Office of Solid Waste and                               EPA-540-R-11 -020
Emergency Response                                     October 2010
(5102G)                                            www.epa.gov/tio
                                         www.clu-in.org/optimization
             Remediation System Evaluation
              Colbert Landfill Superfund Site

              Spokane County, Washington

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  REMEDIATION SYSTEM EVALUATION
  COLBERT LANDFILL SUPERFUND SITE
    SPOKANE COUNTY, WASHINGTON
    Report of the Remediation System Evaluation
Site Visit Conducted at the Colbert Landfill Superfund Site
              April 13, 2010
              Final Report
            October 14, 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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                                    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).  The objective of this project is to conduct independent, expert reviews of soil and
groundwater remedies with public funding with the purpose of optimizing the remedy for
protectiveness, cost-effectiveness, and sustainability. 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.iennifer@epa.gov
Tetra Tech EM, Inc.
(Contractor to EPA)
Therese Gioia
Tetra Tech EM Inc.
1 South Wacker, Suite 3700
Chicago, IL 60606
phone: 312-201-7431
therese.gioia@tetratech.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
                                          11

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                      TABLE OF CONTENTS
NOTICE	i
PREFACE	ii
TABLE OF CONTENTS	iii
1.0  INTRODUCTION	1
    1.1 PURPOSE	1
    1.2 TEAM COMPOSITION	2
    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	4
       1.5.3    HYDROGEOLOGIC SETTING	5
       1.5.4    POTENTIAL RECEPTORS	7
       1.5.5    DESCRIPTION OF GROUNDWATERPLUME	7
2.0  SYSTEM DESCRIPTION	9
    2.1 GROUNDWATER EXTRACTION SYSTEMS	9
    2.2 GROUNDWATER TREATMENT SYSTEM	10
    2.3 COMPONENTS ASSOCIATED WITH LANDFILL POST-CLOSURE	10
       2.3.1    LANDFILL COVER	10
       2.3.2    LANDFILL GAS (LFG) SYSTEM	10
    2.4 MONITORING PROGRAM	11
       2.4.1    WATERLEVELS	11
       2.4.2    P&T PROCESS MONITORING (INCLUDING EXTRACTION WELLS)	11
       2.4.3    SAMPLING AT GROUNDWATER MONITORING WELLS	11
       2.4.4    SAMPLING AT DOMESTIC WELLS	13
       2.4.5    LANDFILL GAS (LFG) SYSTEM MONITORING	14
3.0  SYSTEM OBJECTIVES, PERFORMANCE, AND CLOSURE CRITERIA	15
    3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA	15
    3.2 TREATMENT PLANT OPERATION STANDARDS	17
4.0  FINDINGS	18
    4.1 GENERAL FINDINGS	18
    4.2 SUBSURFACE PERFORMANCE AND RESPONSE	18
       4.2.1    PLUME CAPTURE	18
       4.2.2    GROUNDWATER CONTAMINANT CONCENTRATIONS	19
       4.2.3    INSTITUTIONAL CONTROLS TO PREVENT USE OF IMPACTED
              GROUNDWATER	21
    4.3 COMPONENT PERFORMANCE	22
       4.3.1    GROUNDWATER EXTRACTION SYSTEM	22
       4.3.2    TREATMENT SYSTEM FOR EXTRACTED WATER	23
                                 in

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       4.3.3   VOCs REMOVED BY LFG SYSTEM	23
   4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF ANNUAL COSTS	24
       4.4.1   UTILITIES	24
       4.4.2   NON-UTILITY CONSUMABLES AND DISPOSAL COSTS	25
       4.4.3   LABOR	25
       4.4.4   CHEMICAL ANALYSIS	25
   4.5 APPROXIMATE ENVIRONMENTAL FOOTPRINTS ASSOCIATED WITH REMEDY	25
   4.6 RECURRING PROBLEMS OR ISSUES	26
   4.7 REGULATORY COMPLIANCE	26
   4.8 SAFETY RECORD	26
5.0  EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND
    THE ENVIRONMENT	27
   5.1 GROUNDWATER	27
   5.2 SURF ACE WATER	28
   5.3 AIR 	28
   5.4 SOIL	28
   5.5 WETLANDS AND SEDIMENTS	28
6.0  RECOMMENDATIONS	29
   6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS	29
       6.1.1   ADD MONITORING WELL WEST OF CP-W3	29
       6.1.2   INCLUDE 1,4-DioxANE IN FUTURE RESIDENTIAL SAMPLING (AT SOME
              FREQUENCY)	29
       6.1.3   TIGHTEN INSTITUTIONAL CONTROLS REGARDING GROUNDWATER USE
              AND DOCUMENT APPROACH REGARDING 1,4-DioxANE DETECTIONS	30
   6.2 RECOMMENDATIONS TO REDUCE COSTS	30
   6.3 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT	30
       6.3.1   MODIFICATIONS TO WATER LEVEL MAPS	30
       6.3.2   OTHER SUGGESTED MODIFICATIONS TO QUARTERLY REPORTS	30
   6.4 CONSIDERATIONS FOR GAINING SITE CLOSE Our	31
       6.4.1   CONSIDER SHUT DOWN TEST OF REMAINING ACTIVE EXTRACTION
              WELLS	31
   6.5 RECOMMENDATIONS FOR IMPROVED SUSTAINABILITY	32

Tables

Table 4-1.     Summary of Footprint Results
Table 6-1.     Cost Summary Table
Table 6-2.     Sustainability Summary Table for Recommendations

Attachments

Attachment A - Selected Figures from Previous Site Reports
Attachment B - Sustainability Footprints Calculations
                                  IV

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                               l.OINTRODUCTION
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, and has
also started conducting RSEs at some PRP-lead sites. A strong interest in sustainability has also
developed in the private and public sector.  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 Colbert Landfill Superfund Site was selected by EPA OSRTI based on a nomination from
EPA Region 10. The site is located approximately 2.5 miles north of Colbert, Washington, and
approximately 15 miles north of Spokane, Washington. Contaminants of concern in groundwater
are specific volatile organic compounds (VOCs):

    •   1,1,1 -Trichloroethane (TCA)
    •   1,1-Dichloroethene (DCE)
    •   1,1-Dichloroethane (DCA)
    •  Trichloroethene (TCE)

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    •   Tetrachloroethene (PCE)
    •   Methylene Chloride (MC)

There have also been low levels of 1,4-Dioxane observed in groundwater. The groundwater
remedy includes a pump-and-treat (P&T) system as well as components of landfill post-closure
(e.g., landfill cap, landfill gas system) that serve to reduce contaminant source loading to
groundwater over time. The remedy has also included the provision of an alternate water supply
to impacted residents plus institutional controls. The RSE provides an opportunity for an
independent third-party review of these remediation efforts.


1.2     TEAM COMPOSITION

The RSE team consisted of the following individuals:
Name
Peter Rich
Rob Greenwald
Affiliation
GeoTrans, Inc.
GeoTrans, Inc.
Phone
410-990-4607
732-409-0344
Email
prich@geotransinc.com
rgreenwald@geotransinc.com
In addition, the following individuals from EPA Headquarters participated in the RSE site visit.

    •   Jennifer Hovis

    •   Jennifer Edwards


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.

    •   Fourth Five Year Review Report (USEPA Region 10) - September 2009

    •   Quarterly Progress Reports (Spokane County)
          o  Second Quarter 2009
          o  Fourth Quarter 2008
          o  Third Quarter 2008
          o  Second Quarter 2008
          o  First Quarter 2008

    •   Map showing layout of landfill gas system (CH2MHill) and spreadsheet with landfill gas
       concentrations over time

    •   Operation and Maintenance  Manual (Landau Associates, Inc.), December 15, 1999

    •   Operations and Maintenance Manual for Colbert Landfill Closure (CH2MHILL) - May
       1997

    •   Final Extraction Well Plan - Phase II Remedial Design/Remedial Action (Landau
       Associates, Inc.) - August 7, 1992

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    •   Final Phase 1 Engineering Report: Volume 1 of 3 (Landau Associates, Inc.) - December
       30,1991

    •   Scope of Work for Remedial Action to Address Groundwater Contamination Emanating
       from Colbert Landfill (also referred to as the "Consent Decree") - September 27, 1988

    •   Record of Decision (downloaded without figures) - September 29, 1987

In addition, Deb Geiger from Spokane County forwarded information via email after the RSE site
visit regarding electrical usage and costs, estimated labor costs for system operation and project
management (for County personnel), specific capacity values at extraction wells, recent water
level maps, gas probe locations, results of field gas concentrations at the blower overtime, and
annual VOC analyses for extracted landfill gas (before and  after the vapor GAC units).
1.4     PERSONS CONTACTED
The following individuals associated with the site were present for the visit:
Name
Piper Peterson Lee (RPM)
Bernie Zavala
Michael Kuntz
Deb Geiger
Bill Wedlake
Larry Beard
Affiliation
U.S. EPA Region 10
U.S. EPA Region 10
Washington Dept. of
Ecology
Spokane County
Spokane County
Landau Associates
Phone
206-553-4951





Email
peterson-lee .piper(g)epa. gov





Spokane County operates the remedy, and Landau Associates is a consultant to Spokane County.
1.5     BASIC SITE INFORMATION AND SCOPE OF REVIEW
1.5.1
LOCATION
Colbert Landfill is located approximately 2.5 miles north of Colbert, Washington, and
approximately 15 miles north of Spokane, Washington (see Figure 1 from the Fourth Five Year
Review Report, included in Attachment A of this report).  The closed landfill is bounded by Elk-
Chattaroy Road on the east and Big Meadows Road on the south. Groundwater impacts
associated with the site extend west to the Little Spokane River, which is approximately 3,000
feet to the west of the closed landfill. Groundwater impacts associated with the site also extend
more than 1 mile to the south of the closed landfill. There are also groundwater impacts that
extend up to several thousand feet north and east of the closed landfill, though the exact cause of
the impacts north and east of the landfill are not fully understood.

