Office of Solid Waste and EPA 540-R-10-013
Emergency Response January 2010
(5102G) www.clu-in.org/optimization
Remediation System Evaluation (RSE)
Alaric, Inc. Superfund Site
Tampa, Florida
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REMEDIATION SYSTEM EVALUATION
ALARIC, INC. SUPERFUND SITE
TAMPA, HILLSBOROUGH COUNTY, FLORIDA
Report of the Remediation System Evaluation
Site Visit Conducted at the Alaric, Inc. Superfund Site
April 29, 2009
Revised Report
January 27, 2010
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NOTICE
Work described herein was performed by GeoTrans, Inc. (GeoTrans) for the U.S. Environmental
Protection Agency (U.S. E.P.A). Work conducted by GeoTrans, including preparation of this report, was
performed under Work Assignment #48 of EPA contract EP-W-07-078 with Tetra Tech EM, Inc.,
Chicago, Illinois. Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.
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EXECUTIVE SUMMARY
A Remediation System Evaluation (RSE) involves a team of expert scientists and engineers, independent
of the site, conducting a third-party evaluation of site operations. It is a broad evaluation that considers
the goals of the remedy, site conceptual model, above-ground and subsurface performance, and site
closure strategy. The evaluation includes reviewing site documents, visiting the site for up to 1.5 days,
and compiling a report that includes recommendations to improve the system. Recommendations with
cost and cost savings estimates are provided in the following four categories:
• Improvements in remedy effectiveness
• Reductions in operation and maintenance costs
• Technical improvements
• Gaining site closeout
Another category related to sustainability and integrating renewable energy has also been added.
The recommendations are intended to help the site team identify opportunities for improvements. In
many cases, further analysis of a recommendation, beyond that provided in this report, may be needed
prior to implementation of the recommendation. Note that the recommendations are based on an
independent evaluation by the RSE team, and represent the opinions of the RSE team. These
recommendations do not constitute requirements for future action, but rather are provided for the
consideration of all stakeholders.
The Alaric Site is located in the Orient Park neighborhood at 2110 North 71st Street in Tampa,
Hillsborough County, Florida. The Site was undeveloped prior to 1973 and, thereafter, operated as a
number of businesses. Tetrachloroethene (PCE), trichlorothene (TCE), and other chlorinated
hydrocarbons were detected in soil and ground water in 1986. An Interim Action Record of Decision (IA
ROD) was signed in July 2002 specifying excavation, in-situ treatment with chemical oxidation, and
pump and treat (P&T). Despite these soil and source zone remediation activities, contamination remains.
At the time of the RSE site visit, the only operating remedy was the P&T system in the intermediate zone.
Additional investigation and feasibility analyses are underway for selection of the final site-wide remedy.
This RSE focuses on the effectiveness of previously conducted shallow zone remediation and
implications for potential additional shallow zone remediation, the effectiveness and efficiency of the IZ
P&T system, and an analysis of the October 2008 Technical Memorandum regarding final remedy
selection.
The observations and recommendations contained in this report are not intended to imply a deficiency in
the work of either the system designers or operators, but are offered as constructive suggestions in the
best interest of the EPA, the public, and the facility. These recommendations have the benefit of being
formulated based on operational data unavailable to the original designers.
Recommendations are provided in all four primary categories: effectiveness, cost reduction, and technical
improvement and analysis is provided related to integrating renewable energy. The recommendations for
improving system effectiveness are as follows:
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• Conservatively establish a buffer zone when communicating the extent of ground water
contamination to the State, so that the State uses this conservative extent when placing ground
restrictions in the area.
• Periodically analyze the P&T process water for constituents from the plume emanating from the
neighboring Helena Chemical Site.
• Simplify the process controls to facilitate repairs and reduce downtime.
• Monitor the specific capacity in the recovery wells to forecast potential problems with well
fouling.
• Interpret the capture zone of the P&T system.
Recommendations for cost reduction include the following:
• Modify the VOC treatment to reduce electrical usage and fouling of the injection well.
• Consider discharging treated water to the shallow zone to facilitate addressing fouling issues and
to eliminate potential concerns of discharging contaminants to the Floridan aquifer.
• Characterize the GAC again in the future to confirm that the detected radioactivity is a one-time
occurrence so that the GAC can be regenerated rather than disposed of as hazardous waste.
• Track routine O&M costs separately from non-routine costs so that routine costs can be better
controlled.
The cost savings from these recommendations are modest, resulting in approximately $14,000 per year in
savings.
The recommendation for technical improvement is focused on evaluating potential repairs that have been
suggested by the site contractor. The recommendations for site closure are a compilation of
considerations for selecting the final remedy. Cost and environmental footprint analysis is provided for
several remedial options.
Tables summarizing the recommendations, including estimated costs, savings, and effects on
sustainability associated with those recommendations, are presented in Section 6.0 of this report.
in
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PREFACE
This report was prepared as part of a project conducted by the United States Environmental Protection
Agency Office of Superfund Remediation and Technology Innovation (U.S. EPA OSRTI) in support of
the "Action Plan for Ground Water Remedy Optimization" (OSWER 9283.1-25, August 25, 2004). The
objective of this project is to conduct Remediation System Evaluations (RSEs) at selected pump and treat
(P&T) systems that are jointly funded by EPA and the associated State agency. The project contacts are
as follows:
Organization
Key Contact
Contact Information
U.S. EPA Office of Superfund
Remediation and Technology
Innovation
(OSRTI)
Jennifer Hovis
USEPA Headquarters - Potomac Yard
2777 Crystal Drive
Arlington, VA 22202
phone: 703-603-8888
hovis.jennifer@epa.gov
Tetra Tech EM, Inc.
(Contractor to EPA)
Elizabeth Powell
Tetra Tech EM Inc.
1881 Campus Commons Drive, Suite 200
Reston,VA20191
phone: 703-390-0616
Elizabeth.Powell@ttemi.com
GeoTrans, Inc.
(Contractor to Tetra Tech EM, Inc.)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
phone: 732-409-0344
dsutton@ geotransinc. com
IV
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TABLE OF CONTENTS
NOTICE i
EXECUTIVE SUMMARY ii
PREFACE iv
TABLE OF CONTENTS v
1.0 INTRODUCTION 1
1.1 PURPOSE 1
1.2 TEAM COMPOSITION 1
1.3 DOCUMENTS REVIEWED 2
1.4 PERSONS CONTACTED 3
1.5 BASIC SITE INFORMATION AND SCOPE OF REVIEW 3
1.5.1 LOCATION 3
1.5.2 SITE HISTORY, POTENTIAL SOURCES, AND RSE SCOPE 3
1.5.3 HYDROGEOLOGIC SETTING 5
1.5.4 POTENTIAL RECEPTORS 7
1.5.5 DESCRIPTION OF GROUND WATER PLUME 7
2.0 SYSTEM DESCRIPTION 9
2.1 EXTRACTION SYSTEM 9
2.1.1 SHALLOW ZONE EXTRACTION AND REINJECTION SYSTEMS 9
2.1.2 IZ EXTRACTION AND REINJECTION SYSTEMS 9
2.2 TREATMENT SYSTEM 10
2.2.1 SHALLOW ZONE SYSTEM 10
2.2.2 IZ SYSTEM 10
2.3 MONITORING PROGRAM 10
3.0 SYSTEM OBJECTIVES, PERFORMANCE, AND CLOSURE CRITERIA 11
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA 11
3.2 TREATMENT PLANT OPERATION STANDARDS 11
4.0 FINDINGS 13
4.1 GENERAL FINDINGS 13
4.2 SUB SURFACE PERFORMANCE AND RESPONSE 13
4.2.1 PLUME CAPTURE 13
4.2.2 GROUND WATER CONTAMINANT CONCENTRATIONS 14
4.3 COMPONENT PERFORMANCE 16
4.3.1 EXTRACTION SYSTEM 16
4.3.2 GRANULAR Ac TIVATED CARBON AND AIR STRIPPER 17
4.3.3 BAG FILTERS 18
4.3.4 REINJECTION WELL 18
4.3.5 SYSTEM CONTROLS 18
v
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4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF ANNUAL COSTS 18
4.4.1 UTILITIES 19
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS 19
4.4.3 LABOR 19
4.4.4 CHEMICAL ANALYSIS 19
4.5 APPROXIMATE ENVIRONMENTAL FOOTPRINTS ASSOCIATED WITH REMEDY 19
4.5.1 ENERGY, AIR EMISSIONS, AND GREENHOUSE GASES 19
4.5.2 WATER RESOURCES 20
4.5.3 LAND AND ECOSYSTEMS 21
4.5.4 MATERIALS USAGE AND WASTE DISPOSAL 21
4.6 RECURRING PROBLEMS OR ISSUES 21
4.7 REGULATORY COMPLIANCE 21
4.8 SAFETY RECORD 21
5.0 EFFECTIVES OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE
ENVIRONMENT 22
5.1 GROUND WATER 22
5.2 SURF ACE WATER 22
5.3 AIR 22
5.4 SOIL 22
5.5 WETLANDS AND SEDIMENTS 22
6.0 RECOMMENDATIONS 23
6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS 23
6.1.1 CAREFULLY DETERMINE AN APPROPRIATELY CONSERVATIVE BUFFER WHEN
INFORMING THE STATE OF PLUME EXTENT RELATED TO ESTABLISHING GROUND
WATER RESTRICTIONS 23
6.1.2 ANALYZE PROCESS WATER PERIODICALLY FOR CONSTITUENTS OF CONCERN
FROM THE HELENA CHEMICAL SITE 24
6.1.3 SIMPLIFY SYSTEM CONTROLS 25
6.1.4 MONITOR SPECIFIC CAPACITY IN RECOVERY AND REINEJCTION WELLS 25
6.1.5 INTERPRET CAPTURE 25
6.2 RECOMMENDATIONS TO REDUCE COSTS 26
6.2.1 MODIFY VOC TREATMENT 26
6.2.2 CONSIDER DISCHARGING TO THE SHALLOW ZONE 28
6.2.3 CHARACTERIZE GAC AGAIN AND INVESTIGATE SOURCE OF RADIOACTIVITY IN
AN ATTEMPT TO DISPOSE OF GAC AS NON-HAZARDOUS WASTE OR TO
REGENERATE IT 28
6.2.4 TRACK ROUTINE O&M COSTS SEPARATELY FROM NON-ROUTINE COSTS 28
6.3 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT 29
6.3.1 CONSIDER THE FOLLOWING COMMENT s TO THE MAY 2009 TECHNICAL REVIEW
BY THE SITE CONTRACTOR 29
6.4 CONSIDERATIONS FOR GAINING SITE CLOSE Our 30
6.5 RECOMMENDATIONS FOR IMPROVED SUSTAINABILITY 35
6.5.1 CONSIDERATIONS FOR RENEWABLE ENERGY AT THE SITE 35
VI
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Attachment A - Selected Figures from Previous Site Reports
Attachment B - Assumptions for Development of Approximate Carbon Footprint Estimates
Attachment C - Economic Analysis for Solar Power and Wind Power
vn
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1.0 INTRODUCTION
1.1 PURPOSE
During fiscal years 2000 and 2001 independent reviews called Remediation System Evaluations
(RSEs) were conducted at 20 operating Fund-lead pump and treat (P&T) sites (i.e., those sites
with pump and treat systems funded and managed by Superfund and the States). Due to the
opportunities for system optimization that arose from those RSEs, EPA OSRTI has incorporated
RSEs into a larger post-construction complete strategy for Fund-lead remedies as documented in
OSWER Directive No. 9283.1-25, Action Plan for Ground Water Remedy Optimization. A strong
interest in sustainability has also developed in the private sector and within Federal, State, and
Municipal governments. Consistent with this interest, OSRTI has developed a Green
Remediation Primer (http://cluin.org/greenremediation/) and as a pilot effort now considers green
remediation during independent evaluations.
The RSE process involves a team of expert hydrogeologists and engineers that are independent of
the site, conducting a third-party evaluation of the operating remedy. It is a broad evaluation that
considers the goals of the remedy, site conceptual model, available site data, performance
considerations, protectiveness, cost-effectiveness, closure strategy, and sustainability. The
evaluation includes reviewing site documents, potentially visiting the site for one day, and
compiling a report that includes recommendations in the following categories:
• Protectiveness
• Cost-effectiveness
• Technical improvement
• Site closure
• Sustainability
The recommendations are intended to help the site team identify opportunities for improvements.
In many cases, further analysis of a recommendation, beyond that provided in this report, may be
needed prior to implementation of the recommendation. Note that the recommendations are
based on an independent evaluation, and represent the opinions of the evaluation team. These
recommendations do not constitute requirements for future action, but rather are provided for
consideration by the Region and other site stakeholders.
The Alaric, Inc. Superfund Site was selected by EPA OSRTI based on a nomination from EPA
Region 4. The Site is located in Tampa, Florida. The P&T system is an interim remedy
implemented in accordance with a 2002 Interim Action Record of Decision. The interim remedy
was initiated in 2004. The site team requested an RSE to evaluate the costs associated with the
interim remedy and to provide an analysis of the Technical Memorandum Remedial Alternative
Screening that was recently prepared in association with developing a final remedy for the Site.
1.2 TEAM COMPOSITION
The RSE team consists of the following individuals:
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Name
Doug Sutton
Peter Rich
Affiliation
GeoTrans, Inc.
GeoTrans, Inc.
Phone
732-409-0344
410-990-4607
Email
dsutton@geotransinc.com
prich@geotransinc.com
In addition, the following individuals from EPA Headquarters participated in the RSE
site visit.
• Jennifer Hovis
• Jennifer Edwards
• Chip Love
1.3 DOCUMENTS REVIEWED
The following documents were reviewed. The reader is directed to these documents for
additional site information that is not provided in this report.
• Interim Action Record of Decision - July 2002
• Remedial Design Report, Shaw Environmental - September 2003
• Helena Chemical Five Year Review - January 2006
• Remedial Action Report - March 2006
• Technical Proposal, Air Emissions Modifications, GR&T Systems, Shaw Environmental
- June 2007
• Optimization Report, Fouling Issues, Shaw Environmental - July 2007
• Monthly Operating Reports, Shaw Environmental - May 2007 to September 2008
• Alaric Five Year Review - May 2008
• Remedial System Performance Evaluation, EPA ORD - June 2008
• Phase II Remedial Investigation Report, Revision 0, Intermediate Water Bearing Zone,
Black & Veatch - October 2008
• Technical Memorandum, Remedial Alternative Screening, Revision 0, Black & Veatch -
October 2008
• Tampa Electric Company 2006 - 2008
• Alaric Feasibility Study Remedy Review Meeting - April 2009
• Equipment Inspection and Photo Documentation - May 2009
• Process and Instrumentation Diagrams
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1.4 PERSONS CONTACTED
The following individuals associated with the Site were present for the visit:
Name
Galo Jackson
Chris Strzempka
Affiliation
U.S. EPA Region 4
(RPM)
Shaw Environmental
Phone
404-562-8937
Email
i ackson. salo(3),epamail. epa. sov
1.5 BASIC SITE INFORMATION AND SCOPE OF REVIEW
1.5.1
LOCATION
The Alaric Site is located in the Orient Park neighborhood at 2110 North 71st Street in Tampa,
Hillsborough County, Florida. Figure 2-1 of the October 2008 Remedial Alternative Screening
Technical Memorandum (October 2008 Technical Memorandum), which is provided in
Attachment A of this report, is an aerial photograph of the area and indicates the Site location
along with other notable features in the area. Figure 2-3 of the same report (see Attachment A) is
an aerial photograph of the Site and the neighboring properties. The Alaric Site is accessed by
71st Street along the eastern property edge. The property includes a rectangular building (Alaric
building) approximately 50-foot by 100-foot and an abutting 40-foot by 25-foot remedial
equipment building for the interim remedy. An asphalt covered parking area is located north of
the building. A limestone gravel surface covers the area northwest and west of the building. The
ground surface south of the Site building is grass covered soil. Utilities servicing the property
include overhead electric and communications, and underground municipal water. Industrial
properties surround the Site towards the east, west, and north. A sparsely wooded lot owned by
Helena Chemical is located south of the Site, followed by a CSX railroad easement trending
towards the east and west.
1.5.2
SITE HISTORY, POTENTIAL SOURCES, AND RSE SCOPE
According to the October 2008 Technical Memorandum, the Site was undeveloped prior to 1973
and, thereafter, operated as a number of businesses. Operations between 1978 and 1981 included
manufacturing, repairing, and refmishing concrete mixing equipment. Degreasing agents were
reportedly used, and the west and south sides of the property reportedly included spray-down
areas (e.g., suspected solvent source areas). From 1981 until 1992, Alaric, Inc. operated a plastics
recycling business at this location. The exact nature of the Alaric operation is unknown, but it has
been reported that PCE was stored in a bulk tank on-site for the purpose of removing paints from
plastics prior to recycling. Other businesses with different operations occupied the facility after
this period.
