate
Volume
(cy)
14,828













Fill
Volume

(cy)
5,777












Fill
Export (-)
Import (+)
(cy)
(9,051)













Excavtn
to Fill
Ratio

2.57







Appendix C-3 Cap Costs Asphalt Alt 2A
Dig and Cap Qty
Page 7 of 10

-------
                                                        Appendix C-3
                                              Asphalt Surface Cap Cost Estimate






Design Rainfall (in/hr)
Target Velocity (ft/sec)


Area
ac
11.4

11.4






C

0.45

0.95



Rainfall
(in/hr)
1.5

1.5



1.5
2.5


Q
cfs
7.695

16.245

Estimated linear feet of pipe
Number of manholes
Manhole spaciing (ft)







Target
Vel
ft/sec
2.5

2.5

4000
10
400





Req'd
Area
(sqft)
3.078

6.498







Req'd
Diameter
(ft)
2.0

2.9


at unit price of







Req'd
Diameter
(in)
23.8

34.5


$ 500.00






Cost/LF
Pipe

53.5

96






Total /LF
w/mhole

$ 54.75

$ 97.25






Cost


$219,000

$ 389,000

Manhole Costs
equates to per foot


$ 1.25









Means

Means












2007

2007




Appendix C-3 Cap Costs Asphalt Alt 2A
Runoff
Page 8 of 10

-------
                                                         Appendix C-3
                                              Asphalt Surface Cap Cost Estimate
Total Area

Acres
22.8
SqFt
970,824


Acreage
stated in FS
Screening
Report
Demolition Quantities


Item
Warehouse
NE Tank Farm
Tank Farm Bldg
WWTP

Maint/Locker Bldg
Main Process Area
Rail Siding
Loading Area Tanks
Eastern Process/Glycol
Western Road
Center Road
Road to WWTP










Remaining Area











Length
250
266
100
200
150
200
400
400
300
800
800
1300


Total
Area
SqFt
647,024






Width
200
200
40
200
40
300
60
80
50
15
15
12
Subtotal

Structure
Footprint
%
10

Totals



Bldg
?
1
0
0
0
0
0
0
0
0
0
0
0
50,000
Demo
Area
SqFt
64,702





Area
SqFt
50,000
53,200
4,000
40,000
6,000
60,000
24,000
32,000
15,000
12,000
12,000
15,600
323,800





388,502



Concrete
Thick(ft)
5
2
0.5
1.5
0.5
1.5

1.5
1.5





% Cover
100
100
100
70
100
60
0
70
70
0
0
0


CY
9,259
3,941
74
1,556
111
2,000
0
1,244
583
0
0
0
18,769
Concrete
Thick(ft)
1





% Cover
20





Cubic Yd
479

19,248








Asphalt
% Cover |Sq Yard
0
0
0
0
0
0
0
0
0
90
90
100


0
0
0
0
0
0
0
0
0
10800
10800
15600
37,200
Asphalt
% Cover
30





SqYard
2,157

39,357



Appendix C-3 Cap Costs Asphalt Alt 2A
Demolition Qtys
Page 9 of 10

-------
                                                         Appendix C-3
                                              Asphalt Surface Cap Cost Estimate
Disposal Quantities




Assume all debris is non-hazardous.
Assume all tanks are recycled.





















Debris Volume Expansion Factors (Ratio of Disposal Volume to In-Place Volume)


Material
Concrete
Wood


Tile


Based on P
Factor
2.3
4.0
3.5
5.0
1.2

lot Demolitic


Average
mProjectR



ocky Moun



Light Wood (Offices, etc)
Significant Structure Support









Estimated Cubic Yards based on Square Footage:

Type




Warehouse
NE Tank Farm
Tank Farm Bldg
WWTP

Maint/Locker Bldg
Main Process Area
Rail Siding
Loading Area Tanks
Eastern Process/Glycol
Western Road
Center Road
Road to WWTP