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The closed landfill is surrounded primarily by residential developments and open lands. The area
south of the site contains forested lands, open fields, and a few residential homes. The Spokane
County Recycling Center and Transfer Station is located immediately west of the treatment
facility.   There are residences located within the footprint of the groundwater plume (i.e., beyond
the landfill) in all directions around the landfill.
1.5.2       SITE HISTORY, POTENTIAL SOURCES, AND RSE SCOPE

The 1987 ROD and the Fourth Five-Year Review (September 2009) provides the following
information:

    •   The landfill operated from 1968 to 1986. During a five year period between 1975 and
       1980 the Landfill accepted solvent and other chemical waste from Key Tronic
       Corporation (a local electronic manufacturing company) and Fairchild Air Force Base
       (FAFB). Typically these wastes were delivered to the landfill in 5 5-gallon drums and
       were subsequently poured into open trenches to mix with the soil or ordinary municipal
       refuse already in the trench.  According to Table 1 of the ROD, the solvents from Key
       Tronic were methylene chloride and 1,1,1-TCA, and the solvents from Fairchild Air
       Force Base were methyl ethyl ketone, poly thinner, enamel thinner, toluene, paint
       remover, and primer wastes.

    •   In 1980, nearby residents complained to the Eastern Regional Office of the Washington
       Department of Ecology (Ecology) about the chemical disposal practices. EPA and
       Ecology along with Spokane County Utilities Department conducted an investigation into
       these complaints by initiating a groundwater sampling study of nearby domestic water
       wells. Twenty domestic water wells had samples with contaminants at concentrations
       above drinking water standards which could in part be traced to the spent solvents
       disposed of at the landfill.

    •   Following the initial domestic groundwater sampling investigation, Phase I and II studies
       resulted in the installation of monitoring wells, injection testing, and development of a
       groundwater monitoring program. In 1983, EPA placed the Colbert Landfill on the
       National Priorities List (NPL) and identified Spokane County, Key Tronic Corporation
       and FAFB as potentially responsible parties (PRP). In 1984, Ecology entered into a
       cooperative agreement with EPA for conducting a Remedial Investigation/Feasibility
       Study (RI/FS). During that same year, bottled water was supplied to some of the
       households with high contamination levels in their water wells. In 1985, the County
       extended the Whitworth Water District public water supply main to affected households
       where concentrations of contaminants were greater than Maximum Contaminant Levels
       (MCLs), and the hookup was subsidized by the PRPs if the resident was less than 500
       feet from a water supply main, and the resident signed a hold-harmless agreement.
       Other residents who did not meet these conditions elected to receive this water supply at
       their own expense.

    •   The final RI report was completed in May 1987, and the final FS report was submitted
       for public comment in May 1987. On September 29, 1987, EPA issued the Record of
       Decision (ROD) which selected an interim final remedy for the site based on the
       Remedial Investigation/Feasibility Study (RI/FS). The selected remedy included a pump
       and treat (P&T) system for water, connection to public water for residences negatively

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       impacted by site contaminants and/or the groundwater remedy, institutional controls, and
       landfill closure and post-closure maintenance (e.g., capping, landfill gas management,
       monitoring, etc.).

    •   During the RSE site visit it was stated that there is some disagreement among the site
       stakeholders if the 1987 ROD was "interim". The RSE team notes that the term "interim
       final remedial action" is used in ROD Section VI  (Selected Remedy), and the term
       "interim final ROD" is used in the State concurrence letter (Appendix C of the  1987
       ROD). Additionally, section VI of the ROD refers to a future "final ROD" with respect
       to evaluating the closure of the landfill. These examples suggest this was intended as an
       interim ROD.

    •   On January 23,  1989, a Consent Decree between EPA, Ecology, Spokane County and
       Key Tronics Corporation was lodged in federal court. Fairchild Airforce Base contributed
       waste to the landfill; however, they were not a party to this Consent Decree. On February
       28, 1989, the Decree was entered by the Court. The Decree addressed implementation of
       remedial actions specified in the 1987 ROD.

This RSE includes a holistic third-party review of overall  site remedy.
1.5.3       HYDROGEOLOGIC SETTING

The hyrdrogeology of this site is extremely complex. The interpretation of the hydrogeologic
system presented in the ROD (1987) was subsequently updated in the Final Phase 1 Engineering
Report by Landau Associates, Inc. (1991), and the reader is referred to that document for the most
detailed description of the hydrogeologic system.  A series of cross-sections provided in the
Phase 1 Engineering Report (1991) are included in Attachment A of this RSE report. Key
components of the hydrogeologic system in the vicinity of the Colbert Landfill are described
below.

The geology consists of vertically stratified and laterally discontinuous geologic units derived
from glacial material, modified by erosional (and possibly landslide) process, overlaid on granitic
bedrock. There  are two primary aquifers (according to the fourth five-year review, the primary
aquifers would be classified as drinking water sources according to the EPA groundwater
classification system):

    •   The upper aquifer is unconfined and consists of a sand and gravel unit that extends from
        the eastern hills west to the bluffs of the Little Spokane River. Groundwater flow in the
        upper aquifer is predominantly toward the southwest and south (see January 2010 water
        level map for upper aquifer prepared by Spokane County in Attachment A), towards a
        discharge point well south of the landfill. The fluvial unit associated with the Little
        Spokane River (west of the landfill) receives some recharge from the upper aquifer, and
        there are some springs reportedly present on the bluff adjacent to the Little Spokane
        River. The Phase 1 Engineering Report (1991) stated that pump testing  performed at
        extraction well CP-S1 indicated transmissivity of 10,000 to  12,000 ft2/d, and hydraulic
        conductivity of 530 to 640 ft/day (using approximate saturated thickness of 19 ft). This
        represents very conductive aquifer material.

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    •  The lower aquifer is confined to the west of the landfill and unconfmed to the east of the
       landfill.  To the west of the landfill, the upper and lower aquifers are separated by the
       lacustrine unit which causes the confined conditions in that area. The lower aquifer
       consists of sands and gravels. Groundwater flow in the lower aquifer is predominantly
       toward the west (see January 2010 water level map for lower aquifer prepared by
       Spokane County in Attachment A), with discharge to the Little Spokane River. The
       Phase 1 Engineering Report (1991) stated that pump testing performed at extraction well
       CP-W1 indicated transmissivity of 30,000 to 40,000 ft2/d, and hydraulic conductivity of
       170 to 230 ft/day (using approximate saturated thickness of 175 ft). The Phase 1
       Engineering Report (1991) stated that pump testing performed at extraction well CP-E1
       indicated transmissivity of 10,000 to 14,000 ft2/d, and hydraulic conductivity of 100 to
       140 ft/day (using approximate saturated thickness of 100 ft). These values for hydraulic
       conductivity also represent very conductive aquifer material.

The lacustrine unit, which consists of silt and clay with sand interbeds, pinches out under the
eastern portion of the landfill, and where it is not present the upper and lower aquifers are
connected. West of the landfill, where the lacustrine unit is present, the water levels in the upper
aquifer are nearly 100 ft higher than in the lower aquifer.

Other stratigraphic units that are illustrated on the cross-sections in Attachment A (for instance,
section B-B' and C-C') include the following:

    •  Latah Formation and Weathered Latah. The Latah Formation consists of fine-grained
       lacustrine sediments that overlie the granitic bedrock. The Basalt Unit (described below)
       is interbedded within the Latah Formation.  The Weathered Latah, where present,
       overlies the Latah formation and consists of weathered material from the Latah
       Formation and also weathered material from the basalt that is contained within the Latah
       Formation. In some places the Latah/Weathered Latah are below the lower aquifer, and
       in other places the lower aquifer is absent and the  Latah/Weathered Latah are below the
       upper aquifer.

