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 ------- This page intentionally left blank ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 1 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 11 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 111 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report U.S. EPA Region 3 i HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report U.S. EPA Region 3 ii HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report U.S. EPA Region 3 iii HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report U.S. EPA Region 3 iv HydroGeoLogic, Inc. July 2009 ------- This page intentionally left blank ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report ES~ 1 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report ES~2 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report ES~3 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report ES~4 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 Standard Chlorine of Delaware Site Feasibility Study Report ES~5 HydroGeoLogic, Inc. July 2009 ------- 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- U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report ES~6 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report ES~7 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report ES~8 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report ES~9 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report ES~ 10 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report ES~ 11 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 Standard Chlorine of Delaware Site Feasibility Study Report U.S. EPA Region 3 ES-12 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report ES-13 HydroGeoLogic, Inc. July 2009 ------- This page intentionally left blank ------- 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1-1 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -2 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 ~3 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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: U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -4 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware • 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 10 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 ~6 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -7 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 ~8 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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). U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 ~9 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -10 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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). U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1-11 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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; U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -12 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware • 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1-13 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1-14 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -15 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -16 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -17 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1-18 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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). U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1-19 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -20 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1-21 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -22 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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). U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -23 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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); U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -24 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware • 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 1 -25 HydroGeoLogic, Inc. July 2009 ------- FIGURES ------- 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 *in:!;d!:'^ '...,: ;;orineRIFS\FS Filesii' :^:>.>:'y!/ Vewre 1-1.doc Revised: 04/30/08 CW Project: E10002.10.01 v HGL Legend Approximate Site Boundary Figure 1.1 Site Location Map Standard Chlorine of Delaware New Castle County, Delaware SCD FS Report U.S. EPA Region 3 HydroGeoLogic, Inc. 5/15/09 ------- 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 ------- 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 Source: T HGL — riyilroO ' " " 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 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 2~ 1 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 2~2 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware • 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 2~3 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 2-4 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 2~5 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 2~6 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 2~7 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 /-\ Q Standard Chlorine of Delaware Site Feasibility Study Report L~O HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 2-9 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware • 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 2-10 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 2~ 11 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 Standard Chlorine of Delaware Site Feasibility Study Report 2~ 12 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 2~ 13 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 2~ 14 HydroGeoLogic, Inc. July 2009 ------- 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 ------- 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 ------- TABLES ------- 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. I I 1' 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. ------- 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. I I 1' 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. ------- Table 2.1 Applicable or Relevant and Appropriate Requirements (ARARs) for Standard Chlorine of Delaware Operable Unit 3 (Page 3 of 9) i I I 1' 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. ------- Table 2.1 Applicable or Relevant and Appropriate Requirements (ARARs) for Standard Chlorine of Delaware Operable Unit 3 (Page 4 of 9) i I I 1' 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 ------- 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. I I i ------- 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. I I 1' 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). ------- 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. I I 1' 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. ------- Table 2.1 Applicable or Relevant and Appropriate Requirements (ARARs) for Standard Chlorine of Delaware Operable Unit 3 (Page 8 of 9) I I 1' 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. ------- 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 I I 1' 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- FIGURES ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 3-1 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 3~2 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 3~3 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 3~4 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 3~5 HydroGeoLogic, Inc. July 2009 ------- 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 3~6 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 3~7 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 3Q -O HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 3~9 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware • 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 3-10 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 3-11 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 3-12 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 3-13 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 3-14 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 Standard Chlorine of Delaware Site Feasibility Study Report 3-15 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 3-16 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 3-17 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 3-18 HydroGeoLogic, Inc. July 2009 ------- 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 3-19 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 3-20 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 3-21 HydroGeoLogic, Inc. July 2009 ------- TABLES ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 s v 3- ------- 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. s v 3- ------- 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. s v 3- ------- 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 ------- 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 s v 3- ------- 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 s v 3- ------- 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 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 4— 1 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 4-2 HydroGeoLogic, Inc. July 2009 ------- 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 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 4~5 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 4-6 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 4~7 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 4~8 HydroGeoLogic, Inc. July 2009 ------- 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 ------- 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 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 4-11 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 4-12 HydroGeoLogic, Inc. July 2009 ------- TABLES ------- This page intentionally left blank ------- 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 ------- 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 ' ' ' :::::::«:::::::: w * ; ; ; IKTI&wiflih ! ! ' 'RfeJti0i^^ii ftitu ' > > >• >*riri?*T' > >>>>>>"> ' '1» ' ' ' tvvt' ''*''*' ;;;;;; -SOilS !!!!!! ::::::::«.:::::::: ; AltftrnapYP: : : JSC0:wlth : : ::»¥E: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 ------- 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 HydroGeoLogic, Inc. July 2009 ------- 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 HydroGeoLogic, Inc. July 2009 ------- 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 HydroGeoLogic, Inc. July 2009 ------- 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 ------- FIGURE ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 5~ 1 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 5~2 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 5~3 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 5~4 HydroGeoLogic, Inc. July 2009 ------- 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); U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 5~5 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware • 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 5~6 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 5~7 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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. U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 5~8 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 5~9 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 5-10 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 5-11 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 5-12 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 5-13 HydroGeoLogic, Inc. July 2009 ------- HGL—Feasibility Study Report, Standard Chlorine of Delaware Site, Operable Unit 3 (OU-3) — New Castle County, Delaware 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- TABLE ------- 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 ------- 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 ------- 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. ------- 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 ------- 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. ------- 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. ------- 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 ------- FIGURES ------- 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 ------- 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 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 6~ 1 HydroGeoLogic, Inc. July 2009 ------- 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 U.S. EPA Region 3 Standard Chlorine of Delaware Site Feasibility Study Report 6~2 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 6~3 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 6-4 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 6~5 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 7-1 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 7~2 HydroGeoLogic, Inc. July 2009 ------- 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 Standard Chlorine of Delaware Site Feasibility Study Report 7~3 HydroGeoLogic, Inc. July 2009 ------- This page intentionally left blank ------- Appendix A PRG Detail Tables ------- 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 ------- 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 ------- 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 ------- |