Tetrachloroethene (PCE) and trichloroethene (TCE) were detected in ground water in an on-site
private well (MW008) in 1986. The Florida Department of Environmental Protection (FDEP)
initiated assessment and investigation activities in 1988, and EPA began a Remedial Investigation
in 1997. An Interim Action Record of Decision (IA ROD) was signed in July 2002 specifying the
following interim action remedy components:
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• Excavation, removal, and off-site disposal of the shallow subsurface soil contamination,
septic tank and drain field
• Treatment of the deeper contaminated soils below the water table using in-situ chemical
oxidation (ISCO)
• Treatment of contaminated ground water from the surficial and intermediate aquifers by
pumping and treating (P&T)
Additional investigations were conducted in late 2002 to support the design basis of the interim
remedy.
According to the 2008 Five-Year Review, approximately 562 tons of solvent-contaminated soils
were excavated, categorized as non-hazardous, and disposed of at a permitted landfill. Consistent
with the IA ROD, the maximum depth of contaminated soil excavation was to the depth of the
water table (approximately 3 feet below ground surface). During this period, the septic tank and
related drain field components were replaced. Soil contamination identified under the building
during the septic tank replacement was left in place for treatment during the ISCO applications.
ISCO treatment occurred in two separate phases. The first phase included injection of potassium
permanganate through a surficial aquifer P&T system. The extracted water was treated and used
for make-up water for the potassium permanganate, which was injected into the reinjection wells.
The system operated for a total of 377 days between September 2003 and October 2004. Over
220,000 pounds of potassium permanganate was injected, substantially reducing soil
concentrations in the surficial aquifer. The second phase of ISCO was conducted with sodium
permanganate in two rounds, one from December 2006 through January 2007 and another in late
February 2007. The sodium permanganate solution, mixed with potable water, was gravity fed to
the surficial aquifer through two PVC galleries. Approximately 6,000 pounds of sodium
permanganate was added in the source area to the southeast of the Alaric building. Due to
concern regarding the effectiveness of the second phase of ISCO, limited soil excavation (under
30 cubic yards of soil) was conducted in Spring 2008 with the excavated material disposed of off-
site.
Despite soil and source zone remediation in the surficial aquifer, the site conceptual model
continues to include dense non-aqueous phase liquid (DNAPL) in the intermediate zone between
the surficial aquifer and the Floridan aquifer, which will provide an ongoing source of dissolved
ground water contamination.
P&T in the surficial aquifer operated into July 2008, and a intermediate zone (IZ) P&T system
continues to operate. This RSE focuses on the following items:
• The effectiveness of previously conducted shallow zone remediation and implications for
potential additional shallow zone remediation
• The effectiveness and efficiency of the IZ P&T system
• An analysis of the October 2008 Technical Memorandum
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1.5.3 HYDROGEOLOGIC SETTING
The hydrogeologic setting for the Site contains two separate aquifers: the surficial aquifer and the
Floridan aquifer. The surficial aquifer consists of undifferentiated sand and silt and is an
unconfmed aquifer of variable thickness and lateral discontinuity throughout the region. The
surficial and Floridan aquifers are separated by the semi-confining Hawthorn Group (identified at
the Site as the Intermediate Zone or IZ), and are locally interconnected by sinkholes and leaky
and discontinuous portions of the IZ. Descriptions of these formations and ground water flow
within them are as follows:
Shallow Zone: The shallow zone corresponds to the unconfmed surficial aquifer, which is
recognized by undifferentiated sand and silty sand from the land surface to the top of an
underlying semi-confining zone. At Alaric, the surficial aquifer is 10 to 20 feet thick. The
undifferentiated silty sands of the surficial aquifer lie unconformably on the top of the undulatory
surface of the semi-confining clay. Regionally, the surficial aquifer is not considered an
important water supply but can sustain yields under 10 gpm for domestic, commercial, and
community water supplies. A potentiometric surface map generated from water levels collected
in December 2002 under non-pumping conditions indicate semi-radial flow in the shallow zone
from a locally high ground water elevation in the northeastern corner of the former Alaric
property (Figure 3-4 of the October 2008 Technical Memorandum, see Attachment A). Based on
this potentiometric surface map, ground water along the eastern portion of the former Alaric
property flows to the south, ground water in along the northern portion of the property flows to
the west, and areas in between indicate a transition from southerly to westerly flow.
Upper Intermediate Semi-Confining Zone (UIZ): The top of the semi-confining zone immediately
beneath the surficial aquifer consists of clay-rich deposits of the Bone Valley Member, which is
included within the Hawthorn Group (primarily mixtures of clay, sand, and limestone). At the
Site, the Bone Valley Member is approximately 10 to 25 feet thick (e.g., from approximately 12
to 35 feet below ground surface) and is easily recognized by its characteristic greenish-gray and
occasional bluish-gray to brownish-gray color. Insufficient consistent information for the UIZ is
available to develop a useable potentiometric surface map for this interval. The 2008 Technical
Memorandum concluded that the UIZ presumably does not have sufficient soil moisture and
connected porosity to function by definition as an aquifer. The hydraulic conductivity for the
UIZ is considered to be generally less than 1 foot per day.
Middle and Lower Intermediate Semi-Confining Zone (MIZ and LIZ): The Tampa Member of
the Hawthorn Group underlies the Bone Valley Member clay in the Tampa area. At the Site, the
Tampa Member is primarily a mixture of gray gravelly calcareous clay with some competent
limestone/dolomite. At least some of the gray clay also has properties of a semi-confining unit
(similar to the overlying greenish-gray clay). The Tampa Member exists from approximately 35
to 80 feet below ground surface, although the unit may extend another 20 feet or so because of
the lack of data between 80 and 100 feet below ground surface. The bulk of the clay-rich soil in
the IZ contains little moisture, although discrete thin zones of saturation (0.1 to 2.0-ft thick) with
sand and/or gravel in the clay. Within the lower portion of the IZ, limestone interbedded in the
clay is believed to contain localized solution channels that also contribute to the distribution of
ground water. Potentiometric surface maps from May and September 2007 indicate that ground
water flow in the MIZ and LIZ are southeast and south-southeast, respectively, with an
approximate hydraulic gradient of 0.007 feet per foot. This is in the direction of the Tampa
Bypass Canal, the location of which is depicted in Figure 2-1 of the October 2008 Technical
Memorandum (see Attachment A). The results of pumping tests in 2002 and 2008 reportedly
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indicate hydraulic conductivities of 1.5 to 6.1 feet per day for the MIZ and 3.0 to 7.1 feet per day
for the LIZ.
Upper Floridan Aquifer: Consists of any ground water in competent limestone units within the
upper Floridan aquifer, as monitored by the five wells screened below 110 feet below ground
surface. Based on regional studies, this interval is comprised of Suwannee Limestone (poorly to
well-cemented limestone, with clay zones and thin chert beds). This boundary is imprecise, and
has been designated to occur at approximately 85 feet below ground surface at the Site.
Regionally, the Floridan aquifer is a highly productive aquifer and is the principal water supply
source for the Tampa area. The aquifer is over 3,000 feet thick in the Tampa area and has a
transmissivity ranging from 250,000 to over 1,000,000 square feet per day.
Figure 3-2 from the October 2008 Technical Memorandum (see Attachment A) provides an
indication of Site stratigraphy, and the following table from the same document summarizes key
hydrogeological information for the shallow zone (SA in the table) and the intervals of the IZ.
Property
Hydraulic
Conductivity, K
(average)
Potentiometric Surface
Storage Coefficient
(dimensionless)
Assumed
Porosity
Horizontal Gradient
Vertical
Gradient
Average
Linear
Velocity
ft/day
ft/year
Hydrogeologic Zone
SA
20 to 30
ft/day
-0.5 to 5
ft bis
-
0.25
0.0005-
0.003
WtoSW
-0.13to-
0.22
(ft/ft)
(SA to MIZ)
0.04 to 0.36
14 to 131
UIZ
-
~3to
14
ft bis
-
MIZ
-1.5 to
3.0
ft/day
~6to 14
ft bis
-0.0002-
0.0019
LIZ
-3.0 to 6.1
ft/day
-7 to 18
ft bis
-0.0004-
0.0062
0.35-0.45
-
-
-
-
0.003-
0.01 SE
0.004-
0.011 SSE
-0.005 to -0.027
(ft/ft, down)
0.01 to 0.17
4 to 62
Comment
Injection tests (SA); aquifer
pumping tests (MIZ + LIZ)
2002 - 2007
Pumping Tests
Based onDriscoll (1986); IZ
porosity is variable with
lithology
ft/ft
-0.06 to -0. 1 1 ft/ft gradient
from LIZ to Deep Zone
Assuming average porosity
Assuming average porosity
2008 Pumping Test
Hydraulic
Conductivity, K
(average)
Transmissivity
(ft2/day)
Storage Coefficient
(dimensionless)
-
-
-
-
-
-
5.1 to
6.1
128 to
154
0.001
7.1
143
0.0003
RW-I3 pumping test
Two MIZ wells and one LIZ
well
Two MIZ wells and one LIZ
well
* bis = below land surface
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1.5.4 POTENTIAL RECEPTORS
According to the October 2008 Technical Memorandum, appreciable ecological risks were not
identified for the Site. Rather, the focus is on protecting human health. The Floridan aquifer is a
primary source for drinking water in the Tampa area; therefore, protection of the Floridan aquifer
is a high priority. Contaminated ground water poses a potential risk due to the potential for direct
contact by construction workers, for vapor intrusion in surrounding businesses and homes, and to
potential domestic supply wells in the vicinity of the Site. No specific reference to local ground
water use was mentioned during the RSE process. A well survey was conducted in 1986 and
reportedly found that all water in the area was provided by the public water supply system.
1.5.5 DESCRIPTION OF GROUND WATER PLUME
The ground water plumes for PCE, TCE, cis 1,2-dichlorothene (c/sl,2-DCE), and vinyl chloride
in the shallow zone (April 2007) and the IZ (2007/2008) are illustrated in Figures 2-6 of the 2008
Remedial Investigation and Figures 3-11, 3-12, and 3-13 of the October 2008 Technical
Memorandum (see Attachment A). Additional shallow zone sampling was conducted in Spring
2009. The results and the implication of these results are discussed in Section 4.2.2 of this report
along with interpretations of contaminant distribution in the IZ.
The October 2008 Technical Memorandum states that the preponderance of evidence supports the
occurrence of DNAPL at the Alaric Site, although it is restricted to a twenty foot radius. The
highest PCE soil concentration (3,010 mg/kg) in the entire IZ occurred in clay-rich soil in SB-56
at 11.8 feet below ground surface in 2003 corresponding to approximately 0.5 feet beneath the
top of the UIZ. SB-137 had a concentration of 810 mg/kg at 49 feet below ground surface. In
addition, prior to the ISCO treatment of the surficial aquifer, actual DNAPL ganglia were
reportedly observed in the overlying silty sand within this same boring. Finally, DNAPL is also
evidenced by high PCE ground water concentrations in the MIZ/LIZ. For example, PCE has been
detected at 100 mg/L in MIZ well MW069 (about 66% of PCE's solubility of 150 mg/L), and at
36 mg/L in LIZ well MW068 (about 24% of solubility). The October 2008 Technical
Memorandum estimates that the total mass of PCE, TCE, cis 1,2-DCE, and vinyl chloride in soil
and ground water is just under 1,400 pounds as summarized in the following table from the
October 2008 Technical Memorandum.
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Combined Mass Estimate
Contaminated Media Zone
Intermediate Zone Impacted
Depth Interval (ft bis)
Estimated Soil Volume (yd3)
Estimated Ground water Volume (gals)
DNAPL
Defining Soil Concentration
Range (ug/kg)
Defining Ground water Concentration
Range (ug/L)
Soil Analytical Mass (Ibs)2
Soil Equilibrium Partitioning Mass (Ibs)
Ground water Analytical Mass (Ibs)
Total Mass (Ibs)
Percent total Mass
Source
Zone A
(SZA)
UIZ
MIZ
-12 to 35
-2,140
-151,600
Yes1
>5,000
-
192
NE
13
205
14.8%
Source
ZoneB
(SZB)
MIZ
-35 to 60
-820
-58,100
Yes1
>5,000
-
43
NE
70
113
8.2%
High
Concentration
Plume (HCP)
UIZ
MIZ
LIZ
-12 to 75
-2,200
-2,175,500
No
300 - 5,000
3,000 - 10,000
16
(>1,000 jig/kg)
485
125
626
45.3%
Dilute
Plume (DP)
UIZ
MIZ
LIZ
>12 to 80
-35,720
-7,215,600
No
30 - 3,000
<300
NE
378
60
438
31.7%
'DNAPL presumed or inferred
2 Soil analytical mass contains DNAPL mass in theory, but could be underreported.
NE = not evaluated
ft bis = feet below land surface; yd3 = cubic yards; gals = gallons; lbs=pounds; ug/kg = micrograms per kilogram;
ug/L = micrograms per liter
-------
2.0 SYSTEM DESCRIPTION
Two P&T systems are currently installed at the Site as part of the interim remedy specified in the 2002 IA
ROD. The shallow zone P&T system was activated in September 2003 and was used for the first phase
of ISCO injections. ISCO injections were discontinued in October 2004. The system continued to
operate until it was shut down in July 2008 to observe plume behavior after the limited source excavation
conducted during Spring 2008. The IZ P&T system was also activated in September 2003 and operation
continues.
2.1 EXTRACTION SYSTEM
2.1.1 SHALLOW ZONE EXTRACTION AND REINJECTION SYSTEMS
The shallow zone extraction system (which no longer operates) addressed two plumes, one emanating
from the northwestern portion of the property and one emanating from the southeastern portion of the
property. Four recovery wells are located near the northwestern plume. For the southeastern plume, the
extraction system is a series of three rows/trenches of well points oriented perpendicular to ground water
flow along the length of the shallow zone plume as depicted in Figure 2-6 of the October 2008 Remedial
Investigation (see Attachment A). The reinjection system (which also no longer operates) is comprised of
two rows/trenches of well points located between the extraction "trenches" to inject/mobilize
permanganate and to separate "exfiltration" galleries to otherwise discharge treated water. Extraction is
performed via an eductor system comprised of the following components:
• Feed tank
• Two 15 HP pumps (that alternately operate)
• Drop tubes with valves and pressure gauges in each well point
• Eductor for each well point
• Piping and manifold vaults
In addition to the injection points and "exfiltration" galleries, the reinjection system consists of a 10 HP
effluent pump, valves, and piping.
During operation, the average extraction/discharge rate was approximately 10 gpm.
2.1.2 IZ EXTRACTION AND REINJECTION SYSTEMS
The IZ extraction system consists of four recovery wells each fitted with a 0.5 HP variable speed
submersible pump. The design basis suggested a total recovery rate of 11 gpm from the wells; however,
pumping from one of the recovery wells has been discontinued to prevent drawing in the plume from the
neighboring Helena Chemical Site and/or pulling contamination down from overlying zones. Reinjection
is accomplished through a 6-inch injection well installed into the Floridan aquifer. The system has
typically operated at approximately 8 gpm but at the time of the RSE site visit the extraction rate was
approximately 4 gpm.
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2.2 TREATMENT SYSTEM
2.2.1 SHALLOW ZONE SYSTEM
The shallow zone treatment system (not currently operating) consists of the following components:
• 1.5 HP feedpump
• Two bag filter units arranged in parallel
• Two 1500-pound granular activated carbon (GAC) units arranged in series
• four-tray ShallowTray 2641 tray stripper with a 7.5 HP blower
• 10 HP effluent pump
2.2.2 IZ SYSTEM
The IZ treatment system consists of the following components:
• Three 1,000-pound granular activated carbon (GAC) units arranged in series
• QED EZ Stacker 2.3P three-tray air stripper rated for 1 to 25 gpm with a 2 HP blower
• 1.5 HP feedpump
• Two bag filter units arranged in parallel
2.3 MONITORING PROGRAM
Ground Water Monitoring
There is no formal ground water monitoring program with a set number of wells and set frequency. Most
recent sampling has been conducted to either evaluate the effects of source remediation in the shallow
zone or as part of the final Remedial Investigation for the Site initiated in 2007.
Process Monitoring
Process monitoring for the shallow zone system was discontinued when system operation was
discontinued in July 2008. Intermediate process monitoring includes VOC analysis for samples collected
from each of the three operating recovery wells, influent to each of the GAC units, air stripper influent,
air stripper effluent, and bag filter (system) effluent on a quarterly basis.
10
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3.0 SYSTEM OBJECTIVES, PERFORMANCE, AND
CLOSURE CRITERIA
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA
The IA ROD for the Alaric Site identified the following Remedial Action Objectives (RAOs):
• Treat and-reduce concentrated source materials (in soil) below the water table to a total
chlorinated VOC concentration ranging from 100 ug/kg to 1,000 ug/kg.
• Remove VOC contaminated soils in the unsaturated zone in the vicinity of the septic system drain
field and other related areas for off-site disposal.
• Contain, collect, treat, and dispose of VOC-contaminated ground water.
• Perform this work in a manner that is compatible with the ground water remediation planned for
the Helena Chemical Superfund Site.