Concrete
Asphalt




Ratio:
cy/sqft
0.10
0.02
0.05
0.10
0.05
0.05
0.01
0.05
0.05
0.05
0.05
0.05

Assume thick (ft)=



















0.5




















tain Arsena










Disposal
Qty (cy)
5,000
0
0
0
0
0
0
0
0
0
0
0

19,248
6,559

il
Reductio
0
40
40
50
40



Expand
Factor
2.4
2.0
2.
2.
2.
2.
2.5
2.
2.
2.
2.
2.
Bldg
2.3
2.2









n (%) < Transport























Sub-total


Total =









Landfill
Qty (cy)
12,000
0
0
0
0
0
0
0
0
0
0
0
12,000
44,270
14,431
70,701














Net Factor
2.3
2.4
2.1
2.5
0.72

















































Appendix C-3 Cap Costs Asphalt Alt 2A
Demolition Qtys
Page 10 of 10

-------
             Appendix C-4



Soil Vapor Extraction (SVE) Cost Estimate

-------
                                                                                                    Appendix C-4
                                                                                                  SVE Cost Estimat
Standard Chlorine of Delaware
Soil Vapor Extraction System
COST ESTIMATE SUMMARY
Site: Standard Chlorine of Delaware Description:
Location: Delaware City, Delaware 330,000 SF, Estimated remedial target area (12 on-facility areas, 1 off-site area)
Phase: Feasibility Study 18 FT, Assumed ROI. On-facility SVE wells installed to a depth of 50ft. Assume an overlap of 10%.
Base Year: 2008 LTM for estimated 2 year period
Date: 6/3/2008 Revised 5/8/2009
CAPITAL COSTS
DESCRIPTION
SVE Construction
Mobilization/Demobilization
Extraction & Conveyance Systems
Pilot Test
Well Installation (2" PVC with 10 slot screen X 50' deep)
Trenching and Backfill (31 wide x 3' deep)
Piping Installation (10" Diameter)
Piping Installation (2" Diameter)
Pipe Fittings
Erosion and Sediment Control
Subtotal
Soil Vapor Extraction System
SVE rotary claw system capable of 3,000 scfm at 1 0" Hg
Manifold with seven influent legs
Pneumatic activated Solenoid Valves
Air/water separator
Water Transfer Pump
Air to air heat exchanger
Air supply compressor
Control Equipment
Telemetry
Startup Assistance
Shipping
Subtotal
Remediation Building
Vapor Treatment System
GAC vessels

Granular Activated Carbon
Delivery & Installation
Subtotal
Monitoring System
Monitoring Wells (60' deep)
Well Development
Vapor Monitoring Probes (45' deep)
Subtotal
Startup/Performance Testing
Start-up and Testing
CONSTRUCTION SUBTOTAL
Contingency
SUBTOTAL
DESIGN, PERMITTING, REGULATORY (LABOR AND MISC EXPENSES)
G & A, Program Mngmt, Fee
Workplan/Remedial Design
Permits
Project Management/QC
Construction Oversight
Construction Completion Report
SUBTOTAL
TOTAL CAPITAL COST

QTY

1

1
357
17000
16600
400
1
1


1
1
7
1
1
2
1
1
1
1
1
1
1

1

18,000
1


20
20
20


1

15%


20%
15%
1%
5%
15%
1



UNIT

LS

LS
EA
LF
LF
LF
LS
LS













LS
LS

LS

LBS
LS


EA
EA
EA


LS









LS



UNIT
COST

$25,000

$50,000
$5,000
$38.85
$24.50
$4.40
$25,000
$15,000













$271,151
$80,000

$17,000

$1.07
$4,500


$10,000
$350
$6,000


$23,000




$4,296,194
$4,296,194
$4,296,194
$4,296,194
$4,296,194
$50,000

I


TOTAL

$25,000

$50,000
$1,785,000
$660,450
$406,700
$1,760
$25,000
$15,000
$2,968,910












$271,151
$80,000

$17,000

$19,260
$4,500
$40,760

$200,000
$7,000
$120,000
$327,000

$23,000
$3,735,821
$560,373
$4,296,194

$859,239
$644,429
$42,962
$214,810
$644,429
$50,000
$2,455,869
$6,752,000


NOTES

Drill rig, equip, etc., Includes HSP
Level D PPE
1 Pilot test to evaluate vacuum ROI, Re, etc.
SVE wells; 2" HOPE with 0.010 slot screen, 2" HOPE casing
VTANG quote via Matt Germon
ECI quote, HOPE (10" diameter)
ECI quote. Condensate Discharge to onsite treatment plant
sample ports, etc.
Including hay bales and/or silt fencing