    •  Basalt Unit. Interbedded within the Latah Formation, these basalts form secondary
       aquifers that appear to be of limited extent. One of the remedy extraction wells (CP-E2)
       is completed in the basalt. The Phase 1 Engineering Report (1991) stated that pump
       testing performed at extraction well CP-E2 indicated transmissivity of 25 ft2/d, and
       hydraulic conductivity of 0.7 ft/day (using approximate saturated thickness of 35 ft).
       These parameter values are much lower than for the upper aquifer and lower aquifer, and
       limit the rate at which groundwater can be extracted.

    •  Granite. This represents the bedrock unit. As illustrated on the cross sections in
       Attachment A, the granite bedrock is several hundred feet below ground surface in the
       vicinity of the landfill.

The discontinuous nature of the lacustrine unit, the lower aquifer, and the other units
(Latah/Weathered Latah/bedrock) makes the hydrogeology extremely complex, and has impacted
the contaminant distribution and remedy design.

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1.5.4       POTENTIAL RECEPTORS

Based on discussions during the RSE site visit, the primary potential receptors are groundwater
users.  Residents whose wells have been impacted by the site have reportedly been provided
alternate water and the Spokane County Health Department has procedures in place to detect any
wells installed as part of a new development (discussed in Section 4.2.3 and Section 5.1).

The fourth five-year review summarized the potential for impacts due to vapor intrusion. It stated
that the current landfill gas management system would prevent this pathway for indoor air in
residences or businesses adjacent to the landfill.  With respect to areas away from the  landfill, the
fourth five-year review included a screening level analysis using the Johnson and Ettinger (J&E)
Vapor Intrusion Model, and concluded that the concentrations of COCs in groundwater in the
upper aquifer do not appear to pose a risk to indoor air.  The RSE team reviewed these
calculations and agrees with the conclusion that the vapor intrusion pathway does not appear to
be a concern. The J&E model incorporates a groundwater concentration value at the top of the
groundwater surface that attenuates via several mechanisms in the distance between the water
table and the structure, and the larger that distance, the lower the impact due to vapor  intrusion
will be in the structure (for a specific concentration in groundwater). The J&E calculations in the
five-year review very conservatively used a groundwater depth of only three feet (which is the
case immediately adjacent to the Little Spokane River).  The  RSE team notes that depth to
groundwater in the upper aquifer is generally on the order of 80 to 90 ft. Even using the
conservatively small depth to water, the J&E results in the five-year review suggested for most
COCs that concentrations in the upper aquifer would need to  be orders of magnitude higher than
are actually observed in the upper aquifer (e.g., the threshold concentration for 1,1,1-TCA was
greater than 5,000 ug/1).  The two constituents with relatively low threshold concentrations were
PCE (~1 ug/1) and TCE (~ 5 ug/1).  However, based on the groundwater data presented in
Attachments 3 to 5 of the five-year review (Compliance Monitoring Wells, Compliance
Extraction Wells, and MFS Wells)  the concentrations of PCE and TCE are below these threshold
levels in the upper aquifer. Coupled with the conservatively  shallow depth to groundwater
utilized for the J&E analysis, the RSE team does not feel that vapor intrusion is a concern.
1.5.5       DESCRIPTION OF GROUNDWATER PLUME

The primary site contaminants are VOCs. The observed VOC concentrations have not been high
enough to suggest the presence of any significant free product (i.e., concentrations in groundwater
are well below one percent of the aqueous solubility of each COC). As stated earlier, the
complex hydrogeology at the site has led to a complex distribution of contaminants.  The pre-
remedy plume extended to the southwest and south of the landfill in the upper aquifer, and
primarily to the west of the landfill in the lower aquifer.

Concentrations of VOCs in the upper aquifer are very low (i.e., close to cleanup standards), and
the groundwater extraction wells in the upper aquifer associated with the remedy (located more
than one mile south of the landfill) have been shut off for several years. Concentrations of VOCs
in the lower aquifer are higher than in the upper aquifer.  Figures 27 to 29 from the fourth five-
year review are included in Attachment A, and represent results from the 2007 "supplemental
monitoring" at lower aquifer wells for PCE, DCE, and TCE. These figures provide a general
summary of the concentration distribution in the lower aquifer. It is particularly noteworthy that
some of the highest concentrations in the lower aquifer are found east and south of the landfill,
which seem to be upgradient from the landfill in that aquifer. Based on discussion during the
RSE site visit, it is not certain why this occurs.

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Low concentrations of 1,4-Dioxane, which was frequently used as a stabilizer for TCA, have also
been detected in groundwater within the footprint of the VOC plume. That chemical is often
found in association with TCA, and it is likely associated with the solvents disposed of in the
landfill. There is currently no attempt made at the site to actively capture and treat groundwater
with 1,4-Dioxane levels above standards (i.e., in locations beyond the capture zone of the P&T
system); rather, if 1,4-Dioxane is found at supply wells the approach is for Spokane to provide
bottled water and then pay for a hook-up to public water.  This approach for 1,4-Dioxane is
essentially the same approach that is used in the domestic well program for the other site COCs.

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                         2.0 SYSTEM DESCRIPTION
The primary active components of the groundwater remedy include the following:

    •  A P&T system that began operation in May 1994, and has consisted of three separate
       extraction systems (only two of which are now operating). Extracted water is conveyed
       to a treatment plant with an air stripper that is located at the closed landfill, and treated
       water is discharged to surface water (Little Spokane River).

    •  Landfill post-closure components (e.g., landfill cap, landfill gas system) that serve to
       reduce contaminant source loading to groundwater overtime.

These active remedy components are discussed in more detail below. As discussed earlier, the
remedy has also included alternate water supply to impacted residents plus institutional controls.
2.1     GROUNDWATER EXTRACTION SYSTEMS

The remedy has included three groundwater extraction systems (locations indicated on Figure 3-2
from the O&M Manual which is included in Attachment A):

    •   West System - Consists of three extraction wells (CP-W1 to CP-W3) screened in the
       lower aquifer, intended to provide hydraulic containment at the western edge of the
       closed landfill. Extraction well CP-W1, which is located southwest of the closed landfill,
       was shut down in January 2005 because it achieved low concentrations of target COCs.
       The remaining two west system extraction wells currently pump on the order of 400 to
       450 gpm combined.

    •   East System - Consists of three extraction wells (CP-E1 to CP-E3) screened in lower
       aquifer and/or weathered basalt/Latah, intended to remove groundwater with highest
       concentrations located near the eastern edge of the closed landfill. CP-E1 and CP-E3
       currently pump on the order of 225 to 250 gpm combined.  CP-E2 is screened in the
       basalt and has a much lower pumping rate (approximately 0.5 to 2 gpm).

    •   South System (shut down since June 2004 due to low concentrations) - Consists of four
       extraction wells (CP-S1 and  CP-S4 to CP-S6) located more than one mile south of the
       closed landfill, screened in the upper aquifer, and intended to control contaminant
       migration to the south of those wells. During the 2006 fourth quarter groundwater
       monitoring event, water from one of the south system extraction wells had a TCE
       concentration of 3.3 ug/L, which is just over the "adjustment criteria" that is used to
       determine when wells can be shut off (discussed later). This well was reactivated and ran
       until January 2007 when concentrations of TCE decreased to below the adjustment
       criteria. All of the south extraction wells have been on standby since that date (and are
       sampled quarterly).

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The extracted groundwater from each system is conveyed through a PVC piping system
(illustrated on Figure 3-2 from the O&M Manual which is included in Attachment A) to a
treatment facility located in the southwest corner of the Landfill property.


2.2     GROUNDWATER TREATMENT SYSTEM

This is a relatively simple treatment system that consists of an air stripper that removes VOCs
from the groundwater.  The O&M manual indicates the air stripper is capable of treating up to
1600 gpm, though recent flow rates for this system have been lower (currently on the order of 650
gpm).  The air stripper has a 50 Hp blower with a motor controlled by a variable frequency drive
(VFD) such that less electricity is used when the motor is throttled down, and during the RSE site
visit the system operator indicated that the  stripper operates at approximately 15 Hz (or
approximately  10 HP).  A scale control chemical (NALCO 8357, shipped from Carson, CA) is
added to the water at a rate of 20 ml diluted solution per 1000 gallons of water (the diluted
solution is 1 part scale inhibitor to 7 parts water).  There is also a small tank near the air stripper
that was intended for use with disinfection chemicals, but those have only been used once.