The IA ROD stated "that implementation of this IRA should reduce the amount of future loading of
contaminants from the source materials to the ground water, contain the horizontal and vertical migration
of the ground water plume, and reduce the total mass of contaminants in the ground water. Remedial
components specified in the IA ROD were not intended to restore the aquifer nor to attain the MCLs.
A Final Remedial Investigation has been completed and the October 2008 Technical Memorandum has
screened potential remedial options for the Site. The table on the following page, from the October 2008
Technical Memorandum, summarizes cleanup standards that would apply to the Site and also includes
standards for co-mingled contaminants from the neighboring Helena Chemical Superfund Site that are not
specific chemicals of concern for the Alaric Site.
3.2 TREATMENT PLANT OPERATION STANDARDS
The treatment standards for discharging the treated water to the Floridan aquifer reinjection well are the
FDEP Groundwater Cleanup Target Levels indicated in the table on the following page.
11
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Chemicals of Concern - Alaric Site
Chemical
PCE
TCE
cis-l,2-DCE
Vinyl chloride
Manganese
Maximum
Valuei
(fig/L)
100,000
6,700
14,000
1,000
860
EPA
MCL
(MS/L)
5
5
70
2
none
FDEP Soil
Leaching
SCTL (ug/kg)
30
30
400
7
SPLP
FDEP Soil
Residential
Direct
Exposure
SCTL (mg/kg)
8.8
6.4
33
0.2
3,500
FDEP
Ground
Water
GCTL
(MS/L)
o
J
3
70
1
50
FDEP Natural
Attenuation
Default
Concentration
(|Ag/L)
300
300
700
100
500
Co-Mingled COCsfrom Helena Chemical
Sulfate
Iron
Arsenic
Chromium
(total)
Nickel
Alpha - BHC
Beta - BHC
Delta - BHC
Gamma - BHC
MCPP
1,300,000
15,000
7
29
0.550
0.31
0.28
0.014
62
-
-
10
100
-
-
-
-
-
-
-
SPLP
SPLP
38,000
130,000
0.3
1
200
9
0.03
-
53,000
2.1
210
340
0.1
0.5
24
0.7
64
250,000*
300*
10
100
100
0.006
0.02
2.1
0.2
7
-
3,000
500
1,000
1,000
0.6
2
21
20
700
1 Maximum value detected in IZ or Floridan aquifer
MCL = Maximum contaminant level (EPA, 2003)
* = Secondary drinking water standard
FDEP = Florida Department of Environmental Protection
SCTL = Soil Cleanup Target Level (FDEP, 2005)
GCTL = Groundwater Cleanup Target Level (FDEP, 2005)
SPLP = Synthetic Precipitation Leaching Procedure
ug/kg = micrograms per kilogram
mg/kg = milligrams per kilogram
ug/L = micrograms per liter
BHC = hexachlorocyclohexane
MCPP = potassium salt of propionic acid
12
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4.0 FINDINGS
4.1 GENERAL FINDINGS
The observations provided below are not intended to imply a deficiency in the work of the system
designers, system operators, or site managers but are offered as constructive suggestions in the best
interest of the EPA and the public. These observations have the benefit of being formulated based upon
operational data unavailable to the original designers. Furthermore, it is likely that Site conditions and
general knowledge of ground water remediation have changed over time.
The findings in this section are limited to the results of the shallow zone interim remediation efforts and
the ongoing IZ P&T system. The performance of the shallow zone system when it operated is not
discussed.
4.2 SUBSURFACE PERFORMANCE AND RESPONSE
4.2.1 PLUME CAPTURE
Plume capture in the shallow zone is not discussed because there is no active remediation occurring in
this zone since the discontinuation of pumping in July 2008.
The design basis for the IZ system included ground water modeling that suggested 11 gpm would be
required for plume capture. Figure K-18 from the Remedial Design (see Attachment A) suggests capture
of the 1,000 ug/L plume but not necessarily complete capture of the 100 ug/L plume. A target capture
zone was not specified, but given that the depicted pumping scenario was selected as the design basis, the
illustrated degree of capture is apparently sufficient to meet objectives. The model calibration upon
which this simulation was conducted is questionable for the IZ (referred to as the Floridan at the time of
the Remedial Design). Figure K-7 from the Remedial Design (see Attachment A) plots the simulated
heads against observed heads, and it is clear that the plot does not follow the intended 1:1 trend. Rather,
the simulated heads are low relative to the observed heads, and simulated capture may not be accurate.
Additional model development and calibration incorporating actual pumping scenarios from the recovery
wells (such as comparing observed versus simulated drawdown) has not occurred since this initial effort
conducted as part of the design basis.
Plume capture was evaluated by EPA Office of Research and Development (ORD) in June 2008 but did
not include a review of the design basis. The average extraction rate considered during this evaluation
was 8.1 gpm. The evaluation concluded that insufficient coverage of water level measurements was
available to accurately interpret capture and a sufficient record of observed VOC trends in downgradient
monitoring wells was not available to accurately interpret capture. Using a transmissivity of 100 ft2/day,
a hydraulic gradient of 0.01 feet per foot, and a pumping rate of 2.7 gpm, the evaluation included sample
capture zone width calculations that suggested that capture in the vicinity of RW-I2 might be sufficient.
The RSE team would have used the following parameters for the analysis based on the information
provided in the October 2008 Technical Memorandum:
13
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• Transmissivity - 145 ft2/day (average of four similar values from the PS001 pumping test during
design)
• Hydraulic gradient - 0.007 ft/ft
• Pumping rate (for one well) - 2.7 gpm (equal to one third of the 8.1 gpm)
• Factor to account for heterogeneity and contributions from above and below - 2.0
Based on these values and an assumed flow direction to the southeast, the estimated capture zone width
using the simplified capture zone width calculation would be approximately 250 feet wide for one well,
which would be sufficient to capture the portion of the 3,000 ug/L contour that is upgradient of RW-I2
and much of the 300 ug/L contour shown in Figures 3-12 and 3-13 of the October 2008 Technical
Memorandum (see Attachment A). Similar extraction rates from RW-I1 and RW-I3 would likely provide
capture of the 300 ug/L contour that is upgradient of the recovery wells. Some portion of the 300 ug/L
contour that has already migrated downgradient of the recovery wells might not be captured. This is only
one line of evidence based on a calculation that relies on many simplifying assumptions (e.g.,
homogeneous aquifer). Given the heterogeneity at the Site and the contributions of water to the IZ from
the shallow zone, additional lines of evidence should likely be considered if capture of a specific target
capture zone is stipulated.
Other potential lines of evidence include interpreting ground water flow directions from potentiometric
surface maps, observing concentration trends in wells downgradient of the extraction system, and
utilizing an appropriately calibrated ground water flow model. The potentiometric surface map and
capture zone interpretation presented in Figure 7-10 of the October 2008 Technical Memorandum (see
Attachment A) may not be a reliable line of evidence. Contrary to recent guidance (A Systematic
Approach to Evaluating Capture Zones at Pump and Treat Systems, EPA 600-R-08-003), Figure 7-10
utilizes water levels from active extraction wells to assist in developing the potentiometric surface map.
Because water levels are often substantially lower in active extraction wells than in the surrounding
aquifer, using water levels from active extraction wells can lead to substantially overestimating drawdown
associated with pumping. In Figure 7-10, this overestimation appears to have lead to extrapolating the
15.50-foot contour to the downgradient side of the extraction wells and establishing a ground water divide
that is over 100 feet downgradient of the wells. Therefore, as it currently stands, this line of evidence is
not reliable. As stated by ORD, there is also not enough of a historical ground water quality record to
evaluate capture zone effectiveness based on concentration trends in downgradient wells.
The RSE team is confident that the extraction rate of 4 gpm at the time of the RSE site visit provides
substantially reduced plume capture compared to that provided by an extraction rate of 8 gpm. In
addition, although 8 gpm may provide adequate capture if this flow rate is maintained, it may not provide
adequate capture if the flow rates are unequally distributed among the wells (RW-2 is expected to only
pump 2 gpm vs. 3 gpm from RW-1 and RW-3), if the plume is not necessarily migrating to the southeast
(see discussion below), if there is substantial downtime such that the average flow rate over time is much
lower, or if a continuing source of dissolved phase contamination is entering the aquifer beyond the extent
of the capture zone (see discussion below).
4.2.2 GROUND WATER CONTAMINANT CONCENTRATIONS
Shallow Zone
VOC data collected from shallow zone monitoring wells in Spring 2009 indicate substantial
contamination remains in the shallow zone. The following results are noteworthy.
14
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Well
MW28R
MW047
MW048
MW056
MW057
PCE
(ug/L)
14,000
3,200
15,000
0.16
12,000
TCE
(ug/L)
3,600
130
350
12
150
cis 1,2-DCE
(ug/L)
1,200
190
290
38
220
Vinyl Chloride
(ug/L)
38
11
<100
30
74
In addition, MW056 had total VOC concentrations over 20,000 ug/L in April 2007. Based on the
location of this well approximately 120 feet from the source area, high concentrations (noted in the table
above) continue to exist between the source area and this well, and given the absence of ground water
remediation in the vicinity of MW056 since April 2007, the RSE team believes it is unlikely that the
observed contamination has been remediated to the degree suggested in the table above. A more
plausible scenario is that discontinuing pumping in the shallow zone has redirected ground water flow in
the vicinity of this well and that the contamination now follows a flow path that is not intercepted by this
well. Consistent with this hypothesis is an increase in the concentrations at MW027 (albeit not as large as
the decrease observed at MW056), suggesting that some of the high-level contamination that previously
migrated toward MW056 has been shifted toward MW027.
MW28R, MW048, and MW057 are all located in the immediate vicinity of the source area where
remedial activities were previously performed. Given that VOC concentrations in these wells are
comparable to the concentrations detected in 2007 and concentrations in these wells and are still in excess
of 10,000 ug/L suggests that source area was not completely remediated. MW047 is located
approximately 60 feet downgradient of the source area and concentrations have decreased to the above
values from a total VOC concentration of 19,170 ug/L in April 2007. Given the observed 2009
concentrations in the other wells noted above, the RSE team believes that the decrease in observed
concentrations between April 2007 and Spring 2009 are also potentially the result of a change in ground
water flow patterns as described above for MW056.
Despite the relatively high density of wells in the shallow zone to the southwest, it does not appear that
the extent of contamination in the shallow zone has been thoroughly delineated to the southwest. Prior to
remediation, total VOC concentrations over 50,000 ug/L were detected as far downgradient as MW009
(over 200 feet from the source area). The concentrations in the two wells immediately side gradient of
MW009 (MW051 and MW058) were substantially lower, suggesting a narrow plume. Total VOCs in
MW058 did not exceed 3 ug/L and total VOCs in MW051 did not exceed 151 ug/L. RW-29, which is
approximately 75 feet downgradient of MW009 had a total VOC concentration of over 9,000 ug/L before
remediation, but MW052 and MW055 which are only 50 feet apart and straddle the flow path between
MW009 and RW029 had historical total VOC concentrations that did not exceed 100 ug/L, confirming
that the plume remains highly concentrated and narrow. MW015 and MW016, which are southwest of
RW029 are also likely sidegradient of the plume core in the shallow zone. Based on the total VOC
concentration of over 1,000 ug/L at MW015 in 2003 and undetectable values at MW016, it is likely that
the plume migrated closer to MW015 than to MW016, but it is also likely that MW015 is not necessarily
within the plume core.
Access downgradient of MW-15 is severely restricted due to industrial buildings and an active railroad.
Although wells MW038, MW039, and MW040 have been installed downgradient of MW015, it is
unlikely that the required density of points could reasonably be installed to find and delineate the plume
in this area. Therefore, continuing uncertainty may remain about the magnitude and extent of
contamination in this area and its potential to migrate downward into the IZ.
15
-------
As indicated in Figures 3-6, 3-7, and 3-11 through 3-13 from the October 2008 Technical Memorandum
(see Attachment A), the VOC plume in the IZ does not have a shape that would be expected based on the
observed potentiometric surface. Ground water flow is to the southeast (MIZ) or south-southeast (LIZ),
but total VOC concentrations exceeding 300 ug/L have been detected over 200 feet side-gradient to the
southwest. The plume extent to the southwest (sidegradient to ground water flow) is greater than the
plume extent in the direction of ground water flow. In addition, the plume extends to the east-southeast
toward (and past) the Helena Chemical property further than it extends to the southeast or south-
southeast.
The plume extent to the southwest in the IZ appears to be related to downward migration of
contamination from the shallow zone. Similar to the above findings for the shallow zone, plume
delineation to the southwest in the IZ also appears to be incomplete but access is difficult for a
comprehensive delineation effort. The plume extent to the southeast toward the Helena Chemical
property is not easily explained by the interpreted hydraulic gradient or Alaric-related contamination
migrating downward from the shallow zone. One possible explanation is the orientation for the plume
extent in this area is a combination of the hydraulic gradient and the orientation of the permeable zones
that are present within the generally lower permeable material of the IZ. Another possible explanation is
that there may be insufficient water level measurement points to the east in the shallow zone or IZ to
accurately interpret the ground water flow direction. It is possible that additional water level
measurements to the east of the Alaric property could result in interpreting a flow component in this
direction.
Contamination exceeding the FDEP GCTL and natural attenuation criteria is also present in MW059,
located in the northwest portion of the property. This contamination is presumably related to secondary
source area and shallow zone contamination in this portion of the property. As of the April 2007
sampling, the VOC concentrations in the shallow zone in this area appear to have been significantly
reduced to below the FDEP natural attenuation levels.
4.3 COMPONENT PERFORMANCE
The performance of the primary treatment components are discussed below. As a general note, major
process equipment appears to be functioning as intended, but process instrumentation (such as
flowmeters, pressure gages, etc.) and various fittings are in general disrepair and/or are missing.
4.3.1 EXTRACTION SYSTEM
The extraction system has historically maintained the design value of 8 gpm for RW-I1, RW-I2, and RW-
13 until recently. At the time of the RSE site visit, the low flow of 4 gpm was reportedly due to problems
with a recovery pump fitting and the flow meters. These problems are likely easily addressed, but had not
been addressed.
RW-I4 has not been operated due to concerns of pulling in contamination from the Helena Chemical
Superfund Site and due to concerns of pulling contamination down from overlying formations. This
reasoning is unclear. The treatment system can address the VOCs and pesticides from the Helena
Chemical Site with GAC, and based on figures provided in Appendix E of the Alaric Remedial Design
(see Attachment A), the Helena sulfate plume in the surficial aquifer is above the FDEP GCTL as far as
RW-I1 such that it would be extracted by RW-I1, RW-I2, and RW-I3 just as easily as it would be by RW-
16
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14. Metals concentrations in the vicinity of the RW-I4 (see Attachment A) are low enough that they
would likely not result in an exceedance of the discharge criteria if extraction was maintained at all four
recovery wells. More thorough evaluation of the Helena Chemical plume in both the shallow zone and IZ
is merited. Process sampling of the Alaric IZ system indicates low levels of pesticides from the Helena
Chemical plume that are present in the influent but removed by the GAC. In addition, sampling
associated with the reinjection well fouling analysis indicated influent sulfate concentrations of
approximately 240 mg/L, which is consistent with intercepting some of the plume from the Helena
Chemical Site. With regard to pulling VOC contamination down, the PCE concentrations in the LIZ are
lower but comparable to those of the UIZ and MIZ in the area of RW-I4. RW-I4 screens both the MIZ
and the LIZ. The concentrations in the LIZ, albeit lower than those of the MIZ and UIZ are comparable
(e.g., 80,000 ug/L and 88,000 ug/L in the UIZ in 2005 and 2007, and 37,000 ug/L and 100,000 ug/L in
the MIZ in 2005 and 2007 compared to 22,000 ug/L and 36,000 ug/L in the LIZ in 2005 and 2007).
These concentrations in all three zones are close to the solubility of PCE (approximately 150,000 ug/L,
Groundwater Chemicals Desk Reference, Lewis Publishers, 1989), suggesting that product and high
dissolved contaminant concentrations are present in all three zones.
4.3.2 GRANULAR Ac TIVATED CARBON AND AIR STRIPPER
GAC was originally included in the treatment train because it would be able to address the VOC
contamination at the Alaric facility but also the pesticides and VOCs associated with the Helena Chemical
plume, if those constituents were present in the process water. An air stripper was not included in the
original treatment system, but was added after system operation began when influent concentrations were
higher than expected. The air stripper was originally placed in front of the GAC units, which is the
common approach. Although air permit conditions were met, complaints from a resident regarding
potential impacts to local air quality led to moving the air stripper behind the GAC so that air emissions
would be substantially reduced. The air stripper currently is able to provide polishing to the GAC
effluent, especially for those compounds, such as vinyl chloride, that breakthrough quickly.
The current process is to change the GAC when there is breakthrough of any one target compound,
including vinyl chloride, which breaks through significantly faster than the other target compounds. This
measure of conservatism is reportedly used due to concern that the air stripper may fail and that treated
water is discharged directly to the Floridan aquifer. The influent to each of the GAC units and the
influent to the air stripper (i.e., the effluent from the final GAC unit) are sampled monthly to evaluate
breakthrough.