National Turbine model NT1 22607


MLEE 480 gallon vapor liquid separator
Gould's N PE model 2ST - maximum flow rate of 60gpm @ 50' TDH
Xchanger Inc. with EXP motor
Champion model HR3-6. Included for pneumatic valve operation
PLC Series Direct Logic programmable logic controller & system alarms
MLE model SL-P wireless remote access


Maple Leaf Environmental Equipment Quote #801 249RO
Slab on grade, insulated, with lights, heat, and ventilation, estimated
Cost estimated from information received from Carbon Air.
Capacity of vessel is 18,000 Ib. Max flow 10,000 cfm
Virgin coconut based activated carbon, 4-8 mesh size, assumed 104lbs/lb usage
rate (replacement in O&M costs)
Estimated


2" SCH 40 316 stainless with 0.010" slot screens

1"SCH 40 31 6 stainless, three nested completions within same borehole


Equipment commissioning, performance testing, initial operations

Allowance for unidentified scope items









I

Appendix C-4 FS SVE Cost 2009 Revision
                                                                                               Standard Chlorine SVE Cost

-------
                                                                                                    Appendix C-4
                                                                                                  SVE Cost Estimat
Standard Chlorine of Delaware
Soil Vapor Extraction System
OPERATIONS AND MAINTENANCE COST
COST ESTIMATE SUMMARY


Years of operation 2
DESCRIPTION
Groundwater Monitoring
Groundwater Samples
QC Samples
Sampling Labor
Consumables
Data Validation and Management
Reporting
SUBTOTAL
Allowance for Misc. Items
SUBTOTAL
Contingency
SUBTOTAL ANNUAL COST
GAC Replacement
RCRA Characterization
GAC removal & containerization
Granular Activated Carbon
QTY

20
14
60
1
10
32

20%

15%


1
2
37,960
UNIT

EA
EA
MRS
LS
MRS
MRS






LS
LS
LBS

UNIT
COST

$150
$150
$85
$1,000
$85
$85






$1,000
$4,500.00
$1.07


TOTAL

$3,000
$2,100
$5,100
$1,000
$850
$2,720
$14,770
$2,954
$17,724
$2,659
$20,000

$1,000
$9,000
$40,617


NOTES
semi-annual (twice/year) sampling of 10 wells
VOC Analysis only
(Per Year: 4MS/MSD,4dup,3TB.3EB)
3 hrs/sample

0.5 hrs/sample




10% Scope + 20% Bid


TCLP VOC analysis, 2 total
2 change outs per year assumed
Virgin coconut, 4-8 mesh size, assumed 104lbs/lb usage rate



















T&D as RCRA haz waste above treatment standards (requires treatment prior to
GAC Transport & Disposal
SUBTOTAL ANNUAL COST
SVE System O&M
Routine System Monitoring
Equipment maintenance
Analytical Costs - Vapor
Analytical Costs - Water
Monitoring Equipment
Electricity
Other Expenses (Shipping, supplies, etc.)
Quarterly Report
Subtotal
PM and Administrative
Contingency
SUBTOTAL ANNUAL COST
PRESENT VALUE ANALYSIS

COST TYPE
CAPITAL COST
O&M COST (SVE Operation, GAC Replacement
TOTAL PRESENT VALUE
37,960


240
1
180
12
12
12
12
1




Discount Rate =



GW Sampling)

LBS


HR
LS
EA
EA
Mo
Mo
Mo
LS

10%
15%

5.0%

YEAR
0
0-2

$2.00


$90
$14,000
$235
$150
$500
$10,281
$300
$60,000





ANNUAL
COST
$6,752,000
$487,537
I
$75,920
$126,537

$21,600
$14,000
$42,300
$1,800
$6,000
$123,368
$3,600
$60,000
$272,668
$27,267
$40,900
$341,000


PRESENT VALUE
$6,752,000
$906,532
$7,700,000

landfill. Estimate based on existing contract for this service


(1 person, 2 times per month, 10 hours a day)




estimate for oil, replacement parts (belts, filters, gauges), misc tools & equip
TO-14 analysis (1 per area plus total influent & effluent (15 sam
8260 analysis for condensate discharge
PID, GEM 2000 (LEL, O2, CO2, CH4), vapor sampling pump
estimate based on power consumption, see worksheet
estimate
4 reports



does not include system decommissioning


NOTES


I
pies) per month















Appendix C-4 FS SVE Cost 2009 Revision
                                                                                               Standard Chlorine SVE Cost