There is no vapor treatment for the stripped VOCs. It was stated during the RSE site visit that
there were no permit issues for discharged  vapors based on the original flow rates and
concentrations, and the current system has  lower flow rates and lower concentrations. Treated
groundwater is discharged via gravity to the Little Spokane River through an underground 12-
inch diameter PVC pipeline.
2.3     COMPONENTS ASSOCIATED WITH LANDFILL POST-CLOSURE
2.3.1       LANDFILL COVER

The landfill cover (approximately 32 acres), installed in 1996, consists of one 60 mil (0.06" or
1.52mm) thick High Density Polyethylene (HOPE) membrane installed over a 6 in. subgrade of
prepared native material. The HOPE membrane is covered with a free-draining 18 inch sand
layer, then a 6 inch layer of topsoil. A strip drain collection system is installed directly on top of
the cover system to carry  surface water that has infiltrated through the topsoil and granular cover
material to a toe discharge system or directly into the perimeter drainage ditch. The landfill does
not have a bottom liner or leachate collection system.

2.3.2       LANDFILL GAS (LFG) SYSTEM

A landfill gas (LFG) system was installed to prevent off-site gas migration and to prevent build-
up of gas pressure. It consists of wells inside the landfill and at the perimeter of the landfill, as
well  as trenches.

The system utilizes a 15 Hp blower (no VFD). The extracted gas is treated with granular
activated carbon (GAC), followed by discharge to the atmosphere. Two condensate traps remove
condensate droplets and other particles from the gas stream, and condensate is manually drained
into a transport vehicle for treatment off-site.
                                          10

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2.4     MONITORING PROGRAM

The following components of monitoring are discussed below:

   •   Water Levels - Section 2.4.1

   •   P&T process monitoring (including extraction wells) - Section 2.4.2

   •   Sampling at groundwater monitoring wells - Section 2.4.3

   •   Sampling at domestic wells - Section 2.4.4

   •   LFG system monitoring - Section 2.4.5

Currently there are quarterly reports prepared by Spokane County that summarize monitoring
results.


2.4.1        WATER LEVELS

Water levels are measured quarterly at a variety of monitoring wells and residential wells.  In
some cases the site operator estimates values where water levels could not be collected based on
historical/recent data that are available. Water level maps for the upper and lower aquifers are
prepared using Surfer and presented in the quarterly reports.  Discussion regarding these water
level maps is presented in Section 4.2.1 of this RSE report.


2.4.2        P&T PROCESS MONITORING (INCLUDING EXTRACTION WELLS)

Process monitoring for P&T system includes the following:

   •   The extraction wells are sampled quarterly for VOCs plus field parameters (pH,
       temperature, conductivity, turbidity)

   •   Influent to the treatment system is analyzed monthly for VOCs and field parameters

   •   Effluent from the treatment system is analyzed as follows:
           o  Monthly for VOCs and field parameters
           o  Quarterly for chloride
           o  Four times per year (January, May, June, July) for total phosphorous and
              NO3+NO2
           o  Semi-annual for "toxicity"

Sampling is performed by County personnel.


2.4.3        SAMPLING AT GROUNDWATER MONITORING WELLS

Groundwater monitoring is comprised of several components:
                                         11

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    •   Compliance monitoring (24 wells)

    •   Supplemental monitoring (approximately 40 wells)

    •   Minimal Function Standards (MFS) monitoring (currently at 4 upper aquifer wells)

Each of these is described below.


Compliance Monitoring

Compliance monitoring is based on the Consent Decree and detailed in the O&M Manual.  The
compliance monitoring program is intended to focus on the down-gradient boundaries to
determine if the interception systems are containing the groundwater plume. The 24 compliance
wells are sampled annually for VOCs. The compliance monitoring cluster locations are
illustrated on Figure 8 from the fourth five-year review (which is included in Attachment A) and
are summarized below:

    •   West Extraction System. These are designated as follows.

           o   Set A monitoring well clusters (CD-41C1/2/3, CD-42C1/2/3, and CD-48C1/2/3)
               are located down-gradient of the system and monitor those portions of the lower
               aquifer believed to be within the capture zone of existing supply wells. These
               well clusters are located directly up-gradient of the existing supply wells.

           o   Set B monitoring well clusters (CD-43C1/2/3 and CD-44C1/2/3) monitor
               portions of the lower aquifer not directly impacting the water quality of the
               existing supply  wells.

           o   Two monitoring well clusters were also placed at the outboard limit of the
               interception system (CD-45Cl/2/3and CD-48C1/2/3).  One of these clusters (CD-
               48/C1/2/3) is also considered to be part of Set A.

    •   East Extraction System. The east extraction system was intended for source control and
       does not have required performance monitoring.

    •   South Interception System. Six upper aquifer monitoring wells are used to monitor
       performance: four wells are located directly down-gradient of the south extraction system
       (CD-31A1, CD-36A1, CD-37A1, and CD-38A1) and two wells are located near the
       western and eastern outboard limits of the system (CP-S3 and CD-34A1).


Supplemental Monitoring

The compliance monitoring locations listed above do not provide a comprehensive monitoring
network for tracking groundwater concentrations within much of the plume.  To address this
issue, the County voluntarily collects supplemental groundwater samples about every 5 years
throughout the  extent of the plume. The last supplemental sampling was completed in May 2007
and the data were presented in the  second quarter 2007 monitoring report.  The supplemental
                                          12

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sampling occurs at approximately 40 wells with analysis for VOCs. It was stated during the RSE
site visit that many of the monitoring wells associated with the supplemental sampling do not
have dedicated pumps, and this makes the supplemental sampling a major effort.
MFS Monitoring

The MFS groundwater monitoring is required as a component of the landfill post-closure.
Samples are analyzed for COCs plus chloride, nitrite/nitrate/ammonia, sulfate, total organic
carbon, chemical oxygen demand, iron, manganese, and zinc. Initially, quarterly sampling was
performed at a total of six wells (four in the upper aquifer and two in the lower aquifer).
Quarterly monitoring and monitoring of the two lower aquifer wells was discontinued in January
1999, and currently the four upper aquifer wells are sampled annually.  The four current MFS
monitoring locations are illustrated on Figure 8 from the fourth five-year review (which is
included in Attachment A).
2.4.4       SAMPLING AT DOMESTIC WELLS

Approximately 40 domestic wells are monitored for VOCs according to a schedule (see
Attachment 6 of the fourth five-year review). Domestic well sampling locations are illustrated on
Figure 28 from the fourth five-year review (which is included in Attachment A). According to
Section VII of the Consent Decree, all wells in the domestic well monitoring program are
required to be sampled annually. Specific wells can be sampled more frequently if necessary.
Sampling of a well may be discontinued or reduced if (1) an alternative water supply has been
provided, (2) it is determined the well is not threatened by contamination from the Colbert
Landfill Site or (3) the remedial action is complete. According to the fourth five-year review, the
County uses the following methodology to determine the appropriate sampling frequency:

    •  Quarterly - Wells near the leading edge of the plume or in areas where contaminants are
       not migrating in the direction of groundwater flow and contaminants have been detected
       at levels below Evaluation Criteria; wells in areas where contaminants exceeding
       Evaluation Criteria were detected in nearby wells; multiple user wells where
       contaminants were previously detected at levels below Evaluation Criteria.

    •  Semi-Annual - Wells in close proximity of the leading edge of the plume that are not
       separated from the plume by another well currently in the sampling program.

    •  Annual - Previously contaminated wells that currently show non-detectable levels of
       contaminants; wells without detectable concentrations of contaminants and that do not
       fall into the Bi-annual sampling category.

    •  Bi-Annual - wells previously in the sampling program that do not fall into any of the
       above categories (could be used as a transition from annual to no sampling).

    •  No Sampling - Wells hooked up to an Alternate Water Supply; wells not used for
       domestic purposes; wells that the owner requests not to be tested; no access to the
       property or sampling site.
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The fourth five-year review (September 2009) indicated there is little documentation on the
domestic wells that have been connected to municipal water since the original water supply
extension, and recommended that a review of all residences within the groundwater plume area
also be completed.  It also recommended that changes to the domestic sampling program or new
wells installed within the groundwater plume area should be documented in the quarterly reports
including the sampling frequency (quarterly, semi-annual, etc), well numbers and addresses, and
a location map.