Due to prior concerns regarding air quality, the emissions of VOCs from the air stripper off-gas are also
calculated monthly.
No pressure gauges are currently provided on the GAC units to evaluate the pressure drop across each of
the units.
The GAC and air stripper have functioned as intended; however, the GAC from a previous changeout
tested positive for radioactivity, which precluded it from being regenerated. The GAC was disposed of as
a hazardous waste to the EQ facility in Michigan. The radioactivity is not believed to be a site-related
contaminant of concern, and is not expected to recur.
17
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4.3.3
BAG FILTERS
The bag filters are intended to remove solids to prevent the reinjection well from fouling. The bag filters
are changed on a weekly basis. The pressure gauges on the bag filter units do not read accurately.
4.3.4
REINJECTION WELL
The reinjection well has fouled repeatedly as a result of carbonate precipitation from the aeration of the
process water in the air stripper. The reduced performance of the well has led to substantial system
downtime, including from January 2008 to June 2008. Previous rehabilitation efforts have included acid
injections and overdrilling the well.
4.3.5
SYSTEM CONTROLS
The system is controlled by a PLC with a human machine interface that allows for remote system
operation and records system data every 10 minutes. Many features that are easily controlled manually
are automated, and this automation (though intended to provide efficient operation) has led to many
operational problems. For example, the variable frequency drives on the influent pumps have not been
able to maintain a set point, and the flow rates from the wells have been controlled by throttling. The
variable speed drives appeared to be off during the RSE site visit. Problems with the flow meters on each
of the influent lines have further complicated recording flow rates and controlling extraction rates since
extraction is controlled by a set point with feedback from the flow meters.
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
ANNUAL COSTS
O&M costs are approximately $186,000 per year on a move forward basis for operating the IZ system.
An assumed breakdown of the operational costs is provided below based on the general cost information
provided by the site team (which also included other activities) and professional judgment by the RSE
team.
Item Description
USAGE oversight
Routine project management, quarterly system reporting
O&M labor
Electricity
GAC purchase and regeneration
Supplies/services for routine maintenance
Non-routine maintenance (e.g., well rehabilitation)
Ground water sampling (assume annual event with 45 wells)
Annual ground water report
Total Estimated Annual Cost
Approximate Annual Cost
$36,000
$36,000
$40,000
$7,000
$5,000
$12,000
$15,000
$20,000*
$15,000*
$186,000
* These items are not specifically included in the O&M program to date but would likely be
included in future years of operation.
18
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4.4.1 UTILITIES
The utility costs have varied over the past several years due to previous operation of the shallow zone
treatment system and extensive shutdown periods due to reinjection well fouling. The estimated cost for
electricity is based on average electricity usage of approximately 60,000 kWh per year at approximately
$0.12 per kWh, including demand charges, fees, and taxes. The estimated usage of 60,000 kWh is based
on the total 2008 electrical usage and is comparable to what would be expected for operation of the
specified motors, plus lighting, and air conditioning (for the electronics in the control room).
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS
The GAC cost is based on two 1,000-pound change outs per year on a cost of approximately $1,000 per
mobilization and $1.50 per pound of material (including regeneration). This translates to a yearly cost of
approximately $5,000 per year.
The RSE team has estimated the routine and non-routine maintenance costs based on professional
judgment and experience with similar systems.
4.4.3 LABOR
Labor costs, including USAGE oversight, are estimated based on the specified level of effort for operator
labor for the IZ system (8 hours per week at a rate of $75 per hour estimated by the RSE team plus
approximately 25% additional time for maintenance), approximate historical annual costs for USAGE,
and an estimate by the RSE team of reasonable costs for project management and monthly reporting for
the IZ system only. These estimated costs, along with the costs for the other fields appear to generally
agree with the historical costs for the Site, when extracting other site activities, including operation of the
Shallow system.
The cost for ground water sampling is based on sampling 4 to 5 wells per day and an average cost of
$2,000 per day for field labor, equipment, and supplies.
4.4.4 CHEMICAL ANALYSIS
Chemical analysis is not included in the above table because analyses are provided by the Contract
Laboratory Program and are not billed to the Site. If the costs were billed to the Site, it is estimated that
the analytical costs would be on the order of $4,000 per year for the current process monitoring program
and approximately $5,000 per year for annual sampling of 45 wells for VOCs.
4.5 APPROXIMATE ENVIRONMENTAL FOOTPRINTS ASSOCIATED WITH
REMEDY
4.5.1 ENERGY, AIR EMISSIONS, AND GREENHOUSE GASES
The annual emissions for carbon dioxide for the current system are presented in Table 4-1. Energy usage
and emissions for sulfur dioxide, nitrogen oxides, and particulate matter are not calculated because they
are assumed to generally scale with carbon dioxide emissions because, like carbon dioxide, the primary
source is the combustion of fossil fuels. Fossil fuels are the primary source of energy used at this site;
19
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therefore, carbon dioxide emissions are an indication of the energy footprint. Efforts to reduce the carbon
footprint would be assumed to reduce the footprints for energy and these other pollutants. The emissions
of hazardous air pollutants associated with the site would primarily result from air stripper off-gas or
vapor intrusion. These items are discussed in section 5 of this report in the context of protecting human
health and the environment.
Item
Energy
Electricity
Diesel (GAC disposal)
Gasoline
Energy subtotal
Materials
GAC
Other materials (bag filters,
disposables)
Materials subtotal
Waste Disposal
Hazardous waste disposal for GAC
Disposal subtotal
Other Services
Well rehabilitation
Laboratory analysis
Other services subtotal
Treatment Process Emissions
Air stripper off-gas
Process emissions subtotal
P&T System Total
Carbon Footprint
(Ibs CO2e/yr)
76200
616
2166
78982
4000
5000
9000
27.5
27.5
10000
9000
19000
0
0
107009
Percent Contribution
of Carbon Footprint
71%
1%
2%
74%
4%
5%
9%
0%
0%
9%
8%
17%
0
0
100%
ye/yr = carbon dioxide equivalents per year
4.5.2
WATER RESOURCES
The remedy operations have a limited effect on water resources beyond the attempts to remediate the
aquifers. Water that is extracted and treated (approximately 4 million gallons annually if the system is
operating continuously) is reinjected into the Floridan aquifer for beneficial use. However, preserving
this discharge option comes at significant effort and resources to maintain the injection well.
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4.5.3 LAND AND ECOSYSTEMS
Remedy activities have a limited affect on the surrounding land and ecosystems. The area surrounding
the Site is industrial in nature with the exception of the wooded lot to the south of the Site. Although
wells and piping have been installed in this area, the area has been largely left unaffected since remedy
construction in 2003. The wells are only occasionally accessed by foot for system checks, minor repairs,
and ground water sampling.
4.5.4 MATERIALS USAGE AND WASTE DISPOSAL
GAC represents the principal material that is used on-site and disposed of off-site. A historic GAC
characterization sample indicated radioactivity and precluded the GAC from being disposed of locally as
a non-hazardous waste or from being regenerated. As a result, the GAC is hauled approximately 1,200
miles to Belleville, Michigan and is handled as a hazardous waste. On a move-forward basis with the
existing system, the RSE team would expect two GAC changeouts per year with used GAC being
regenerated.
4.6 RECURRING PROBLEMS OR ISSUES
The primary recurring issues with the Site are the disrepair of process instrumentation and the fouling of
the reinjection well. The site team has recently made an inventory of problematic instrumentation and
appears to have identified a successful method for well rehabilitation. It is likely that continued use of the
reinjection well will require continued maintenance and/or frequent (e.g., once per year) rehabilitation
efforts.
4.7 REGULATORY COMPLIANCE
The system has complied with its discharge requirements. There is no air permit for the air stripper off-
gas.
4.8 SAFETY RECORD
No health and safety issues were identified during the RSE site visit, and the site visit began with an
appropriate health and safety tailgate meeting.
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5.0 EFFECTIVES OF THE SYSTEM TO PROTECT HUMAN HEALTH
AND THE ENVIRONMENT
5.1 GROUND WATER
Ground water is impacted at the Site in the shallow zone and in the IZ but does not appear to pose an
immediate risk to human health. Site-related contamination has not been found above FDEP GCTL
standards in the Upper Floridan Aquifer. A historic well survey suggests no wells are used in the vicinity
of the Site, but these findings have apparently not been confirmed since 1986.
5.2 SURFACE WATER
The Tampa Bypass Canal is the closest surface water body to the Site, and it is located sufficiently far
downgradient that it is unlikely to be affected by site-related contamination.
5.3 AIR
Air quality could potentially be affected by site-related contamination through either the air stripper off-
gas if breakthrough occurs through all three GAC units or through soil vapor intrusion. As the system
currently operates, VOC emissions from air stripper off-gas would not typically be measureable. During
GAC breakthrough, VOC emissions would be several orders of magnitude lower than the emission rates
that would require an air permit. With regard to soil vapor intrusion, the site team reports evaluating this
potential exposure pathway during the Human Health Risk Assessment using the Johnson-Ettinger Model
and concluding that the non-cancer hazards and cancer risks for the current industrial worker exposed to
surface soil and indoor air were below the threshold of concern. The total HI was reportedly less than 1
and the total cancer risk was reportedly less than 1E-4. Under future land-use scenarios, the risk was
above the level of concern.
5.4 SOIL
Unsaturated soil remediation has generally been conducted to the FDEP standards, and that soil which has
not been remediated would be addressed as part of the final remedy. In the interim, contaminated soil is
not readily accessible for direct exposure by those working above ground. Residual contamination
appears to be present in soil beneath the water table that contributes to an ongoing source of dissolved
ground water contamination.
5.5 WETLANDS AND SEDIMENTS
These media are not affected or potentially affected by Site contamination.
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6.0 RECOMMENDATIONS
Cost estimates provided herein have levels of certainty comparable to those done for CERCLA Feasibility
Studies (-30%/+50%), and these cost estimates have been prepared in a manner consistent with EPA 540-
R-00-002, A Guide to Developing and Documenting Cost Estimates During the Feasibility Study, July,
2000. The costs and sustainability impacts of these recommendations are summarized in Tables 6-1 and
6-2.
Many of the recommendations provided below assume that the system will continue to operate for several
years as an interim remedy or may become part of the final remedy for the Site. If the final remedy does
not include P&T and the final remedy is expected to occur within a few years, then the following
recommendations should be evaluated to determine if the costs and resources of implementing them are
worthwhile given the short-term nature of the P&T system.
6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS
6.1.1 CAREFULLY DETERMINE AN APPROPRIATELY CONSERVATIVE BUFFER WHEN
INFORMING THE STATE OF PLUME EXTENT RELATED TO ESTABLISHING GROUND
WATER RESTRICTIONS
Remediation of the plume between the southwest injection trench (200 feet downgradient of the source
area) and the southwest recovery trench (300 feet downgradient of the source area) appears to have been
effective. However, it is possible that total VOC concentrations exceeding 10,000 ug/L had already
migrated beyond this target area of remediation. This contamination could continue to migrate
horizontally within the shallow zone or could migrate downward into the IZ. The RSE team believes that
the current extent of contamination in the IZ is the result of contamination that had migrated horizontally
in the shallow zone before migrating downward to the IZ. The VOC contamination in the IZ also appears
to not be fully delineated to the southwest. RW-I1 appears to be the furthest well from the source area to
the southwest and has total VOC concentrations over 500 ug/L.
Based on the limited access due to the active railroad, it is likely that these plumes to the southwest will
not be fully delineated or remediated. Given the current and projected land use as a rail yard, it is
unlikely that ground water in this area will be used. EPA is reportedly negotiated a Memorandum of
Agreement (MOA) with the Southwest Florida Water Management District (SFWMD) to provide an
institutional control that restricts the use of contaminated ground water at "off-site" (off source property),
non-liable properties. The MOA was signed by EPA in September 2008. In the MOA, EPA agrees to
provide the SWFMD information on the extent of ground water contamination and the SFWMD agrees to
use their authority to deny any well construction permit application that will cause harm to public health
or degradation of the aquifer.
The RSE team suggests that EPA provide carefully determine a buffer zone that extends beyond the
known extent of ground water contamination to include the unknown extent and expected future extent of
ground water contamination. This may involve some analytical transport modeling with BIOSCREEN,
BIOCHLOR, or a similar program. Using a very simplistic analysis, the RSE team observes that a
concentration of 2,400 ug/L of total VOCs was present in LIZ well MW-18 as early as 2000 (and perhaps
earlier). If the release of PCE occurred at the beginning of the Alaric occupation of the property in 1981,
then the average transport would have been approximately 20 years. MW-18 is located approximately
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300 feet or more from the source area, suggesting and average transport rate of 15 feet per year in the IZ.
If the release from Alaric occurred later during their occupation, then the average transport rate in the IZ
would be faster. Transport velocities in the shallow zone are much higher than the IZ, and PCE
concentrations exceeding 3,000 ug/L likely exist in the shallow zone beyond the area of historic remedial
activities. The hydraulic properties summarized in Section 1.5 of this report suggest an unretarded
seepage velocity as high as 131 feet per year in the shallow zone. The contamination observed at
existing monitoring wells in 2000 has had an additional nine years of transport, suggesting that it may
have migrated another 135 feet (9 years times 15 feet per year) in the IZ and 1,179 feet (9 years times 131
feet per year) in the shallow zone. As important, the observed concentrations of 2,400 ug/L in MW-18 or
similarly high concentrations in the shallow zone are substantially higher than the FDEP GCTL for the
respect constituents. Concentrations above the FDEP GCTL have likely migrated much further than these
estimated distances, especially when considering dispersion. Migration will likely continue into the
future because some of this contamination that migrated this far from the source area may not be
addressed by the remedy. A more thorough analysis of contaminant transport may provide a better
estimate of an appropriate buffer zone. In conducting this analysis, the hydraulic and contaminant
transport properties of the shallow zone and IZ should also be considered.
The cost of this effort should be less than $10,000 and could be included as part of other documents being
prepared as part of the final remedy selection.
6.1.2 ANALYZE PROCESS WATER PERIODICALLY FOR CONSTITUENTS OF CONCERN
FROM THE HELENA CHEMICAL SITE
Concern has been documented by the Alaric Site team regarding potential impacts to the Alaric P&T
system from the Helena Chemical plume. This concern is partially responsible for not operating one of
the Alaric recovery wells. Conditions at both sites have changed over the past several years, and some
remedial activities have occurred at the Helena Chemical property. Process sampling of the Alaric system
for the Helena Chemical constituents as late as 2004 suggested that the system extracts low levels of
pesticides that are treated by the GAC. In addition, analysis of samples from MW011 and MW019
indicated low levels of pesticides above the FDEP GCTL. RW-I3, which continues to operate, extracts
ground water from this vicinity.
Given changing site conditions and the current discharge of treated water to the Floridan aquifer, the RSE
team recommends continuing to sample the process water for pesticides and other constituents (perhaps
arsenic and chromium) from the Helena Chemical plume to confirm they are appropriately treated prior to
discharge. Initially, this monitoring should include sampling the influent, between the various GAC
vessels, and the effluent. Once influent concentrations and treatment performance is documented, the
sampling could be reduced to after the second GAC vessel and the effluent to document when
breakthrough occurs and the quality of the water entering the Floridan aquifer.
The additional analyses would likely be analyzed by the CLP program and not charged to the site. The
RSE team notes; however, that the typical cost of analyzing for pesticides plus two metals is
approximately $100 per sample. The cost of implementing this recommendation will vary on the ultimate
frequency that the samples are collected. If three samples are collected and analyzed monthly for the first
6 months, this would translate to an approximately cost of $1,800. Thereafter, if two samples are
collected and analyzed quarterly, then the annual cost would be approximately $800 per year. The RSE
team would not expect the GAC changeout frequency to increase.
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6.1.3 SIMPLIFY SYSTEM CONTROLS
The main system components consisting of submersible well pumps, three 1000-pound GAC vessels in
series, a small tray type air stripper, bag filters and an injection well are very simple and should be
straightforward to operate with minimal downtime. However, system downtime has been relatively high,
reducing the overall effectiveness of the system. Part of the problem is that the system has relatively
complex electronic control and monitoring equipment, and when the equipment malfunctions it requires
excessive time to fix or the equipment is allowed to remain non-functioning.
In particular, the controls for the well pumps should be simplified. The electronic flow meters should be
replaced with mechanical totalizers that can be monitored during weekly site visits, and the pump control
should be provided by simpler means such as the Pumpsaver® pump control or Warrick-type conductivity
control sensors that allow the pumps to cycle on and off periodically. Cycling can be minimized by
throttling the valves or by using small variable frequency drives that are manually set rather than adjusted
automatically by the PLC. Due to the fairly small motors, the cost savings from using the variable
frequency drives would be fairly low (less than $1,000 per year), but the carbon dioxide emissions from
reduced electricity usage might be on the order of 5,000 to 10,000 pounds per year. Making these
changes might cost $5,000 in materials and up to $10,000 in labor and/or subcontractors for planning,
wiring, and reworking the PLC programming.