-------
                                                                 Appendix C-4
                                                               SVE Cost Estimate
Standard Chlorine of Delaware SVE Treatment Areas
Soil Vapor Extraction System
Site: Standard Chlorine of Delaware
Location: Delaware City, Delaware
Phase: Feasibility Study
Base Year: 2008
Date: 6/3/2008
Treatment Area
Area
ApproximateNuinber of
SVE Points per
Treatment Area
SVE Extraction
Total Depth
(feet)
On-Facility Area
Vnit
Soil PRO On-Facility
Contamination
Volume for Soil Gas PRO On-
Facility Contamination
Off-specification product
PCB/dioxin concentration area
(RAS-1)
Catch basin #1 (RAS-2)
Former rail siding and loading
area (RAS-3/RAS-7)
Warehouse and the area to
the north of the warehouse
(RAS-4)
Facility storm drains
Drum cleaning area (RAS-5)
Northern end of eastern
drainage ditch (RAS-6)
Former wastewater treatment
plant (RAS-8)
Chemical process area (RAS-
9/RAS-10)
1986 tank collapse area
Northeast tank farm
Total On-Facility
Contamination
Square Footage
815,710

.
(feet)


10,000
10,000
65,000
60,000
5,000
10,000
10,000
35,000
50,000
10,000
65,000
330,000
11
11
70
65
5
11
11
38
54
11
70
357
50
50
50
50
50
50
50
50
50
50
50
.
Off-Site Area
Maximum "Northern Area"
Contamination
Total
60,000
390,000
59
416
50
-

Notes:
Assumed ROI is 18 feet from each SVE point
AreaofROI = PI(r2)
Surface area influenced by each SVE point = 1017.36 square feet
Northern Area Not Considered in Costing
Appendix C-4 FS SVE Cost 2009 Revision
                                                                Treatment Areas
Page 3 of 5

-------
                                                                  Appendix C-4
                                                                SVE Cost Estimate

SCO SVE Design Basis & Assumptions
   SVE Radius of Influence and Construction
       The vadose zone (0-50-ftbgs) consists of unconsolidated sand and gravel with pockets of silt and clay with a permeability of 103to 10~2
       cm/sec.
       There are no utility conflicts. Estimate does not cost provisions for removing or temporarily relocating utilities.
       All excavated soil is suitable to be used as backfill or can be incorporated into the area being capped.
       An assumed radius of influence of 18ft has been used to calculate the number of required SVE extraction points per treatment area.
       An air flow rate of 60 scfm per well is assumed to be sufficient to achieve the ROI at each SVE well.
       To treat the entire surface area it is suggested that 357 SVE extraction points are utilized throughout the treatment area assuming a 10%
       overlap of the well ROIs.
       To achieve a reasonable total air flow rate, the SVE unit has been designed to automatically cycle between 7 treatment areas.
       Approximately 42-60 SVE extraction points are located per area.
       The average flow rate of the SVE system is assumed to operate at 3,000 scfm (average 50 SVE points  per treatment area X 60 scfm)
       10" diameter HOPE is assumed to convey extracted vapor from the treatment areas to the central SVE system to minimize head loss.
       It is assumed that condensate collected from the SVE during normal operation would be pumped to and treated at the on-site water
       treatment plant
       Each SVE extraction point will consist of 2" diameter HOPE riser and screen to  a depth of 50ft


   GAC Treatment
       GAC cost and usage  rate estimates have been completed in conjunction with Carbonair's GAC usage model using soil gas
       concentrations from each treatment area
       In order to account for lower concentrations during the two year treatment period, it has been assumed that the long term average
       concentration would be 25% of the original concentrations.
       Effluent air temperature is assumed to be equal to ambient conditions
       New virgin coconut based GAC has been chosen over the less effective  and more costly "reactivated" versions of GAC
       Using average soil gas concentrations from each treatment area (see  below), the initial daily usage rate of carbon is 416 Ib/day, and long
       term average is 104 Ib/day
       A Carbonair RO-10 vessel or equivalent with a 18,000 Ib capacity and 10,000 cfm max flow rate is recommended based on the
       assumptions.