It was stated during the RSE site visit that all potable wells were sampled once for 1,4-Dioxane
during 2008 and 2009, and there were no  detections except for one well (with a detection close to
the performance criterion).  It was stated that follow-up sampling would only occur at wells with
detections.
2.4.5       LANDFILL GAS (LFG) SYSTEM MONITORING

The LFG system is part of landfill post-closure and is not a focus of this RSE. However, the RSE
team notes that there is a variety of sampling for vacuum and landfill gas (methane and carbon
dioxide) at a variety of sampling points throughout the collection/treatment system as well as at
gas probes. The frequency of this monitoring ranges from monthly to quarterly to annually
depending on the type of location. The RSE team also notes that, in addition to field
measurements for vacuum and landfill gases, VOC analyses are performed annually, before and
after the vapor GAC, by method TO-14A (note that this is an older method than method TO-15
which is now more widely used). Additionally, Gastech (tube) readings are taken monthly after
the carbon adsorbers to monitor for possible breakthrough.
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   3.0 SYSTEM OBJECTIVES, PERFORMANCE, AND CLOSURE
                                     CRITERIA
3.1     CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA

The 1987 ROD identifies the following objectives:

   •   Prevent further spread of contaminated groundwater (in the south and west) in two
       aquifers by installing and operating interception wells and treating the extracted
       groundwater

   •   Remove contaminated materials (in the east) which have entered the aquifers and are
       contributing to the contaminant plume, by installing and operating extraction wells in the
       area where the plumes originate and treating the effluent

   •   Provide an alternate water supply system to any residents who are deprived of their
       domestic supply by demonstrated contamination from the landfill or due to the action of
       the extraction systems

The 1987 ROD stated that extraction wells and pumping rates should be implemented to prevent
contamination from migrating beyond the down-gradient extent of the plume (at the time of the
remedy implementation).  The 1987 ROD indicated the following performance criteria to be met
in groundwater to indicate completion of the remedy.
                 Groundwater Performance Standards in the 1987 ROD
Compound
1,1,1 -Trichloroethane
1 , 1 -Dichloroethene
1 , 1 -Dichloroethane
Trichloroethene
Tetrachloroethene
Methylene Chloride
Maximum Concentration
(ppb)
200
7
4050
5
0.7
2.5
Basis
MCL
MCL
MAC
MCL
le"6 cancer risk
le"6 cancer risk
         MAC = maximum acceptable concentrations values which should not be exceeded
               in water used for drinking (ingestion) or bathing (dermal) calculated in
               Risk Assessment and summarized in Table Softhe 1987 ROD

The consent decree states the following objectives for the remedial action:

    •   Prevent ingestion of contaminated groundwater

    •   Provide alternative drinking water supplies to those residents whose domestic water
       supply well(s), in use prior to the date of entry of this Consent Decree, are now
       contaminated or become contaminated at levels exceeding those described in Section
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       VIII of [the Consent Decree], or where the productivity of their existing supply well(s) is
       adversely impacted by remedial measures

    •   Prevent the further spread of contaminated groundwater and remove contamination
       related to the site from the groundwater

    •   Protect surface waters from groundwater discharges potentially harmful to aquatic
       organisms

    •   Establish institutional controls as authorized by law to promote and support remedial
       actions

    •   Prevent transfer of Constituents of Concern from water to air at levels above health
       protection criteria

The Consent Decree indicates additional criteria to the performance criteria identified in the  1987
ROD, summarized below.
          Additional Criteria Described in the Consent Decree and O&M Manual
Compound
1,1,1 -Trichloroethane
1 , 1 -Dichloroethene
1 , 1 -Dichloroethane
Trichloroethene
Tetrachloroethene
Methylene Chloride
Performance Criteria
(ppb)
200
7
4050
5
0.7
2.5
Evaluation Criteria
(ppb)
200
7
4050
5
7
25
Adjustment Criteria (a)
(ppb)
103 (South), 101 (West)
4.5
2026
3.3
na
na
(a) Calculated in O&M Manual based on method presented in the Consent Decree
na - not applicable
The Fourth Five Year Review defines these criteria as follows:

    •   Performance Criteria. Identified in the 1987 ROD (Section V, Alternatives Evaluation,
       Table 6). Numeric standards used for discharge levels of treated groundwater and
       groundwater performance standards for termination of the remedial action.

    •   Evaluation Criteria. Identified in the Consent Decree (Section IV.2.b, Table IV1). At the
       time the Consent Decree was written, quantifying PCE and MC concentrations in the
       groundwater was not possible using the available analytical methods; therefore,
       alternative evaluation criteria were developed to substitute for the performance criteria
       for these two COCs. The evaluation criteria for the remaining COCs (1,1,1-TCA; 1,1-
       DCE; 1,1 DCA; and TCE) are equal to the performance criteria.  The evaluation criteria
       for PCE and MC are ten times higher than the performance criteria. The Consent Decree
       provided for potential improvements to the analytical methods and stated: "If the levels to
       which these compounds can be accurately quantified (using Method 8010) change during
       the source of this project, the evaluation criteria will be adjusted accordingly." The
       project is now using EPA Method 524.2 to analyze for VOCs, which is capable of
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       quantifying PCE and MC to the performance criteria. For this reason, the evaluation
       criteria for PCE and MC are no longer applicable and only the performance criteria
       should be used to determine compliance.

    •   Adjustment Criteria. Identified in the Consent Decree (Section V.A.2.a, Table V-l and
       Section V.C.2.a). Adjustment criteria were developed to conservatively evaluate the need
       for extraction system operational changes and are also used to determine when an
       extraction well can be put into standby mode. The Consent Decree identified a method to
       develop adjustment criteria for indicator compounds (1,1,1-TCA; 1,1-DCA; 1,1-DCE;
       and TCE), which was equal to the lesser value of (1) the baseline concentration (average
       of the time-averaged concentrations in the performance monitoring wells following
       startup) plus 50% of the evaluation criteria or (2) 65% of the evaluation criteria.
       Adjustment criteria are only used to manage operation of the extraction systems. The
       termination of the entire remedial action will be complete when the performance criteria
       for groundwater have been met throughout the plume extent.

1,4-Dioxane was not identified as a COC but has been sampled for as an emerging contaminant.
It was stated during the RSE site visit that a performance criteria for 1,4-Dioxane at this site is 4
ug/1, which is the Washington Department of Ecology Model Toxics Control Act (MTCA)
Method B (carcinogenic)  cleanup level for  1,4-dioxane.


3.2     TREATMENT PLANT OPERATION STANDARDS

The 1987 ROD specified that the performance of the treatment plant would be to "[treat] the
wastewater effluent to or below the MCLs (40 CFR 141.65) or a similar health-based level (the
10"6 risk level  for carcinogens) for contaminants for which MCLs have not been determined."
Table 6 of the 1987 ROD presented the treatment  plant criteria, which were identical to the
remedy performance criteria described above.
             Groundwater Treatment Performance Criteria in the 1987 ROD
Compound
1,1,1 -Trichloroethane
1 , 1 -Dichloroethene
1 , 1 -Dichloroethane
Trichloroethene
Tetrachloroethene
Methylene Chloride
Treatment Performance Criteria (ppb)
200
7
4050
5
0.7
2.5
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                                  4.0FINDINGS
4.1     GENERAL FINDINGS

The RSE team observed that the active remedy components are operated by an extremely capable
and organized operator. 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 groundwater remediation
have changed overtime.


4.2     SUBSURFACE PERFORMANCE AND RESPONSE

4.2.1       PLUME CAPTURE

The design of the extraction system was intended to provide hydraulic capture in the upper
aquifer with the south system extraction wells (located more than one mile south of the site), and
to provide hydraulic capture in the lower aquifer with the west system extraction wells (located
on the western side of the closed landfill).   The east system extraction wells are intended as
source area wells and are not intended to provide plume capture.

The south system wells have generally been shut off since  2004 due to concentrations below the
pertinent criteria. Thus, the current evaluation of capture focuses on the west system extraction
wells.  Extraction well CP-W1 (located southwest of the closed landfill) has been shut off since
2005 due to low concentrations.  Extraction well CP-W2 (located at the northwest corner of the
closed landfill) generally pumps between 170 and 200 gpm. Extraction well CP-W3 (located
west of the closed landfill) generally pumps between 200 and 250 gpm.

Capture for the west system (i.e., lower aquifer) is evaluated by Spokane County using two
primary lines of evidence: potentiometric surface maps generated quarterly using the  Surfer
software, and concentration trends at the compliance monitoring wells located downgradient of
the west system extraction wells. The RSE team makes the following observations:

    •  An example of the potentiometric surface maps for the lower aquifer is provided in
       Attachment A (for lower aquifer, January 2010). The water level values used to develop
       the contours are not posted, which makes it difficult for the reader to establish the validity
       of the contours.

    •  The values used to generate this map were provided to the RSE team. Based on these
       data, it appears that the water levels at the extraction wells are utilized to generate the
       contours, which is not recommended because water levels at extraction wells are subject
       to well losses and/or inefficiencies that often make the water levels measured  in
       extraction wells lower than water levels in the surrounding aquifer materials.  Based on A
       Systematic Approach for Evaluation of Capture Zones at Pump and Treat Systems
       (EPA/600/R-08/003, January 2008), EPA recommends that piezometers be placed near
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       extraction wells for determining water levels in the aquifer adjacent to the pumping wells.
       There are no water levels available near CP-W2 (other than the pumping well itself) and
       only one well near CP-W3 (location CD-46) with no other locations nearby.