6.1.4 MONITOR SPECIFIC CAPACIT YIN RECOVERY AND REINEJCTION WELLS
Well fouling can occur and get progressively worse without operator knowledge if the specific capacity of
a well is not regularly monitored. Specific capacity (gallons per minute extracted/reinjected per foot of
drawdown) should be monitored quarterly to determine if more drawdown is required to achieve the same
extraction rate. If the specific capacity decreases, it is an indication of well fouling, and well maintenance
or rehabilitation will likely be more successful during the early stages of fouling than in the later stages.
The additional level of effort and time for this measurement is negligible relative to existing site activities
and costs, and can be performed within the existing O&M budget.
6.1.5 INTERPRET CAPTURE
Assuming that this remedy may continue to operate for some time, perhaps to contain and remediate the
dilute portion of the VOC plume as a component of the site-wide final remedy, the capture zone
interpretation should be revisited and the extraction rates modified accordingly. A target capture zone
would presumably be developed as part of remedy selection. This will likely require additional
delineation efforts to the east (on the far side of the Helena Chemical Site).
A thorough capture zone has not been conducted to date. Potentiometric surface maps have been
developed based on water levels, and these potentiometric surface maps indicate capture. However, the
maps were developed using water levels from active recovery wells, which biases the potentiometric
surface in favor of capture. A more comprehensive capture zone analysis would include developing
potentiometric surface maps without this source of bias and potentially also using a recalibrated site
model.
The ground water model used during design appeared to have a shortcoming in the model calibration for
the intermediate zone. There is now infrastructure available (i.e., recovery wells) that can be used to
provide more information for model calibration. Prior to collecting this information, however, the site
team should invest in new piezometers in the shallow zone, MIZ, and LIZ near RW-I1, RW-I2, and RW-
13 (there are already wells close enough to RW-I4). These piezometers can be used to develop
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informative potentiometric surface maps that are free from the bias of using water levels from active
recovery wells and help understand the contributions of water from the various intervals. In addition,
these piezometers will be located sufficiently close to the recovery wells to provide useful information
during pumping tests. Without these piezometers, it is unclear if the drawdown from pumping at the
recovery wells will be sufficiently large to see in existing monitoring wells given the distance of these
monitoring wells from the recovery wells. With the piezometers installed, aquifer testing with the
existing extraction system is suggested according to the following general procedure:
• Increase extraction rate back to the intended value of 8 gpm (if using RW-I1 through RW-I3) or
11 gpm (if using RW-I-1 through RW-I4).
• Operate at the intended extraction rate for a period of one month to achieve steady conditions
• Shutdown all operating extraction wells for one week and record water levels with pressure
transducers in MW011, MW060, MW063, MW061, MW019, MW023, MW024, MW017, and
MW018
• Restart RW-I3 at its intended rate while continuing to record water levels
• Restart RW-I2 several days later at its intended rate while continuing to record water levels
• Restart RW-I1 several days later at its intended rate while continuing to record water levels
• Recalibrate the model using the transient drawdown results from the above testing. The model
should be used to simulate the results of the transient pumping, and a defensible calibration
should be achieved.
• Create a steady-state version of the model that can be used to simulate the intended pumping rates
and use forward particle tracking (with particles released from all cells within the capture zone) to
observe capture
• Use the steady-state model to simulate other potential flow rates for either achieving capture at a
lower flow rate or to improve capture.
The above analysis, including piezometer installation (3 in the shallow zone, 3 in the MIZ, and 3 in the
LIZ), collecting the data (but not including additional monitoring wells that might be needed for
delineation), model calibration, simulations, and reporting should cost under $100,000 (e.g., $45,000 for
the piezometers, $15,000 for the hydraulic testing, $20,000 for model calibration, and $20,000 for
simulations and reporting). The model would also be available to simulate capture or other hydraulic
performance criteria for various pumping and reinjection scenarios.
6.2 RECOMMENDATIONS TO REDUCE COSTS
6.2.1 MODIFY VOC TREATMENT
The treatment system currently includes two treatment technologies for removing VOCs from extracted
water: air stripping and adsorption with liquid phase GAC. It is common to include GAC as a polishing
step to air stripping, and GAC was originally selected as the primary treatment technology because it also
26
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would remove pesticides from the Helena Chemical plume if they were present in the extracted water.
The use of air stripping and liquid phase GAC at the Site is counter to typical practice (i.e., the GAC is
placed before the air stripper at this Site), but complaints resulting from the potential VOC off-gas from
the air stripper has resulted in the site team placing the GAC before the air stripper so that the GAC
provides the majority of mass removal and the air stripper provides redundancy to remove contaminants
(especially vinyl chloride) when they breakthrough the GAC. This redundancy is preferred because the
treated water is discharged directly to the Floridan aquifer.
Air stripping at this site has a caused a number of problems within fouling as indicated in the July 24,
2007 optimization report on fouling issues. The aeration of the water increases the pH and causes
calcium carbonate scale to form. This scaling reportedly fouled the GAC when GAC treated the air
stripper effluent, and now that the water from the air stripper directly discharges to the injection well, the
scaling has reportedly been fouling the injection well. The RSE team believes that regardless of the
treatment or discharge component that follows the air stripper, fouling will occur unless that water is
softened or otherwise treated prior to air stripping.
Due to the concerns regarding VOC emissions and the problems with scaling, the site team if could
consider using GAC as the only treatment technology for contaminant removal. However, data from June
2007 through October 2007 suggests that each GAC unit might only last approximately 30 days until
vinyl chloride breakthrough if the system is operating at approximately 8 gpm. The GAC needs to remain
a component of the treatment process to address the constituents from the Helena Chemical plume. As a
result, one of two modifications could be made:
• One option is to continue to operate the system in its current arrangement, but make two
modifications. First, the site team could reduce the air flow rate of the air stripper blower so that
it only provides the air to water ratio needed to address the vinyl chloride that breaks through.
Second, the site team could add an acid drip (before or after the air stripper) to maintain a pH
below 7 (but above 6) to prevent the scaling from occurring. This option would likely require
two liquid phase GAC changeouts per year, some acid usage, and slightly reduced electricity
usage than is presently used. This option would result in minimal air emissions (orders of
magnitude lower than those that would cause a human health concern or that would require an air
permit) and reduced or eliminated scaling of the bag filters and injection well.
• The second option is to move the air stripper prior to the GAC, pre-heat the air stripper off-gas,
treat the air stripper off-gas with vapor phase GAC, add an acid drip to reduce scaling, and polish
the air stripper effluent with liquid phase GAC to address the contamination from the Helena
Chemical plume. This option would likely require increased electricity usage compared to the
present system, one or two vapor GAC changeouts per year, and likely one liquid GAC
changeout per year. The liquid GAC changeouts would likely result from fouling rather than
chemical loading, because although scaling would be reduced, it likely would be sufficient to
decrease GAC performance and increase the pressure across the GAC unit over the course of a
year. This option would result in similar air emissions to the current system or the above option
because the vinyl chloride would not be well addressed by the GAC. It would also result in less
scaling of the reinjection well relative to the current system.
The cost for implementing the first option would be approximately $10,000. This cost includes a
chemical feed pump with controller, 500 gallon HDPE tank for acid, pH probe and transmitter, variable
frequency drive for the blower, installation costs, and design costs. The acid addition might cost $1,000
to $2,000 per year but is difficult to estimate. The RSE team estimates that this option might save
approximately $1,000 per year in electricity costs (which should offset the acid addition costs) and should
either eliminate or greatly reduce the frequency of injection well rehabilitation, which would be a savings
27
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of approximately $10,000 per year. Regarding the environmental footprint, the RSE team expects that the
acid usage and electricity reductions might offset each other, and that the overall footprint may be
reduced by the footprint for the well rehabilitation.
6.2.2 CONSIDER DISCHARGING TO THE SHALLOW ZONE
The fouling of the reinjection well has caused a number of problems with regard to extended system
shutdown and with regard to costly rehabilitation efforts. In addition, discharge to the Floridan aquifer
raises concern within the site team regarding water quality. The concern regarding discharging the water
to Floridan aquifer could be avoided if the treated water is discharged to the shallow aquifer. Reinjection
galleries and piping is already present. The concerns regarding scaling of the injection well will also
apply to the shallow zone injection, but should be addressed if Recommendation 6.2.1 is implemented.
Furthermore, if scaling of the shallow zone reinjection system does occur, it would likely be less costly to
rehabilitate than the reinjection well. This option has previously been considered, but uncertainty
regarding the shallow zone remedy prevented further consideration.
Based on the most recent sampling results, it appears that active remediation will likely be needed for the
shallow zone source during the final remedy, but there should be enough capacity in the "exfiltration"
galleries and in the downgradient reinjection trenches to accommodate the treated water from the IZ.
Because the piping and trenches are already in place, the cost for making this change should be under
$5,000. If Recommendation 6.2.1 is not implemented, the RSE team estimates that the cost savings might
be on the order of $5,000 per year, assuming that some form or reduced reinjection system maintenance is
required instead of the more costly injection well rehabilitation. In the absence of implementing
Recommendation 6.2.1, this should also reduce the environmental footprint associated with well
rehabilitation by, perhaps 5,000 pounds of carbon dioxide per year (based on the emission factor in Table
4-1).
6.2.3 CHARACTERIZE GAC AGAIN AND INVESTIGATE SOURCE OF RADIOACTIVITY IN
AN ATTEMPT TO DISPOSE OF GAC AS NON-HAZARDOUS WASTE OR TO
REGENERATE IT
The spent GAC is being disposed of as hazardous waste due to the presence of radioactivity. Based on
the discussions at the site visit, this was an unexpected finding given site conditions. If repeated
characterization samples suggest radioactivity is present, then the site team should consider what the
causes might be. They could be site-related (e.g., naturally occurring), which may lead to a consideration
during final remedy selection, or they might be vendor related, which may lead to using another vendor.
If the detection of radioactivity was a one-time anomalous event, then efforts should be made to either
regenerate the spent GAC or dispose of it locally as a non-hazardous waste. This could reduce cost and
improve remedy sustainability by reducing materials and the emissions footprints associated with the
materials. The benefits could be significantly multiplied if the remedy operates long-term and/or focuses
on more aggressive mass removal. The sustainability benefits are not calculated because the footprint
associated with GAC disposal (including diesel for transportation) is apparently minor according to the
results Section 4.5.1 that are included in Table 4-1. The cost savings (assuming current GAC usage)
might be on the order of $4,000 per year (e.g., approximately $2,000 per changeout).
6.2.4 TRACK ROUTINE O&M COSTS SEPARATELY FROM NON-ROUTINE COSTS
Tracking routine O&M costs regularly can help provide cost control, identify cost increases, and
potentially address cost increases. However, if the routine costs are masked or obscured by additional
items such as additional remedial activities, pilot tests, additional investigation, or technology screening,
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it is difficult to reliably track the O&M costs. The RPM should track the O&M costs separately and
preferably track O&M labor costs separately from O&M materials costs. Contractor invoices or cover
letters can be requested to provide information in this format so that it is easy to track. This cost for
making this change should be negligible relative to other project management activities.
6.3 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT
6.3.1 CONSIDER THE FOLLOWING COMMENTS TO THE MAY 2009 TECHNICAL REVIEW
BY THE SITE CONTRACTOR
The May 2009 Technical Review by the contractor included photographs of current equipment, an
inventory of equipment in need of replacement, and suggestions for simplifying system operation. In
general we agree with the recommendations presented in the referenced letter. However, we consider
this a relatively simple system with clear issues and we believe many of the recommendations listed in the
letter could be resolved immediately based on existing information rather than as part of future work
products. More specific comments are as follows:
• We agree that an O&M manual with monitoring log(s) and maintenance procedures for the
operators should be developed. The monitoring log sheet should include depth to water (could be
checked manually), discharge pressure and flow rate at each well, total system flow rate, pressure
at GAC units and bag filters, air pressure and flow at the air stripper (if it continues to operate)
and pressure at the reinjection point.
• We agree that the PLC and HMI should be updated to reflect the operating system and as-built
documents as listed in Section 4.2 of the 5/27/2009 Shaw letter should be compiled and
maintained at the Site.
• The existing treatment equipment is functioning and fit for continued use. Multiple minor
components should be added, fixed, replaced, or possibly removed if no longer needed (such as
the pressure transducers in the wells if the pump control options discussed in Section 6.1.5 are
adopted). This type of maintenance, such as adding or replacing pressure gages, should be
occurring on an ongoing as-needed basis by the system operator and should be noted in the
quarterly reports.
• Treated water discharge requirements are known and it is clear that the current GAC with or
without air stripping treatment units can meet these requirements at design flow rates. We do not
believe that a final design document and work plan are needed for re-configuration activities. Any
re-configuration activities could be adequately documented in the regular quarterly reports.
• Problems such as the "flow problem" noted at RWI3 should be addressed on an immediate as-
needed basis by the system operator/site team. The site team should pull the pump from the well
and clean and replace any damaged/leaking fittings or pipe.
• Although mixing Schedule 40 and Schedule 80 PVC is not standard, there is no reason based on
the system pressure to replace all of the pipe with Schedule 80 PVC. The mixed schedule piping
would have the Schedule 40 rating. Schedule 40 PVC has a minimum pressure rating of >200 psi
for diameters less than 4 inches and the maximum system pressure is less than 125 psi based on
the maximum head of the Grundfos 5SQE03A-180-NE currently utilized.
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If the hose and camlock fittings used for connecting to the GAC units and bag filters are rated for
over 75 psi (GAC vessel rating) and are not leaking, we recommend maintaining them and
supporting them properly instead of replacing them with Schedule 80 PVC. The hose and
camlocks are preferable for ease of changeouts, flexibility of GAC location and durability. If the
hose is not rated for 75 psi, other flexible hose with that pressure rating is available and could
easily replace the current hose.
We agree that the bag filters should be kept in parallel configuration.
6.4 CONSIDERATIONS FOR GAINING SITE CLOSE OUT
The October 2008 Technical Memorandum provides a reasonable site conceptual model and an estimate
of contaminant mass in the subsurface. It also provides a comprehensive review of many potential
remedial options. We have the following general comments that apply.
• The high sulfate (approximately 250 mg/L) and its impact on in-situ bioremediation is not as
significant a concern as noted in the document. Although sulfate is a competing electron acceptor
to the chlorinated ethenes, the predominant factor controlling the mass of electron donor
(nutrients) added is the adsorptive capacity of the soil. The stoichiometry, including the sulfate,
contributes insignificantly to the overall mass that would need to be added. The RSE team
recently evaluated the Grants Chlorinated Solvents Site where in-situ bioremediation was pilot
tested and will be used in the final remedy. The sulfate concentrations at that Site are over 2,000
mg/L and in-situ bioremediation performed well where the microbe population was sufficient and
donor was effectively added.
• The RSE team favors mass removal and hydraulic containment type approaches to the source
zone remedy, compared to physical isolation with slurry walls and caps, particularly given the
relatively small size of the source zone and the amount of mass that has already migrated from
the source zone to the high concentration and dilute portions of the plume.
• The calculated treatment volumes (e.g., source zone A, source zone B, the high concentration
plume, and the dilute plume) do not appear to add up based on the areal extent of the zones, the
maximum depths of contamination, and the estimated number of injection points, etc. for
remediation. Specific examples are provided below:
o The source zone A and B are reported to have a total volume of approximately 3,000
cubic yards of soil and a volume of ground water (in gallons) that is consistent with this
soil volume and a porosity of 0.35. However, the areal extent multiplied by only 20 feet
of thickness (which is less than the maximum thickness of source zone A only, yields a
volume of 4,600 cubic yards. More importantly, the large diameter auger remedy
assumes 370 locations assuming a 6-foot diameter auger. Again assuming a thickness of
20 feet, this volume is over 7,500 cubic yards. The injection-related remedies assume 70
injection locations, each with a diameter of 12.5 feet. Once again, assuming a thickness
of 20 feet (which does not account for any of source zone B), the volume is over 6,500
cubic yards.
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o The reported volume for the high concentration plume is also questionable. The areal
extent appears to be approximately 20,000 square feet, and the thickness based on most
assumptions in the document is approximately 45 feet. This resulting volume minus
approximately 5,000 cubic yards for the source zone would correspond to a volume of
28,000 cubic yards compared to the 2,200 cubic yards reported in the Technical
Memorandum. Furthermore, the reported ground water volume (1,927,300 gallons) does
not correlate to the soil volume (2,200 cubic yards) the same way it did for the source
zones. Converting 1,927,300 gallons into cubic yards and then accounting for porosity
would yield approximately 27,000 cubic yards not 2,200 cubic yards.
o The volume calculation for the dilute plume is also questionable because of how the soil
volume and ground water volumes compare. Converting the reported gallons in the
dilute plume (7,215,600 gallons) directly to cubic yards (35,720) using 27 cubic feet per
cubic yard yields 35,720 cubic yards, but porosity has not been accounted for. Based on
a preliminary review of Figure 3-12 from the Technical Memorandum, the total area of
the dilute plume (excluding the source zone and high concentration plume) appears to be
approximately 92,000 square feet. Assuming an average thickness of 20 feet (which is a
fraction of the total thickness of the MIZ and LIZ) is impacted above target levels for
active remediation, the total volume for the dilute plume (excluding the source zone and
high concentration plume) would be approximately 68,000 cubic yards.