   The approximate soil gas contaminants of concern are:
       Benzene range: 120-40,000 (average 1,200) ppbv
       Carbon Tetrachloride:  75-6,600 (average 1,495) ppbv
       Chloroform: 50 - 43,000 (average 6,200) ppbv
       Tetrachloroethene: 66 -1,800 (average 410) ppbv
       1,2 Dichlorobenzene: 38,000 - 43,000 ppbv
       1,4 Dichlorobenzene: 120 - 39,000 (average 4,800) ppbv
       Trichloroethylene: 7-310  (average 83) ppbv
       Chlorobenzene: 2,700 - 160,000 (average 71,000) ppbv
Appendix C-4 FS SVE Cost 2009 Revision                               Design Basis                                                          Page 4 of 5

-------
                                             Appendix C-4
                                          SVE Cost Estimate
 Equipment Power Requirements
 SVE blower                200 HP
 A/WTranferPump           1.5 HP
 Heat exchange unit            4 HP
 Air Compressor               3 HP
           Subtotal        208.5 HP        Brake power, including pump efficiency.
           Subtotal          155 KW       Conversion of HP to kW; 1 HP = 0.7457 kW.
 Enclosure Heater             1 KW       Assumed average
 „   .   .                 -,.-„.           Factor to account for that fact that not all motors are continuous
 Service Average           75%
             3                           service

           Average          117 KW
 Electricity cost             0.12 $/KW-Hr
 Monthly Power cost    $10,281           Based on continuous service
Appendix C-4 FS SVE Cost 2009 Revision           Electric Calcs                                     Page 5 of 5

-------
               Appendix C-5



In Situ Thermal Desorption (ISTD) Cost Estimate

-------
                  HGL—Feasibility Study Report, Standard Chlorine of Delaware Site-
                                 New Castle County, Delaware
                                    APPENDIX C-5
                IN SITU THERMAL DESORPTION COST ESTIMATE
                               Dimensions and Properties
Treatment Area
Upper depth of treatment
Lower depth of treatment
Treatment volume
Porosity
330,000
-
50
610,000
0.4
square ft
ft below grade
ft below grade
cubic yards
assumed
                                   Borings and Wells
Number of HO wells
Number of HV wells
Number of monitoring holes
2800
1400
75
                                    Utility Estimate

Shake-down
Heat-up to lOOoC
Boiling phase
Heat-up to 300oC
Cooldown
Total
Days
45
117
267
309
45
783
Power Usage
Average
Power Usage,
kW
150
22,506
22,506
22,506
150

Total Power,
kWh
162,000
63,179,574
143,986,185
167,240,049
162,000
374,730,000
Natural Gas Usage
Average
Rate,
MM BTU/hr
5
2.5
1.25
1.25
5

Total, MM
BTU
5,400
7,017
7,998
9,288
5,400
35,103
Appendix C-5 FS ISTD Cost
                                     U.S. EPA Region 3
Page Iof2

-------
                   HGL—Feasibility Study Report, Standard Chlorine of Delaware Site-
                                    New Castle County, Delaware
                                  Preliminary Cost Estimate

Design and Installation
Operation
Demobilization & other
Design and permitting
Mobilization
Drill + install wells (1)
Hydraulic barrier preparation
Vapo cover installation
Electrical construction (2)
Mechanical construction
Vapor and water treatment system
Commissioning
Maintenance hardware etc.
Labor, per diem
Power
Sampling and analysis
Waste and GAC
Caustic for scrubber
Gas for oxidizer
Rental and fees
Demobilization
Reporting
Travel and office/engineering support
Licensing fees
Contigency and indirect cost
Power (3)
Total costs
Volume, cubic yards
$ per cubic yard
Total Cost, USD
$230,000
$886,000
$22,125,000
not necessary
$2,370,000
$896,000
$1,280,000
$1,454,000
$234,000
$1,497,000
$1,728,000

$294,000
$312,000
$372,000
$1,005,000
$294,000
$1,162,000
$195,000



$44,969,000
$81,303,000
612,356
$133
NOTES:
(1) "Drill+install wells" includes ISTD heaters
(2) "Electrical constuction" includes ISTD power distribution
(3) Electrical power assumed at $0.12/kWhr
Cost estimate based on vendor quote
                                        U.S. EPA Region 3
Appendix C-5 FS ISTD Cost
                                                                        Page 2 of 2

-------