    •  The overall density of water level measurement points does not allow for extent of
       capture to be clearly discerned.  The RSE team notes that this is true for most sites, and
       other lines of evidence (such as concentration trends downgradient of the interpreted
       capture) should also be considered as is being done at this site. At this site, the lower
       aquifer compliance monitoring wells to the west of the western extraction wells along
       Hwy 2 (clusters at locations CD-41, CD-42, and CD-43) have remained generally non-
       detect for site COCs, with only a few minor detections of COCs well below criteria, and
       this is consistent with water level contour maps generated by the County which suggest
       that hydraulic containment is provided by the  extraction wells.

    •  There is no clearly defined "Target Capture Zone" for the lower aquifer described in text
       or figures of the quarterly reports.  This makes evaluation of the adequacy of hydraulic
       capture difficult to interpret within those reports. The intended capture zone for the
       lower aquifer was illustrated on  Figure 2-7 in  the Final Extraction Well Plan (Landau
       Associates, 1992) which is included in Attachment A.

    •  Some of the VOC impacts in the lower aquifer are in areas that might not be captured by
       these extraction wells. For instance, based on the supplemental sampling results (see
       figures in Attachment A) some of the highest VOC concentrations (e.g., DCE of 32.4 ug/1
       in 2007 versus performance criteria of 7, and TCE concentration of 79 ug/1 in 2007
       versus performance criteria of 5  ug/1) are located at CD-26, located appoximatelylSOO ft
       south of the closed landfill.  Based on the potentiometric surfaces, which are based on
       relatively sparse water level measurements, impacted water in this area might be captured
       by the extraction wells, but it is also possible that impacted water in this area may not be
       captured by the extraction wells.

    •  Prior to the remedy, groundwater flow in the  vicinity of CP-W3 was generally to the
       west (see, for instance, Figure ER-4.19 of the  Final Phase 1 Engineering Report), and
       there does not appear to be a compliance monitoring well due west of extraction well CP-
       W3 (see "Figure 8 - Groundwater Monitoring Locations" in Attachment A).

    •  Given the heterogeneity of the subsurface at this site, simple calculations of capture zone
       width using simplifying assumptions are likely not meaningful.

In summary, there are some uncertainties regarding the exact extent of capture, but the Surfer
maps produced by the County and the concentration histories at the compliance wells are
consistent with hydraulic capture of most, if not all, of the impacted portion of the lower aquifer.
4.2.2        GROUNDWATER CONTAMINANT CONCENTRATIONS

Groundwater concentrations have declined significantly over time at the extraction wells and
throughout the plume. Attachment A includes Figures 9 to 15 from the fourth five-year review
which illustrate concentration trends for key VOCs at the extraction wells (i.e., not included for
VOCs that are typically below performance criteria).  Observations from these figures (and the
VOC database for the site) include the following:
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    •  For the south system, COC concentrations are at or near the performance criteria (in
       some events the PCE concentrations at CP-S4 are just above the criteria of 0.7 ug/1). The
       south system extraction wells have generally been shut down since 2004 due to low
       concentrations.

    •  For the east system, the highest concentrations are at CP-E2  (e.g., TCE and DCE
       concentrations are currently on the order of 100 ug/1 at CP-E2), which is screened in
       basalt and pumps at a very low rate. The  concentrations at CP-E2 declined by
       approximately 50% between 1994 and 1998, and have remained stable since 1998. At
       the other two east system extraction wells, concentrations are lower than at CP-E2. At
       those wells concentrations declined significantly early in the remedy (e.g., DCE declined
       at CP-E1 from more than 250 ug/1 in the mid-1990s to less than 50 ug/1 by 1998), but at
       CP-E1 and CP-E3 concentrations have also been relatively stable since 1998.

    •  For the west system, CP-W1 was shut down in early 2005  due to low concentrations. At
       CP-W2 and CP-W3 concentrations of COCs are low (e.g., DCE concentrations of
       approximately 10 to 20 ug/1 versus performance criteria of 7 ug/1, and TCE
       concentrations of approximately 5 to 10 ug/1 versus performance  criteria of 5 ug/1). The
       concentrations have generally declined slowly over the course of the remedy. For
       instance, at CP-W3 the DCE concentration has declined from more than 200 ug/1 in the
       mid-1990s to approximately 10 ug/1 recently. Again, much of that decline occurred by
       1998.

Based on Attachment 3 of the fourth five-year review, the compliance wells typically exhibit low
concentrations of COCs (generally below the performance criteria).  For instance, compliance
wells CD-43C1, CD-43C2 and CD-43C3, which are located downgradient of extraction well CP-
W2, have generally been non-detect for site COCs through the entire period monitored (since
1994 when the P&T system began).  It is unclear if VOC concentrations would exceed criteria at
this compliance location  in the absence of remedy pumping.  With respect to the supplemental
sampling (which provides a more comprehensive  picture of the plume extent approximately every
five years), the fourth five-year review observed that concentrations of COCs above performance
criteria remain in the lower aquifer to the north, east, and south of the landfill. The fourth five-
year review also observed that overall size and shape of the contaminated groundwater plume has
not changed significantly since the active extraction remedy began operation in 1994, but
contaminant concentrations in the upper and lower aquifers have declined. The fourth  five-year
review attributed this to the active extraction associated with the remedy. The RSE team
attributes it to a combination of groundwater extraction and treatment, the construction of the low
permeability cap over the landfill (which essentially eliminates the infiltration of precipitation
through affected soil and further release to the aquifer), natural dilution, and to a lesser extent
other natural processes (e.g. biodegradation if present based on field  conditions) and landfill gas
extraction. As discussed later, the groundwater extraction has removed significantly more mass
of VOCs than the landfill gas extraction. However, it is not possible to determine how much of
the concentration reductions over time are attributable to the extraction versus other factors listed
above.  Initial notable concentration reductions (1994-1998), during the time when the
groundwater extraction wells were removing >10001bs/yr of VOCs, was likely due to the
groundwater extraction.  Since about 1998 concentrations at the extraction wells have remained
relatively stable, and our conceptual model is that relatively higher VOC concentrations that are
remaining in the lower permeability Latah sediments and basalt (e.g., at CP-E2 and other similar
locations) are continuing to diffuse out into the higher permeability sediments. This diffusion
causes lower (but stable) concentrations in the lower aquifer than were observed when the remedy
                                           20

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first started to operate (i.e., before significant mass was flushed/removed from the lower aquifer).
It is possible that pulsed pumping could have led to even greater mass removal over time, but
perhaps at the expense of some plume capture effectiveness.

As mentioned earlier, there have been low level detections of 1,4-Dioxane within the footprint of
the  plume.  Initial 1,4-Dioxane sampling was performed from 2005 through 2007 at every
extraction, compliance, MFS, domestic and supplemental well in both the upper and lower
aquifers of the Colbert Landfill site program at least one time.  Subsequent sampling was
performed quarterly at wells selected near known concentrations of 1,4-dioxane as outlined in a
Work Plan approved by EPA and Ecology (not reviewed by the RSE team). This quarterly
sampling concluded in April 2009 and is currently ongoing on an annual basis. Based on the
Second Quarter 2009 Progress Report (Chapter 6) concentrations of 1,4-Dioxane were detected at
five of the six locations.  The locations and results are illustrated on Figures 6-1 and 6-2 and
Table 6-2 from the Second Quarter 2009 Progress Report, which are included in Attachment A.
The highest concentrations were at CD-40C1 (southwest of the landfill near Little Spokane River
with 1,4-Dioxane concentrations up to 13 ug/1) and at south system extraction well CP-S1 (with
1,4-Dioxane concentrations up to 20 ug/1). These exceed the MTCA Method B cleanup standard
of 4 ug/1, and do not appear to be within the capture zone of the P&T system. There is currently
no attempt made  at the site to actively capture and treat groundwater with 1,4-Dioxane levels
above standards (i.e., in locations beyond the capture zone of the P&T system); rather, if 1,4-
Dioxane is found at supply wells the approach is for Spokane to provide bottled water and then
pay for a hook-up to public water.  This approach for 1,4-Dioxane is essentially the same
approach that is used in the domestic well program for the other site COCs. The fourth five-year
review recommends that sampling of wells with concentrations of 1,4-dioxane above cleanup
criteria be included in the long-term monitoring program.
4.2.3       INSTITUTIONAL CONTROLS TO PREVENT USE OF IMPACTED
            GROUNDWATER
The following description is provided in the fourth five-year review regarding the procedures for
preventing consumption of impacted water:

       The Spokane County Health Department maintains procedures for groundwater
       protection and prevention of the use of contaminated water within the Colbert
       Landfill plume boundaries. The follow ing procedures were described by Jim
       Sackville-West of the Spokane County Health Department. The historical extent
       of the 1,1,1-TCA plume is used to define the groundwater protection area. For
       reference, the 1994/1995 1,1,1-TCE plumes for the upper and lower aquifers are
       presented on Figures 4 and 6 [of the fourth five-year review]. According to
       Spokane County Health Department officials, new wells are identified through
       applications for new development. If a proposed development is within the plume
       boundaries, they are encouraged to connect to municipal water. If a proposed
       residence is within 0.5 miles of the plume boundary and a well is installed, the
       Health Department will sample the groundwater for VOCs to verify that
       groundwater is not contaminated. This procedure does not detect any new wells
       that would be installed at existing residences; however, the Health Department
       reviews start cards (i.e. notice of intent to construct a water well) from Ecology
       for new wells and should be able to detect wells installed within the groundwater
       protection area. No official documentation of these procedures exists;
                                          21

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       maintenance of such procedures is based on Health Department officials working
       in conjunction with Ecology to ensure institutional controls for the Colbert
       Landfill area are met. An Institutional Control Plan is needed to ensure that the
       process for permitting wells is protective of human health and a lead agency is
       designated for oversight.