It is suggested that these volumes be revisited and that if they are deemed to be correct that more
transparency be provided in how the volumes were calculated. Contaminant mass estimates may
also need to be revisited.
• Cost information is not provided in the feasibility study, but it is unclear if the synergy between
continued pumping for plume containment purposes and source zone pumping for mass removal
has been considered. If the P&T system continues to operate to hydraulically contain the plume
and remediate the dilute portion of the plume, there are relatively small incremental costs to
annual operations to remove substantially more mass from the source zone. Consider the
$186,000 per year cost described earlier for operating the P&T system with the current
configuration and the current influent concentrations (approximately 2,000 ug/L of PCE, 2,000
ug/L of TCE, 250 ug/L of cis 1,2-DCE, and 25 ug/L of vinyl chloride). The additional cost to
operate three more extraction wells (e.g., RW-I4 and another well located in the high
concentration portion of the plume), increase the extraction rate to 16 gpm, double the influent
concentration, and treat the water with a GAC-only treatment process would likely cost under
$30,000 per year more than the current O&M costs for four times the amount of GAC and an
increase in electricity for pumping. It is unclear how long the higher influent concentrations
would be maintained, but if they were maintained for six months, the mass removal over the
course of the year would be approximately 600 pounds. Therefore, assuming that P&T continues
to be utilized for hydraulic containment and remediation of the dilute plume, substantial source
zone mass removal via P&T with added wells can occur for an incremental cost of less than
$30,000 per year. A capital cost of $300,000 should be adequate to install addition wells, piping,
and treatment plant modifications.
31
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The following very approximate cost and sustainability comparison compares the relative costs of
remediation over a 30-year period using P&T to address the dilute plume and various remedial
technologies to address the source zone and high concentration plume. Note that these are
estimated costs for up to 30 years and do not necessarily represent the estimated costs to achieve
closure for some of the remedial options. Some remedies would be expected to remove
contaminant mass and reach site closure in less than 30 years and some of the options,
particularly the P&T containment option, may involve remediation for substantially longer than
30 years. The costs do are not discounted to represent net present value. For the purpose of this
evaluation, the following basic, simplifying assumptions are made:
o The total source zone (referred to as source zones A and B in the October 2008 Technical
Memorandum) is approximately 5,000 cubic yards.
o The high concentration plume (total VOC concentrations over 3,000 ug/L) comprises an
additional 27,000 cubic yards.
o The dilute plume (total VOC concentrations between 300 ug/L and 3,000 ug/L)
comprises an additional 68,000 cubic yards of volume to the above volumes for the
source zone and high concentration plume.
o The cost for operating the P&T system to contain the dilute plume or the source zone,
high concentration plume, and dilute plume at an estimated extraction rate of 8 gpm is
approximately $186,000 per year for 30 years.
o The for operating the P&T system to both contain the dilute plume and aggressively
extract mass from the source zone as described above is $216,000 per year for the first 10
years, $210,000 per year for years 11 through 20, and $204,000 per year for years 21
through 30.
o Under either P&T scenario, an additional cost of $150,000 would be more than adequate
for replacing P&T system equipment over the 30-year period.
o The approximate unit cost for thermal remediation is $500,000 for design and
mobilization plus $100 per cubic yard.
o The approximate unit cost for in-situ bioremediation is approximately $60 per cubic yard
for three injections.
The following table summarizes costs for implementing various combinations of the above
remedies, without any discounting:
32
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Approximate Cost Comparison of Various Remedial Options
Source Zone Remedy
High Concentration Plume
Remedy
Dilute Plume Remedy
P&T only to contain the source zone, HCP, and dilute plume for 30 years (operation at
current capacity, ~8 gpm)
P&T only to address the source zone and contain the HCP and dilute plumes for 30 years
(operation at increased capacity, -16 gpm)
In-situ thermal remediation
In-situ thermal remediation
In-situ thermal remediation
Bioremediation
In-situ thermal remediation
In-situ thermal remediation
Bioremediation
P&T at 8 gpm to contain the HCP and dilute plume for 30
years
In-situ thermal remediation
Bioremediation
Bioremediation
In-situ thermal remediation
Bioremediation
Bioremediation
P&T at 8 gpm for 30 years
P&T at 8 gpm for 30 years
P&T at 8 gpm for 30 years
In-situ thermal remediation
Bioremediation
Bioremediation
Total Cost
$5.7 million
$6.8 million
$6.7 million
$9.4 million
$8.3 million
$7.6 million
$10. 5 million
$6.7 million
$6.0 million
Note: The above table analyzes cost only over a 30-year time frame and does not consider which
approach would remove the most mass or remedy performance. The P&T option for 16 gpm includes
$300,000 in capital costs for system modifications and well installations. All P&T options include an
additional $150,000 for equipment replacement over the course of the 30-year period.
The above table indicates that P&T is a viable remedial option that might provide a means of
cost-effective remediation and should be further considered as part of the remedy selection
process. In addition, the above table suggests that if in-situ thermal remediation or
bioremediation is used to address that high concentration plume that it would be more cost-
effective to expand the bioremediation area to include the dilute plume rather than contain the
dilute plume with a P&T system. Continuing to operate the P&T system appears to be cost-
effective if bioremediation or in-situ thermal remediation is not used to address the high
concentration plume.
A similar analysis can be done with respect to the carbon footprint. The table below summarizes
a "very approximate" estimate of the carbon footprint for the same scenarios. The assumptions
and calculations for the footprint estimates are presented in Attachment B.
33
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Estimated Approximate Carbon Footprints of Various Remedial Options
Source Zone Remedy
High Concentration Plume
Remedy
Dilute Plume Remedy
P&T only to contain the source zone, HCP, and dilute plume for 30 years (operation at
current capacity, ~8 gpm)
P&T only to address the source zone and contain the HCP and dilute plumes for 30 years
(operation at increased capacity, ~16 gpm)
In-situ thermal remediation
In-situ thermal remediation
In-situ thermal remediation
Bioremediation
In-situ thermal remediation
In-situ thermal remediation
Bioremediation
P&T at 8 gpm to contain the HCP and dilute plume for 30
years
In-situ thermal remediation
Bioremediation
Bioremediation
In-situ thermal remediation
Bioremediation
Bioremediation
P&T at 8 gpm for 30 years
P&T at 8 gpm for 30 years
P&T at 8 gpm for 30 years
In-situ thermal remediation
Bioremediation
Bioremediation
Estimated
Total CO2e
Footprint
(tons CO2e)
970
1,861
1,655
5,355
2,855
2,396
13,685
4,985
4,526
Note: The above table analyzes cost only over a 30-year time frame and does not consider which
approach would remove the most mass or remedy performance. Assumptions made in deriving these
estimated footprints are provided in Attachment B.
The footprint for containing the plume over 30 years is the smallest of the various options
considered, but it is likely containment would need to occur for substantially longer than 30 years
without source zone remediation. Evaluating the above options, it appears that thermal
remediation should be limited to the source zone. It also appears that some combination of
source zone and high concentration plume remediation coupled with P&T to contain the dilute
plume results in a comparatively small footprint and a reasonable chance of closing the site
within 30 years. The option using an enhanced P&T system to address the source zone, high
concentration plume, and dilute plume offers one of the lowest cost and lowest environmental
footprints, but it is unclear if 30 years of enhanced P&T would be sufficient to achieve the same
mass removal or chance for closure as options that involve more aggressive source zone
remediation.
The remedy options with the lowest cost are not necessarily the remedy options with the lowest
carbon footprints. However, it is apparent that options that involve P&T, including the option to
extract ground water from the source zone and high concentration plume, are competitive with
34
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the other remedial options with respect to cost and environmental footprint (as measured by the
carbon footprint). As such, it seems appropriate to retain some form of P&T as a remedial option
during remedy selection.
6.5 RECOMMENDATIONS FOR IMPROVED SUSTAINABILITY
No specific recommendations are made with respect to further incorporating sustainability into the
remedy. The above recommendations, which are made for other primary reasons, consider and may
enhance remedy sustainability as noted in the discussion of each recommendation.
6.5.1 CONSIDERATIONS FOR RENEWABLE ENERGY AT THE SITE
Cost Analysis for Solar Energy
Florida has abundant sunshine and incentives for photovoltaic (PV) systems. Therefore, consideration of
renewable energy at the Site should include an analysis of the usage and costs, and the costs associated
with installing a PV system. Assuming the roof of the Alaric building is available for solar panels,
approximately 20kW of solar panels could fit on the southern facing portion of the roof. A system this
size in Florida, assuming limited or no obstruction of sunlight by the surrounding trees, could provide
slightly less than half of the electricity used by the extraction system and treatment plant. A cost analysis
is presented in Attachment C. The analysis uses local solar intensity (Tampa, FL) from PVWATTs
(operated by the National Renewable Energy Labortory), commonly used photovoltaic efficiency
parameters, and local electrical rates. After rebates, the system would cost approximately $90,000. The
payback period, assuming rebates from the Florida Solar Energy System Incentives Program operated by
Florida are available, is almost 20 years.
The cost analysis does not consider selling the renewable energy credits ("green tags") generated by the
system because it is assumed that the renewable energy credits would be retained by the Site so that the
generated renewable energy is credited to the Site rather than sold to another entity. If renewable energy
was generated on-site but the renewable energy credits were sold to another party, the "ownership" of the
renewable energy would be transferred to the party purchasing the renewable energy credits.
Cost Analysis and Rationale for Green Tags
Renewable energy can also be used to power the P&T system by purchasing "green tags" or renewable
energy certificates. The market price is approximately $0.025 per kWh. It would therefore cost
approximately $1,500 additional per year to power the P&T system with renewable energy that is
generated elsewhere in the country. Comparing this option to the solar option described above, this
option would have no upfront capital costs but would cost approximately $15,000 additional over the next
10 years (assuming green tag prices do not increase) to address all of the system electricity usage. By
comparison, the solar option described above (including the rebates but excluding benefits of tax credits
and depreciation) would still be approximately $50,000 from breaking even after 10 years and would have
only addressed approximately 50% of the system's electricity usage. As a result, over a 10-year time
frame, the purchase of renewable energy certificates may make more financial sense. If the planning
horizon is a 20-year period, then the renewable energy certificate option would cost over $72,000 where
as the solar option would break even.
35
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Table 4.1 Energy and Atmosphere Footprint Analysis
Energy
Electricity
Diesel (GAC disposal)
Gasoline
Energy subtotal
Materials
GAC
Other materials (bag filters, disposables)
Materials subtotal
Waste Disposal
Hazardous waste diposal for GAC
Disposal subtotal
Other Services
Well rehabilitation
Laboratory analysis
Other services subtotal
P&T System Total
Quantity
60,000
28
114
2,000
$5,000
1
$10,000
$9,000
Unit
kWh
gallons
gallons
pounds
dollars
tons
dollars
dollars
CO2 equiv (Ibs)
emission
factor
(Ibs/unit)
1.27
22
19
2
1
27.5
1
1
total
76200
616
2166
78982
4000
5000
9000
27.5
27.5
10000
9000
19000
107009.5
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Usage and Emission Factor Notes for Table 4-1.
Except where otherwise noted, information regarding emission factors was obtained from eGRID, EPA
Climate Leaders Program, the National Renewable Energy Laboratory life-cycle inventory at
www.nrel.gov/lci. or the EUROPA Reference Life-Cycle Database. Costs used in deriving emission
factors are consistent with costs during Spring 2009. The emissions factors developed here are rough
approximations based on simplifying assumptions. They are intended to provide only approximate
environmental footprints to help understand the affects potential changes to the remedy may have on the
footprint of the remedy.
Electricity
Quantity - 60,000 kWh, see report text for additional information
Emission Factor - Based on eGRID2007 for FRCC output emission rate for base-load using equivalency
ratios of 21:1 methane to carbon dioxide and 310:1 nitrous oxide to carbon dioxide from
http://www.epa.gov/solar/energv-resources/calculator.html
Diesel
Quantity - 0.023 gallons per ton-mile of transport in a single-unit truck, for 0.5 tons of waste transported
1,200 miles to Belleville, MI two times per year (NREL)
Emission Factor - 22 pounds of carbon dioxide per gallon of diesel (Climate Leaders)
Gasoline
Quantity - 2 gallons of gasoline per trip, once per week, 52 weeks per year for operator labor, plus an
additional 10 trips once per year for ground water sampling.
Emission Factor - 19 pounds of carbon dioxide per gallon of gasoline (Climate Leaders)
Granular Activated Carbon
Quantity - 2,000 pounds per year
Emission Factor - 2 pounds of carbon dioxide per pound of regenerated GAC, see Attachment B.
Other Materials
Quantity - Usages were not directly quantified. The emission factor used is based on a percentage of
material cost directed toward energy from fossil fuels. Approximately $5,000 of materials (bag filters,
disposable personal protective equipment, etc.) is assumed.
Emission Factor - 1 pounds of carbon dioxide per dollar of materials, based on 10% of the cost of the
materials resulting from the direct use of fossil fuels or electricity derived from fossil-fuels, and
-------
approximately 10 pounds of carbon dioxide emitted per $1 of fossil fuels consumed. 10 pounds would
represent a blend of natural gas, diesel, gasoline, and coal.
Hazardous Landfill Disposal
Quantity - 1 ton per year based on 0.5 tons (1,000 pounds) disposed of 2 times per year
Emission Factor - 27.5 pounds of carbon dioxide per ton, based at 10% premium on the carbon emissions
from EUROPA file location: Inert waste disposal. Inert waste used so that methane and carbon dioxide
from decomposing waste is not included.
Other Services
Quantity - A breakdown of materials and energy are not directly quantified. The emission factor used is
based on a percentage of service cost directed toward energy from fossil fuels. Approximately $10,000
for well-rehabilitation service is assumed and likely includes diesel for transport and on-site energy
generation, chemicals and/or pressurized nitrogen, and delivery activities. Approximately $15,000 in
laboratory analysis is assumed and likely includes fuel for transport, electricity for operating the
laboratory and equipment, chemicals and disposables associated with sample preparation and analysis,
and disposal.
Emission Factor - 1 pound of carbon dioxide per dollar spent on the service, based on 10% of the cost
resulting from direct use of fossil fuels and approximately 10 pounds of carbon dioxide per $1 of fossil
fuels consumed. 10 pounds of carbon dioxide would represent a blend of natural gas, diesel, gasoline,
and coal.
References
Climate Leader GHG Inventory EPA-430-K-08-004, May 2008
EGRID 2007 v 1.1
(EUROPA) European Reference Life Cycle Database (ELCD core database), version II compiled under
contract on behalf of the European Commission - DG Joint Research Centre - Institute for Environment
and Sustainability with technical and scientific support by JRC-IES from early 2008 to early 2009.
(http ://lca.j re .ec .europa.eu/lcainfohub/datasetArea.vm)
National Renewable Energy Laboratory (NREL), Life-Cycle Inventory Database (www.nrel.gov/lci)
maintained by the Alliance for Sustainable Energy, LLC.
-------
Table 6-1. Cost Summary Table
Recommendation
6.1.1 Carefully Determine
an Appropriately
Conservative Buffer when
Informing the State of
Plume Extent Related to
Establishing Ground Water
Restrictions
6.1.2 Analyze Process
Water Periodically for
Constituents Of Concern
from the Helena Chemical
Site
6.1.3 Simplify System
Controls
6.1.4 Monitor Specific
Capacity in Recovery And
Reinjection Wells
6.1.5 Interpret Capture
6.2.1 Modify VOC
Treatment
6.2.2 Consider Discharging
to the Shallow Zone
6.2.3 Characterize GAC
Again and Investigate
Source of Radioactivity in
an Attempt to Dispose of
GAC as Non-Hazardous
Waste or to Regenerate It
6.2.4 Track Routine O&M
Costs Separately from
Non-Routine Costs
Reason
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Effectiveness
Cost Effectiveness
Cost Effectiveness
Cost Effectiveness
Cost Effectiveness
Additional
Capital Costs
($)
$10,000
$0
$15,000
Estimated
Change in
Annual Costs
($/yr)
$0
$0
$0
Estimated
Change in
Life-Cycle
Costs
$*
$10,000
$0
$15,000
Estimated
Change in
Life-Cycle
Costs (net
present
value)
$**
$10,000
$0
$15,000
Negligible
$100,000
$0
$5,000
$0
$0
($10,000)
($5,000)
($2,000)
$100,000
($300,000)
($150,000)
($60,000)
$100,000
($196,000)
($93,000)
($39,200)
Not Specified
-------
Recommendation
6.3.1 Consider the
Following Comments to
the May 2009 Technical
Review by the Site
Contractor
6.4 Considerations
Regarding Site Closure -
Consider P&T for Final
Remedy
6.5 Sustainability and
Renewable Energy
Reason
Technical
Improvement
Site Closure
*jj-^- i Estimated
Additional „,
/^ •+ , r^ ± Change in
Capital Costs . , „ ,
m Annual Costs
( ' ($/yr)
Estimated
Change in
Life-Cycle
Costs
S*
Estimated
Change in
Life-Cycle
Costs (net
present
value)
$**
Not Specified
Not Specified
Cost Analysis Provided for Solar Energy and Renewable Energy Certificates
Costs in parentheses imply cost reductions
* assumes 30 years of operation with a discount rate of 0% (i.e., no discounting)
** assumes 30 years of operation with a discount rate of 3% and no discounting in the first year
-------
Table 6-2. Sustainability Summary Table for Recommendations
Recommendation
Reason
Effects on Sustainability
6.1.1 Carefully
Determine an
Appropriately
Conservative Buffer
when Informing the State
of Plume Extent Related
to Establishing Ground
Water Restrictions
Effectiveness
None beyond the remedial objectives of the remedy to
protect human health and the environment.
6.1.2 Analyze Process
Water Periodically for
Constituents Of Concern
from the Helena
Chemical Site
Effectiveness
Additional minor footprint associated with laboratory
analysis, but review will help protect the water resource of
the Floridan aquifer
6.1.3 Simplify System
Controls
Effectiveness
None beyond the remedial objectives of the remedy to
protect human health and the environment.
6.1.4 Monitor Specific
Capacity in Recovery
And Reinjection Wells
Effectiveness
None beyond the remedial objectives of the remedy to
protect human health and the environment.
6.1.5 Interpret Capture
Effectiveness
Potentially identify opportunities to reduce overall
extraction rate necessary to provide capture or demonstrate
need to increase extraction rate. The environmental
footprints would tend to scale with the extraction rate.
6.2.1 Modify VOC
Treatment
Cost Effectiveness
Reduced carbon footprint by approximately 10,000 pounds
of carbon dioxide per year. Reductions associated with
other footprints are also likely.
6.2.2 Consider
Discharging to the
Shallow Zone
Cost Effectiveness
Reduced carbon footprint by approximately 5,000 pounds
of carbon dioxide per year (if 6.2.1 is not implemented).
Reductions associated with other footprints are also likely.
6.2.3 Characterize GAC
Again and Investigate
Source of Radioactivity
in an Attempt to Dispose
of GAC as Non-
Hazardous Waste or to
Regenerate It
Cost Effectiveness
Potentially avoid long-distance transportation and
potentially allow GAC to be regenerated rather than
disposed of in landfill.
6.2.4 Track Routine
O&M Costs Separately
from Non-Routine Costs
Cost Effectiveness
None.
-------
Recommendation
Reason
Effects on Sustainability
6.3.1 Consider the
Following Comments to
the May 2009 Technical
Review by the Site
Contractor
Cost Effectiveness
None.
6.4 Considerations
Regarding Site Closure -
Consider P&T for Final
Remedy
Technical
Improvement
Effects are unclear, but analysis provides perspective on the
footprints of several remedial approaches.
6.5 Sustainability and
Renewable Energy
Site Closure
A photovoltaic system could provide almost 50% of the
electricity required by the system. Purchase of renewable
energy certificates could allow entire site to be powered by
renewable energy.
-------
ATTACHMENT A
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E3
Figure Not To Scale
Source: Google Earth (by license)
Client:
U.S. EPA Region 4, RAG
File.AIaric Tech Memorandum
Figures 10-02-08
Drawn By/Checked By: EMS
Rev:
1.0
Project #:
048706
Date:
10/02/08
Title:
Regional Aerial Photograph of the Site
Alaric Site, Tampa, Florida
Figure
2-1
-------
Figure Not To Scale
Source: Hillsborough County Property Appraiser Website
Client:
U.S. EPA Region 4, RAG
File.AIaric Tech Memorandum
Figures 10-02-08
Drawn By/Checked By: EMS
Rev:
1.0
Project #:
048706
Date:
10/02/08
Site Aerial Photograph
Alaric Site, Tampa, Florida
Figure
2-3
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SB137
SB138
SURFICIAL
AQUIFER
68
21
UPPER
INTERMEDIATE
ZONE
8.3
5.1
39
MIDDLE
INTERMEDIATE
ZONE 7.1
4.3
i-
S-
5.5
0.03
LOWER 0.01
INTERMEDIATE
ZONE
Project #: 048706
Date: 09/08
Title: Cross-Section of the
Primary Source Area
Technical Memorandum
Former Alaric Site, Tampa
Figure
3-2
-------
PROPERTY BOUNDARIES WERE INTERPOLATED
EROM AN AERIAL PHOTOGRAPH
EJ
SCALE
0 120 241
Client:
U.S. EPA Region 4, RAG
File.AIaric Tech Memorandum
Figures 10-02-08
Drawn By/Checked By: SF/EMS
Rev:
1.0
Project #:
048706
Date:
10/02/08
Title:
Groundwater Elevations
In Shallow Wells (Non-Pumping)
December 15, 2002
Alaric Site, Tampa, Florida
Figure
3-4
-------
\CHEMICAL
PAN>
PROPERTY BOUNDARIES WERE INTERPOLATED
FROM AN AERIAL PHOTOGRAPH
J22.01) GROUNDWATER ELEVATION (FEET)
-19.00 GROUNDWATER ELEVATION CONTOUR
^- GROUNDWATER FLOW DIRECTION
MIZ MIDDLE INTERMEDIATE ZONE
EJ
SCALE
0 120 241
Client:
U.S. EPA Region 4, RAG
File.AIaric Tech Memorandum
Figures 10-02-08
Drawn By/Checked By: EMS
Rev:
1.0
Project #:
048706
Date:
10/02/08
Title:
Groundwater Elevations
In MIZ Wells (Non-Pumping)
December 15, 2002
Alaric Site, Tampa, Florida
Figure
3-6
-------
PROPERTY BOUNDARIES WERE INTERPOLATED
FROM AN AERIAL PHOTOGRAPH
J17.40) GROUNDWATER ELEVATION (FEET)
— 19.00 GROUNDWATER ELEVATION CONTOUR
^- GROUNDWATER FLOW DIRECTION
LIZ LOWER INTERMEDIATE ZONE
SINGLETON
BATTERY
EJ
SCALE
0 120 241
Client:
U.S. EPA Region 4, RAG
File.AIaric Tech Memorandum
Figures 10-02-08
Drawn By/Checked By: SF/EMS
Rev:
1.0
Project #:
048706
Date:
10/02/08
Title:
Groundwater Elevations
In LIZ Wells (Non-Pumping)
December 15, 2002
Alaric Site, Tampa, Florida
Figure
3-7
-------
1. GROUNDWATER SAMPLES COLLECTED
BY THE MICROPURGE TECHNIQUE
IN JULY 2005 AND APRIL 2007.
2. GROUNDWATER ANALYTICAL RESULTS IN
KLU EXCEED THE FDEP CTL.
3. GROUNDWATER ANALYTICAL RESULTS IN
GREEN EXCEED THE FDEP NADC.
4. THE GROUNDWATER DETECTION LIMIT POR
VINYL CHLORIDE RANGED FROM 1 TO
1,000 ug/L IN JULY 2005 AND APRIL 2007.
EJ
SCALE
0 50 120 FEET
Client:
U.S. EPA Region 4, RAG
File.AIaric Tech Memorandum
Figures 10-02-08
Drawn By/ Checked By: RC/EMS
Rev:
1.0
Project #:
048706
Date:
10/02/08
Title:
2007/2008 VOC Distribution in the UIZ
Alaric Site, Tampa, Florida
Figure
3-11
-------
NOTES:
1. ANALYTICAL RESULTS IN RED EXCEED
THE FDEP CTL.
2. ANALYTICAL RESULTS IN 1 EXCEED
THE FDEP NADC.
3. THE DETECTION LIMIT FOR VINYL CHLOR DE
RANGED FROM 1 TO 1,000 ug/L N
JULY 2005 and APRIL 2007.
-------
/MW081^
: -*• N
-i—®
^r
FLOW DIRECTION IN THE LOWER
INTERMEDIATE ZONE
(NO ACTIVE RECOVERY WELLS)
\% "& ft
x LY&$V&
HELENA CHEMCAL 3,000 UQ/L \ ^\ 1
COMPANY WAREHOUSE/ \ \\
EXISTING MIDDLE INTERMEDIATE
ZONE MONITORING WELL LOCATION
(40 to 55')
/ SRW-D
/ ^-^- *• -il [Hi ASPHALT
Client:
U.S. EPA Region 4, RAG
File.AIaric Tech Memorandum
Figures 10-02-08
Drawn By/Checked By: RC/EMS
Rev:
1.0
Project #:
048706
Date:
10/02/08
2007/2008 VOC Distribution in the LIZ
Alaric Site, Tampa, Florida
Figure
3-13
-------
Exfiltration
Gallery (typ.)
INTERMEDIATE RECOVERY WELL FLOW ON
MAY 9, 2007 INCLUDED 2.D gpm AT RW-11,
2.2 gpm AT RW-I2, and 1.4 gpm AT RW-13.
RW-I4 WAS OFFLINE.
EJ
SCALE
0 50 120 FEET
Client:
U.S. EPA Region 4, RAG
File.AIaric Tech Memorandum
Figures 10-02-08
Drawn By/Checked By: RC/EMS
Rev:
1.0
Project #:
048706
Date:
10/02/08
Title:
Remedial Alternative SZB-2B, HCP-3B, DP-2B Layout:
Groundwater Containment
Alaric Site, Tampa, Florida
Figure
7-10
-------
30
C/)
LLJ
LU
O
C/)
Q
<
LU
LU
Q
O
25
20
15
• Surficial Aquifer
• Upper Intermediate Aquifer
i
A Lower Intermediate Aquifer
o Deep Intermediate Aquifer
15 20 25 30
OBSERVED GROUNDWATER ELEVATION (FEET AMSL)
Shaw
4/28/03
725 U.S. Highway
301 South
Tampa, FL 33619
Figure K-7
Comparison of Steady-State Model
and Observed Groundwater Elevations
Alaric, Inc. HWC-114
210 North 71st Street, Tampa, FL
Project # 804408 PM: TW
PE: EMS
-------
Oi 100 200 300 400
, Scale in Feet
100
100
Groundwater Capture Zone
Head Elevation
Contour (Feet NAVD 88)
Groundwater Flow Path
Total VOC Concentration
Upper Intermediate (ug/L)
Total VOC Concentration
Lower Intermediate (ug/L)
Proposed
Intermediate
Aquifer Groundwater
Recovery Well
W !!*^
Shaw
4/28/03
725 U.S. Highway
301 South
Tampa, FL 33619
Figure K-18
Groundwater Flow Path Solution
Layer 3 (Upper Intermediate Aquifer)
Alaric, Inc. HWC-114
210 North 71st Street, Tampa, FL
Project # 804408 I PM: TWl PE: EMS
-------
•-OGP-2;
pH 4.9
CENTRAL
FLORIDA LUMBER
—OGP-22
pH 4.0
XYLENE 110
SULFATE 875
NATIONAL
FISHERIES
A&D
ROLL-OFF
SERVICE
OGP-28^
pH 6.8 '
XYLENE <1
SULFATE 150
GULF
COAST
METALS
OGP-1
pH 5.6
XYJLNE
SULFAIE 975
OOP-??-"
pH 3.8
XYLENt
'•OOP- 17
pH 3.5
XYLENE 22
^•.,'IFATF 1.VS
IFpEND
—*—•—>—'.—* FENCE |
• - NEW Sl'fJFlCIAL MONITORING "'EL..
- SURFICIALl MONITORING WELL.
•• FLORIDA^I MONITORING WELL
- LOST 0° URANnnNFD UONITORiNr: v.'FI i
- OrFSiTE tJLUME OELiNEATION OR XYl ENE AREA
DPT LOCATIONS
-F- - DESIGNATES A FLORlDAN MONITORING WEl L
pH ISOCCNCFNTRATION CONTOUR (S.U.)
XYLENE ISOCONCtNTRATION CONTOUR (f^g/i-)
- SULFATE (SOCONCENTOATION CONTOUR (mg/L)
}) pH IS SHOWN IN STANDARD UNITS. CONTOURED AREA SHOWS pH<5.
2) XYLENE CONCENTRATIONS ARE | SHOWN IN WiCR!)GRA)jtS PER LITER
THE ROD GOAL FOR XYLENE IS .
SULFATE CONCENTRATIONS ARE! SHOWN IN MILLIGRAMS PER LfTER (mg/L).
THE FSDWS FOR SULFATE IS 250 mg/L.
OOP-16
pH 5.8
Maps Prepared by Ensafe (2002)
Shaw
05/10/03
725 U.S. Highway
301 South
Tampa, FL 33619
Figure E-1
pH, Xylene, and Sulfate Concentration
Maps From Helena Rl
Alaric, Inc. HWC-114
2110 North 71st Street, Tampa, FL
Project # 804378
PM:TW
PE. EMS
-------
Maps Prepared by Ensafe (2002)
HCUW2"
SO.275
"*— "
"' VlOV:O"ING WELL
rLOh"OAN MONITORING WELL
- LOV C"' Ar.',NDOKt"0 MOMTOWNO
- OF-:,!Tf. PIIJWF DFUNFATION OR XVIFNF ARFA
OF' LOCATIONS
DESIGNATES A FLORlDAN MONITORING WELL
- SULI-ATE ISOCONCENTRATION CONTOUR (rr|q/L)
- FERROUS IRON ISOCONCENTRAT10N CONTOUR (mg/l
- SULFIDE ISOCONCFNTRATION CONTOUR (mg/l )
F .NOTES
ALL UNITS ARE MILLIGRAMS PER LITER (mg/L).
21 THE FSD'iVS FOR SU.FATE 15 250 mg/L.
3; OR = OVi."R RANGE. CONCENTRATION ASSUMED TO BE GREATER THAN
THF. HIGHEST DETECTION AT A COMPARABLE DILUTION.
(4) UR - UNDER RANGE. CONCENTRATION ASSUMED TO BE LESS THAN THE
LOWEST DETtCT:ON AT A COMPARABLE DILUTION.
(5) SO*- SULFATE
S»- = SULFIDE
Fe(ll) = FERROUS IRON
FLOR'OA
MASONRY
S04275
~ UR <0.01
FE(II) 0.2
/ SO.1375
/ S'- 9.1
FE(ll) 62.3
HCMW-23
INTERIOR
WOOOESIGNS
HCMW10A
S0< 300
- O.n
PZ02
50. OR >1400
HCMW09
O SO. 300
S2" 1.2
__-WV,T1A
SC* 375
- 0.68
FF(II) ?..'
HCMY/08
S0.25
- 3.0
) 0.85
HCMW-24
'OR >1400
O.O43
FB(II)
725 U.S. Highway
301 South
Tampa, FL 33619
LPWI •
5O« OR >1400
- 0.08
FE(II) 24.8
Sulfate, Ferrous Iron, and Sulfide
Concentration Maps From Helena Rl
NAIIONAL
RSHERIES
A&D
ROLL-OFF
SERVICE
HCMW-27
S0< 1400
Ss~ 0.61
FE(ll) 5.88
Alaric, Inc. HWC-114
2110 North 71st Street, Tampa, FL
Project # 804378
-------
_£GLND
- f-'LORIDAN MONFOR1NG vVEl.i.
- lOST OR ABANfiONED MONITORING WELL
- orrsiTf- PLUME TEMPORARY WELL POINT OR
XrlENE AREA DPI LOCATION
- FLORIDAN MONITORING WELL '
- aBHL' ISOCGNCENTRATION CONTOUF [pg/l )
- 0-BHC ISOCONCifNTRAT/ON CONTOUR'(/jg/l )
- 6EHC iSOCONCFNTRATlON CONTOUR (/iq/L)
- uHHC (-JNOANF) .SOCONCENTRAJPON CONTOUR
(1) ALL CONCENTRATIONS IN MlCROGRAWS
PER LITER
(2) THE ROD GOAL rOR o-BHC IS '0.05
<
laBHC 0.004 7 i
<0.0'i
BHC
Fi ORIDA
MASONRY
aSHC<0.01
^3HC<0,A)1
<5BHC<-01
PZ01 -
a3MC
0.66
0
^
5
i
T" i
^ i
o !
Q_ **
i
1
I
I
aBHC 0.091
r JHC 0.0381
6BHC 0.028!