The RSE team concurs with the five-year review findings that the current institutional controls
are somewhat lacking with respect to documentation of procedures.
4.3     COMPONENT PERFORMANCE

4.3.1       GROUND WATER EXTRACTION SYSTEM

Information about the extraction pumps is provided below.

                             Extraction Pump Information
Extraction
Well
CP-W1
CP-W2
CP-W3
CP-E1
CP-E2
CP-E3
CP-S1
CP-S4
CP-S5
CP-S6
Original Pump
Size(1)
(Hp)
30
30
30
20
0.75
20
10
10
7.5
7.5
Designed Pump
Capacity'-1'1
(gpm)
250
250
250
200
6
200
90
90
90
90
Converted to
Newer
VFD?(3)
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
Typical Current
Pumping Rate(2)
(gpm)
0
170-200
200-250
125-135
0-2
100-120
0
0
0
0
       (l)from O&MManual
       (2) based on specific capacity calculation spreadsheet provided by system operator, except
          CP- Wl based on fourth five-year review report
       (3) All extraction wells were originally installed with VFDs. Spokane County is currently
           replacing old VFDs with newer more efficient models that don't require the inclusion of an
           air conditioning unit, thus saving on power and associated equipment and repair costs.

Wells may be operated by either a flow mode or a level mode setting. Unless there is a need to
acquire a specific flow or the level instrumentation is in repair, wells are operated using level
controls that are set by the plant operator. For the western extraction wells, the operator seeks a
balance between maximizing extracted concentrations and achieving adequate capture based on
her experience interpreting capture for the system.  The east and west system well pumps (except
CP-E3) have had the original variable frequency drive (VFD) motors updated to newer models,
and during the RSE site visit the system operator said that the VFDs for the operating extraction
wells are running at anywhere from 65% to 98% of possible output based on  a scale of 30 to
60Hz. There are plans to update the VFD at CP-E3.  The south system has had updates to the
VFDs since the wells are no longer in use.  Each well has its own totalizing flow meter and
electricity meter.
                                          22

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4.3.2        TREATMENT SYSTEM FOR EXTRACTED WATER

Quarterly progress reports prepared by the County include calculations of mass of the COCs
removed by the groundwater extraction system. In the report for Q2 2009, the total mass
removed to date was reported to be approximately 10,500 Ibs, and the current removal rate was
estimated at approximately 200 Ibs/yr.  Figure 2-18 of that same report suggests that the mass
removal rate was much higher (more than 1,000 Ibs/month) when the system was first operated in
1997, but stabilized at values similar to current levels by approximately 2002.
4.3.3        VOCs REMOVED BY LFG SYSTEM

The County provided the RSE team with TO-14a results for a variety of dates.  The RSE team
calculated mass removed by the LFG system for three dates (August 1996, August 1997, and July
2004) for the following four major COCs: DCA, DCE, TCA, and TCE (PCE concentrations were
minimal and VC concentrations were low and inconsistent):
   •   August 1996:
          o  DCA= 460 ppbv
          o  DCE = 600 ppbv
          o  TCA = 240 ppbv
          o  TCE=  28 ppbv
          o  Approximate flow rate of 200 cfm
          o  Calculate mass removed =38 Ibs/yr

   •   August 1997
          o  DCA= 290 ppbv
          o  DCE =190 ppbv
          o  TCA = 190 ppbv
          o  TCE=  24 ppbv
          o  Approximate flow rate of 200 cfm
          o  Calculated mass removed = 21 Ibs/yr
   •   July 2004
          o   DCA= 33 ppbv
          o   DCE = 62 ppbv
          o   TCA = 17 ppbv
          o   TCE = 9.9 ppbv
          o   Approximate flow rate of 50 cfm
          o   Calculated mass removed = 1 Ib/yr

To calculate mass, the concentrations in ppbv must first be converted to units of ug/m3
                       Conc(ppbv)   1 mole air   1000L  lOOOmg
                          	^	x	x	;
                           106         24.1L      m3
Cair(ug/ m3) =	—6	x -^TTT- x        x	x MWX
                                       23

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where MWX is the molecular weight of each compound in grams per mole (DCA = 99, DCE
97, TCA = 133, and TCE = 131).  Then the mass (Mair in Ibs/day) is calculated as follows:
                 air = Qair x Cair x
Where Qair is the flow rate (cfm).
                                 0.0283 m3    1440 mm.   2.2 Ibs.
                                     ft3
                                    day
109ug
It is evident from the data and calculations provided above that the extracted landfill gas
concentrations declined overtime, and the mass removed by the LFG system (less than 50 Ibs per
year in the mid-1990s and 1 Ib per year recently) is far lower than the mass removed by the
groundwater extraction wells (which was initially more than 1,000 Ibs per year and is currently on
the order of 200 Ibs per year).


4.4     COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
            ANNUAL COSTS

Rough annual cost estimates for operating this remedy are summarized below, based on
information provided by the site team and/or estimated by the RSE team based on discussions
with the site team.
Item Description
Project Management (County)
O&M Labor including sampling (County)
Electricity
Materials
Vapor Carbon for LFG System
Scale Inhibitor for Air Stripper
Other
Misc Equipment/Supplies etc.
Lab Analysis

Total Estimated Annual Cost
Approximate Annual Cost*
$ 26,000
$215,000
$ 54,000
$ 10,000
$ 6,600
$ 3,400
$15,000
$22,000

$352,000
       *does not include supplemental groundwater sampling approximately every 5 years

Additional details regarding these items are provided below.
4.4.1
UTILITIES
The site operator provided electric usage and costs by month for each of the 10 extraction wells,
plus the "plant" which includes the LFG system blower. The total usage for 2009 was
approximately 703,000 kWh and the total cost for 2009 was approximately $54,000. This
translates to an approximate unit cost of $0.08 per kWh. The site operator indicates the rate for
the extraction wells is slightly higher than this amount per kWh, and the rate for the plant is
slightly lower than this amount per kWh, resulting in the blended rate of $0.08 per kWh.
                                         24

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4.4.2       NON-UTILITY CONSUMABLES AND DISPOSAL COSTS

Based on discussions during the RSE site visit, the vapor carbon for the LFG system requires
approximately 4,400 Ibs exchanged each year by Siemens (located in the Yakima area). The
scale inhibitor cost is approximately $6,600 per year.
4.4.3       LABOR

Estimated costs were provided by the County for routine project management ($26,000 per year)
and O&M ($215,000 per year). The O&M labor includes operating the treatment plant and the
LFG system, all related sampling for process monitoring and groundwater monitoring, and
reporting.
4.4.4       CHEMICAL ANALYSIS

There are likely on the order of 200 samples per year for VOCs consisting of extraction wells
samples (40 per year), influent/effluent samples (24 per year), compliance well samples (24 per
year), MFS samples (4 per year), domestic well samples (approximately 80 per year), and various
duplicates and blanks. Assuming VOC analysis cost of approximately $100/sample, this would
translate to approximately $20,000 per year. Additional lab analyses, such as the annual TO-14a
for the LFG system, influent/effluent, toxicity testing for treatment plant process water, and the
additional parameters for the MFS samples, should be minimal (less than ~$2,000 per year).
Thus, the RSE team estimates that laboratory analysis cost is on the order of $22,000 per year.
Note that this does not include supplemental groundwater sampling that is conducted
approximately every five years.  It also does not include extra analysis for 1,4 dioxane, which
likely requires approximately  $150 additional per sample.
4.5     APPROXIMATE ENVIRONMENTAL FOOTPRINTS ASSOCIATED WITH
            REMEDY

Direct energy usage for the site includes electricity and diesel associated with materials
transportation.  Energy is also associated with manufacturing of materials that are used at the site
(e.g., vapor GAC and scaling inhibitor). We have not included off-site services associated with
laboratory analysis. Air emissions of greenhouse gases, nitrogen oxides (NOx) and sulfur oxides
(SOx) result from the direct energy usage and from manufacturing site-related materials.
Greenhouse gas emissions are of global concern, and other pollutants are of more local concern as
they adversely affect local/regional air quality. Briefly, nitrogen oxides (NOx) are respiratory
irritants and precursors to ground level  ozone. Sulfur dioxide is also a respiratory irritant and is a
precursor to acid  rain. Emissions of other pollutants may also be of concern, but these common
pollutants were selected because emissions information is more readily available for them and
they may be adequate indicators for other potential air emissions.