Shaw
05/10/03
725 U.S. Highway
301 South
Tampa, FL 33619
Figure E-3
BHC Concentration Maps From Helena
Rl
Alaric, Inc. HWC-114
2110 North 71st Street, Tampa, FL
Project # 804378 I PM: TW
PE: EMS
-------
Maps Prepared by Ensafe (2002)
a.—
INTERIOR
WOODESIGNS
ALARIC
PRIVATE
WFU Q
HCMW09
2.4-D <0.5
) SILVEX <0.5
PZ01
,J
Lx X «• > X '/ > 1 -,
4
[2.4-0 <67f>
[SILVETX
-------
FENCE
SURFIClAi MONITORING WELL
FLORIDAM MONITORING WELL
I n<^T OP ftRAMDOMFn MONITORINC r
OFFSITE PLUME INVESTil^ATION OR X/LENC AREA
DPT LOCATIONS
DESIGNATES A FLORIDAN MONITORING WELL
r HCMW06
As <3
• I .->0 -xj
[ / Cr 346
I 1 Ni 66.8
- NICKEL ISpCONCENTRATION CONTOUR (ug/l)
- ARSENIC tSOCONCENTRAHON CONTOURTio/L)
- CHROUWMl ISOCONCENTRAT10N CONTOUR (uq/L)
- I
/ Pb <1,9 I
PZ05-X
As <3\
I ,— PZ02
4/As 20.3/23,7
Cr 184/180
. Ni 162/160
Pb 17.6/14.7
THE FPOV/S FOR ARSENIC IS 50
THE FPOWS FOR CHROMIUM IS llOO
THE FPDWS FOR LEAD IS '5
HCMW10A
As 113
Cr 2.1
Ni 2.2
Pb <1.9
PRfKATE
WELL
• As 3.4
Cr 3.3
Ni 7.3
Pb <1.9
PZ03
As <3
Cr 6.5
Ni 11.3
• Pb 2.2
*
HCMW08
As <3
Cr 3.8
Mi 2.4
Pb
\ CENTRAL
F&OKIDA LUMBER
725 U.S. Highway
301 South
Tampa, FL 33619
/ ! \ JOHN'S
/ I SA(L BONDS
Metals Concentration Maps From
Helena Rl
Alaric, Inc. HWC-114
2110 North 71st Street, Tampa, FL
Maps Prepared by Ensafe (2002)
-------
Maps Prepared by Ensafe (2002)
- SURFICIAl. MONITOR I NO WELL
•- FLORIDAN MONITORING WELL
- LOST OR ABANDONED MONITORING WELL
- OFTS1TE PLUME TEMPORARY V/F.I.L POINT OR
XYLF.NE AREA DPT LOCATION j
- FLORJQAN MONITORING WELL
FLORIDA
MASONRY
- XYLENE ISOCONCENTRATION CONTOUR (;tg/L)
• ETHYI.BENZENE iSOCONCENTRATiO^ CONTOUR
(1) ALL CONCENTRATIONS IN M1CROQRAMS
PER LITER
(2) THF, ROD GOAL FOR XYLENE
IS 20
(3) THE FSD'.VS FOR ErHYLBENZENE
IS 30
XYLENE
ETHYLSENZENE
XYLENE <2
ETHYLBENZENE < 1
V/OODESIGNS
XYLENE
ETHVLBENZENE
25.000
3,200
XYLENE <2
ETHYL9EN2ENE 1.3
XYLENE
ETHYLBENZENE
XYLENE <2
ETHYLBENZENE 0.79
XYLENE
ETHYLBENZENE
XYLENE <2.4
ETHYLBENZENE 1.5
CENTRAL
FLORIDA LUMBER
7 XYLENE I
HETHYLEI£NZENE
XYLENE 1.500
I ETHYLBENZENE <25
NATIONAL
FISHERIES
725 U.S. Highway
301 South
Tampa, FL 33619
A&D
ROLL-OFF
SERVICE
XYLENE <5.8
ETHYLBENZENE <1
Xylene and Ethylbenzene
Concentration Maps From Helena Rl
RONMENTAL
Alaric, Inc. HWC-114
2110 North 71st Street, Tampa, FL
Project # 804378
-------
ATTACHMENT B
-------
Approximate Carbon Footprint Calculations
These only consider those activities or components that are expected to be the primary contributors to the
overall footprint. As such, the calculated footprints are approximations.
Baseline P&T System Operating at 8 gpm for Plume Capture
Electricity usage - 1,051,000 kWh total as follows
1.5 HP total for all three extraction wells, operating 100% of the time
1 HP for blower operating 100% of the time
1.5 HP feed pump operating 33% of the time
1 kW operating 100% of the time for miscellaneous usage (e.g., lighting, controls)
All motors assumed to operate a 75% efficiency
Remedy duration of 30 years
GAC usage - 60,000 pounds total as follows
2,000 pounds per year
Remedy duration of 30 years
Acid usage - 126,000 pounds total as follows
4,200 pounds per year based on neutralizing 100 mg/L (CaCO3) of alkalinity at 8 gpm
Remedy duration of 30 years
Laboratory Analysis - $180,000 in laboratory analysis as follows:
Monthly analysis of 5 samples (including QA) for VOCs only
Analytical cost of $ 100 per sample
Remedy duration of 30 years
Item
Electricity (kWh)
GAC (Ibs)
Acid (Ibs)
Laboratory analysis ($)
Quantity
1,051,000
60,000
126,000
$180,000
CO2e Emission
Factor
1.27
2
2.4*
1
Total (Ibs)
Total (tons)
CO2e Emission (Ibs)
1,335,000
120,000
302,000
180,000
1,937,000 Ibs
970 tons
* Emission factor for acid from European Reference Life Cycle Database (ELCD core database), version II
compiled under contract on behalf of the European Commission - DG Joint Research Centre - Institute for
Environment and Sustainability with technical and scientific support by JRC-IESfrom early 2008 to early 2009.
(http://lca.irc. ec. europa. eu/lcainfohub/datasetArea. vm)
-------
Enhanced P&T'System Operating at 16 gpm for Remediation and Plume Capture
Electricity usage - 1,840,000 kWh total as follows
3 HP total for all six extraction wells, operating 100% of the time
2 HP for blower operating 100% of the time
1.5 HP feed pump operating 67% of the time
1 kW operating 100% of the time for miscellaneous usage (e.g., lighting, controls)
All motors assumed to operate a 75% efficiency
Remedy duration of 30 years
GAC usage - 180,000 pounds total as follows
8,000 pounds per year for first 10 years
6,000 pounds per year for next 10 years
4,000 pounds per year for last 10 years
Acid usage - 352,000 pounds total as follows
8,400 pounds per year based on neutralizing 100 mg/L (CaCO3) of alkalinity at 16 gpm
Remedy duration of 30 years
Laboratory Analysis - $180,000 in laboratory analysis as follows:
Monthly analysis of 5 samples (including QA) for VOCs only
Analytical cost of $ 100 per sample
Remedy duration of 30 years
Construction - excluded because footprint is negligible compared with other components.
Item
Electricity (kWh)
GAC (Ibs)
Acid (Ibs)
Laboratory analysis ($)
Quantity
1,840,000
180,000
352,000
$180,000
CO2e Emission
Factor
1.27
2
2.4*
1
Total (Ibs)
Total (tons)
Total (tons)
CO2e Emission (Ibs)
2,337,000
360,000
845,000
180,000
3,7622,000 Ibs
1,861 tons
970 tons
* Emission factor for acid from European Reference Life Cycle Database (ELCD core database), version II
compiled under contract on behalf of the European Commission - DG Joint Research Centre - Institute for
Environment and Sustainability with technical and scientific support by JRC-IESfrom early 2008 to early 2009.
(http://lca.jrc. ec. europa. eu/lcainfohub/datasetArea. vm)
-------
Thermal Remediation for Source Zone
Electricity usage - 835,000 kWh total as follows
20,000 btus of energy per cubic foot (approximately 15,000 btus of heat to heat water and soil
150 F plus additional 5,000 btus to account for some heat loss and limited water vaporization)
3,413 btus of heat per kWh for electrical resistive heating
27 cubic feet per cubic yard and source zone volume of 5,000 cubic yards
5 HP blower operating for 12 months (motor operates at 75% efficiency
Steel for electrode installation - 280,000 total pounds as follows
56 electrodes to average depth of 50 feet
4-inch steel casing at approximately 10.8 pounds per foot
730 cubic feet of steel shot (342 pounds/cubic foot) to backfill boreholes to increase electrical
conductivity
Other construction materials and activities are negligible
GAC usage - 600 pounds total as follows (negligible)
2 pounds of GAC per pound of contaminant
Approximately 300 pounds of contaminants
Construction is excluded, but is anticipated to have a small footprint relative to footprint from electricity
usage
Item
Electricity (kWh)
Steel (Ibs)
GAC (Ibs)
Quantity
835,000
280,000
600
CO2e Emission
Factor
1.27
1.1*
2
Total (Ibs)
Total (tons)
CO2e Emission (Ibs)
1,060,000
308,000
1,200
1,369,000 Ibs
685 tons
* Emission factor for steel from European Reference Life Cycle Database (ELCD core database), version
II compiled under contract on behalf of the European Commission - DG Joint Research Centre - Institute
for Environment and Sustainability with technical and scientific support by JRC-IESfrom early 2008 to
early 2009. (http://lca.jrc.ec.europa.eu/lcainfohub/datasetArea.vm)
-------
Thermal Remediation for High Concentration Plume
Scaling the footprint for source zone from 5,000 cubic yards (source zone) to 27,000 cubic yards (high
concentration plume) yields a footprint of 3,700 tons of CO2e for remediating the HCP with thermal
remediation.
Thermal Remediation for Dilute Plume
Scaling the footprint for source zone from 5,000 cubic yards (source zone) to 68,000 cubic yards (dilute
plume) yields a footprint of 9,300 tons of CO2e for remediating the dilute plume with thermal
remediation.
Bioremediation for Source Zone
Primary footprint components
On-site diesel usage - 5,150 total gallons as follows
70 locations for pneumatic fracturing and injection at one location per day
12 gallons of diesel per day for direct-push rig
70 8-hour days of 70 HP air compressor operating at 40% duty and 0.056 gallons of diesel per
HP-hr
3 injection/fracturing events using the above parameters
Emulsified vegetable oil - 90,000 pounds as follows
0.002 pounds per pound of soil adsorptive capacity
5,000 cubic yards of treatment area
1.5 tons per cubic yard of soil and 2,000 pounds per ton
3 injections made at soil adsorptive capacity
Off-site diesel usage - 1,035 total gallons as follows
30,000 pounds of vegetable oil hauled 1,000 miles for each event
3 events
0.023 gallons per ton-mile of transport
Item
Diesel
Vegetable oil
Quantity
6,185
90,000
CO2e Emission
Factor
22
3.51
Total (Ibs)
Total (tons)
CO2e Emission (Ibs)
136,000
316,000
452,000 Ibs
226 tons
* Footprint for vegetable oil obtained from Nielsen PH, Nielsen AM, Weidema BP, DalgaardR and Halberg N
(2003). LCA food database, www.lcafood.dk
-------
Bioremediation for High Concentration Plume
Scaling the footprint for source zone from 5,000 cubic yards (source zone) to 27,000 cubic yards (high
concentration plume) yields a footprint of 1,200 tons of CO2e for remediating the HCP with
bioremediation.
Bi ore mediation for Dilute Plume
Scaling the footprint for source zone from 5,000 cubic yards (source zone) to 68,000 cubic yards (dilute
plume) yields a footprint of 3,100 tons of CO2e for remediating the dilute plume with bioremediation.
-------
Derivation of Estimated Carbon Footprint for GAC
Information from Literature
Use of Adsorbents for the Removal of Pollutants from Wastewaters, by Gordon
McKay, published by CRC Press, 1995, ISBN 0849369207
Table 8.1
Granular Carbon Regeneration Process Energy Requirements
(15,000 kg/day Regeneration Rate)
System
Electric infrared furnace
Multiple-hearth furnace
Rotary Kiln
Fluid bed furnace
Fuel, kJ/kg
0
18,600
23,300
11,700
Electricity, kWh/kg
0.36
0.10
0.07
0.11
Steam, kg/kg
0
1.0
1.0
0.8
1.2
0.5
0.7
0.27
14
1.34
Ib CO2e/lb
Ib CO2e
Ib CO2e
Specific gravity of coal (www.engineeringtoolbox.com)
Specific gravity of GAC (Westates/Siemens)
Fraction of coal that is carbon
(http://www.eia.doe.gov/cneaf/coal/quarterly/co2 article/co2.html)
Carbon footprint of extracting and delivering 1 Ib of coal to a plant
(EUROPAELCD- Hard Coal)
Carbon footprint of natural gas, including natural gas production (per
therm) (NREL)
Carbon footprint of electricity (per kWh) (EGRID, US Average)
Assumptions:
Use fuel and electricity requirements for multiple hearth furnace to estimate energy required
for regeneration
Assume energy requirements for regeneration is the same as they are for initial
activation
-------
Calculations for Virgin Coal:
Carbon Footprint
2.4
1.68
1
0.68
2.5
0.65
8,920
1.2
0.045
0.061
4.5
Ib CO2e
Ib CO2e
Btus
Ib CO2e
kWh
Ib CO2e
Ib CO2e
Pounds of coal required to produce one pound of GAC
Pounds of that coal that is carbon
Pounds of carbon in one pound of GAC
Pounds of carbon from coal emitted to atmosphere
Pounds of carbon dioxide emitted for burning off coal (measured
pounds of CO2)
as
Pounds of CO2e emitted during coal extraction
Fuel required to activate one pound of GAC (2.2 pounds per kg and
1.055 kJ/btu)
Pounds of CO2e emitted for combustion of natural gas during
activation (100,000 btus per therm)
Electricity required to activate one pound of GAC (2.2 pounds per
kg)
Pounds of CO2e emitted for electricity generation
Total CO2e emitted for carbon activation
Energy Footprint
2.4
1440
8,920
0.045
470
10,800
Btus
Btus
kWh
Btus
Btus
Pounds of coal required to produce one pound of GAC
Energy required during coal extraction
Fuel required to activate one pound of GAC (2.2 pounds per kg and
1.055 kJ/btu)
Electricity required to activate one pound of GAC
Energy required to generate that electricity (3,413 btus/kWh and 33%
thermal efficiency)
Total energy required for virgin carbon activation
Calculations for Regenerated Coal
Footprint per Regeneration Cycle (including 10% virgin GAC to make-up for loss)
Energy
8,920 H
h 10% x 10,800 =
10,000
CO2e
1. 2 + 0.061 + 10% x 4.5 = 1.7
-------
Footprints over 10 Regeneration Cycles
Cycle
1
2
3
4
5
6
7
8
9
10
Energy
10,800
10,400
10,300
10,200
10,200
10,100
10,100
10,100
10,100
10,100
CO2e
4.5
3.1
2.6
2.4
2.2
2.1
2.1
2
2
1.9
-------
ATTACHMENT C
-------
Fin an dal Analysis
Photovoltaic System - Alaric Superfund Site, Tampa, Florida
System Power (DC, STC)
System Efficiency
System Power (AC)
Installed Unit Cost
Annual Production
Electricity Rate
Demand Charge
Escalation
Estimated SREC value
20
77%
15.4
$8,500
27,260
$0.1200
$0.0000
5.00%
$0.0000
kW
kW
$/kW DC
kWh/yr
$/kWh
$/kW
{annual rate increase}
$/kWh
Solar Capital Cost
Rebate
Total MTC Grant
Solar G rant %
Cost After Grants
Net Upfront Cost
30% fed tax credit
max taken in 1st year
amount remaining
Loan Amount
Loan Term
Interest Rate
Annual Payment
$170,000
$80,000 at $4 per installed watt
$80,000
47.06%
$90,000
$90,000
$0
0
0.00%
$0
0.0%
$0 not applicable to military
$0 not applicable to military
$0 not applicable to military
years
per year
not applicable to military
Federal Tax Credit Tax Deduction on Loan
Year Cash/Loan and Depreciation Interest
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
($90,000)
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Avoided Energy Cost
Photovoltaic System
$3,271
$3,400
$3,535
$3,674
$3,819
$3,970
$4,127
$4,290
$4,460
$4,636
$4,819
$5,009
$5,207
$5,413
$5,627
$5,849
$6,080
$6,320
$6,570
$6,829
$7,099
$7,379
$7,671
$7,974
$8,289
Other Federal Credit
(per kWh)
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
REC
Cash
Flow
($86,729)
$3,400
$3,535
$3,674
$3,819
$3,970
$4,127
$4,290
$4,460
$4,636
$4,819
$5,009
$5,207
$5,413
$5,627
$5,849
$6,080
$6,320
$6,570
$6,829
$7,099
$7,379
$7,671
$7,974
$8,289
Cumulative
Cash
Flow
($86,729)
($83,328)
($79,794)
($76,119)
($72,300)
($68,329)
($64,202)
($59,912)
($55,452)
($50,817)
($45,998)
($40,988)
($35,781)
($30,368)
($24,742)
($18,893)
($12,813)
($6,493)
$77
$6,906
$14,005
$21,385
$29,056
$37,029
$45,318
Notes:
Avoided energy cost from the photovoltaic system assumes a decay in panel efficiency by 1% per year
DISCLAIMER
Energy demand, usage, and utility costs are estimated. Solar output is estimated based on default/optimal parameters using PVWATTs for Tampa, FL. Actual values may vary depending on facility
activities or other factors. No value is assigned to the Renewable Energy Certificates (RECs) because it is assumed that RECs will be retained to apply renewable energy to the facility rather than to sell it
to another party. Net metering up to the full capacity of the photovolataic system is assumed but should be confirmed with the inidividual utility.
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