Spreadsheets were used to calculate the energy and emissions footprints  for the remedy on an
annual basis(see Attachment B). The landfill gas system is included in these  calculations (e.g.,
electricity and methane), though CO2 for the landfill gas system is not included in GHG emission
                                          25

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because similar CO2 would ultimately be emitted under any approach.  Footprint results are
summarized in Table 4.1.

                        Table 4.1 Summary of Footprint Results
Green and Sustainable Remediation Parameter
Greenhouse gas emissions
Nitrogen oxide emissions
Sulfur oxide emissions
Total energy use
Water use (groundwater extraction)
Annual Value
(per year)
990,7751bs CO2e
617 Ibs
971 Ibs
8,471, 922 MMbtu
343,210,000 gallons
              CO2e = carbon dioxide equivalents of global warming potential
              MMbtu = million British thermal units
For the greenhouse gas emissions (CO2e) approximately 83% is from methane emissions from
landfill gas, approximately 11% is from electricity use, and the remaining 6% is from various
other activities. By contrast, almost all of the energy use is associated with electricity use.  The
disparity between greenhouse gas emissions and energy use is because over 80% of the electricity
provided by the local electricity provider is from hydropower.

With respect to water usage, essentially all of the water use is from the groundwater extraction
system.  The water that is extracted and treated from this system is discharged to Little Spokane
River, and therefore is unavailable as a resource for groundwater usage.

Waste disposal associated with this remedy is minimal. With respect to more qualitative issues,
the remedy does not cause any aesthetic issues (noise, visual, odor) and there are no major traffic
issues associated with the remedy that would impact the surrounding land or ecosystems.


4.6     RECURRING PROBLEMS OR ISSUES

No significant issues reported.


4.7     REGULATORY  COMPLIANCE

During the RSE process, the site team did not report any exceedances of discharge standards or
other compliance related standards.


4.8     SAFETY RECORD

During the RSE process, the site team did not report any health and safety concerns or incidents
related to the remedial activities.
                                         26

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   5.0EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
                     HEALTH AND THE ENVIRONMENT
5.1     GROUND WATER

The following protectiveness statement was included in the fourth five-year review:

    The remedy at the Colbert Landfill Site currently protects human health and the
    environment because residences with affected wells have been connected to County
    water supplies; the groundwater extraction systems are preventing further migration of
    the groundwater plume; domestic wells are sampled on a schedule to confirm that the
    drinking water exposure pathway is blocked; and the Spokane County Health
    Department has procedures in place to detect any wells installed as part of a new
    development.

    However, in  order for the remedy to  be protective of human health and the environment
    in the long term the following actions need to be taken:

           •  Put restrictive covenants  in place for the landfill and complete an
              Institutional Controls Plan that documents procedures to control
              installation of domestic wells.

           •  Improve the current groundwater monitoring program to track the
              remaining contaminant concentrations within the plume area. Currently,
              the County voluntarily collects samples throughout the plumes (upper
              and lower aquifer) approximately every five years to account for this
              short coming.

           •  Conduct a RSE to determine if the current extraction system is adequate
              to maintain containment and/or achieve long term cleanup goals within a
              reasonable timeframe.

The RSE team is not certain that the current groundwater extraction from the east and west
systems adds to the overall protectiveness of the remedy, for the following reasons:

    •   Initial concentration reductions at the extraction wells (1994 to 1998) were likely due to
       flushing and mass removal associated with the P&T system plus the implementation of
       landfill post-closure systems (capping, landfill gas collection, etc.). However, there have
       only been minor concentration reductions at the extraction wells since 1998, and it is not
       clear if continued extraction leads to meaningfully reduced concentrations of COCs
       observed in the lower aquifer.

    •   The overall extent of the VOC plume in the lower aquifer has not changed significantly,
       although concentrations have gone down over the course of the remedy. If extraction did
       not continue, it is not clear that the plume extent would subsequently grow and/or that
       concentrations of COCs away from the landfill would increase, given the remaining
                                          27

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       strength of the contaminant source which has been reduced over time by groundwater
       remedy extraction and engineered controls such as landfill capping.

The RSE team believes this is a challenging site because there are diffuse COC concentrations in
the lower aquifer over a large area, with some apparent source areas to the north, east, and/or
south of the actual landfill. It is likely that some low levels of VOCs (and 1,4-dioxane) will
persist above performance standards for some period of time over a large area, some of which are
beyond the capture zone of the P&T system.   These relatively low level concentrations of the
COCs (and 1-4-Dioxane) that persist are being addressed with a combination of domestic well
sampling, institutional controls, and hook-ups to public water. The RSE team agrees that this
general approach is appropriate, given the complex nature of the site  and the large extent of a
diffuse plume. The RSE team also feels that a shut-down test of the remaining extraction wells
may be appropriate, in conjunction with some increased monitoring, to determine if terminating
extraction has a negative impact on water quality.  The RSE team also agrees with the fourth
five-year review that the process for documenting and implementing  the institutional controls
should be improved,  and that the process for sampling VOCs and 1,4-Dioxane throughout the
plume footprint should be more clearly defined.


5.2     SURFACE WATER

The RSE did not focus on surface water, but the RSE team believes it is very unlikely that the low
levels of VOCs observed in the groundwater plume would have negative impacts on surface
water quality, including the Little Spokane River.


5.3     AIR

The fourth five-year review summarized the potential for impacts due to vapor intrusion. It stated
that the current landfill gas management system would prevent this pathway for indoor air in
residences or businesses adjacent to the landfill. With respect to areas away from the landfill, the
fourth five-year review included a screening level analysis using the Johnson and Ettinger (J&E)
Vapor Intrusion Model, and concluded that the concentrations of COCs in groundwater do not
appear to pose a risk  to indoor air.  As discussed in Section 1.5.4, the RSE team agrees that vapor
intrusion does not appear to be a concern.


5.4     SOIL

Not addressed as part of the RSE, but not expected to be a concern.


5.5     WETLANDS AND SEDIMENTS

Not addressed as part of the RSE, but not expected to be a concern.
                                          28

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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.


6.1     RECOMMENDATIONS TO IMPROVE EFFECTIVENESS
6.1.1       ADD MONITORING WELL WEST OF CP-W3

As noted in Section 4.2.1, there does not appear to be a compliance monitoring due west of extraction
well CP-W3, and based on the figures included in Attachment A, there also do not appear to be
supplemental or domestic monitoring wells in that region. If a shut-down test of the P&T system is to be
considered, it will be important to have at least one monitoring well due west of CP-W3. It is
recommended that at least one monitoring well be drilled to the west of CP-W3 (i.e., between the CD-42
and CD-43 compliance locations), perhaps at a depth consistent with CD-42C2 and CD-43C2 (i.e.,
middle of lower aquifer). Based on cross-section E-E' in Attachment A, this would correspond to a depth
of approximately 300 ft, and using a generic approximate cost of $100/ft for well installation (including
oversight and associated equipment and logistics), this would require a capital cost of approximately
$30,000 (assuming no major access limitations). Note this is not a site-specific cost estimate, it is only
intended as a rough estimate. Annual sampling of this well for VOCs (similar schedule as compliance
wells) would have a minor cost impact (perhaps $500/yr). This well will provide valuable information
under continued pumping conditions, and is especially important for monitoring a shut-down test of the
extraction system if that occurs (see Section 6.4.1).
6.1.2        INCLUDE 1,4-DioxANE IN FUTURE RESIDENTIAL SAMPLING (AT SOME
             FREQUENCY)

As discussed in Section 4.2.2, there have been low level detections of 1,4-Dioxane within the footprint of
the plume. It was stated during the RSE site visit that follow-up sampling for 1,4-dioxane at residential
wells would only occur for wells with detections. The RSE team recommends that future residential well
samples be analyzed for 1,4-Dioxane (at some frequency) in addition to the other COCs.  The lack of a
detection for 1,4-Dioxane in one sampling event does not guarantee that future detections will not occur
at that location, especially if the flow system changes (for instance, due to changes in remedy pumping).
Perhaps the 1,4-Dioxane analysis at residences could be done at reduced frequency relative to other
COC's. Assuming 80 residential samples are taken per year for other site COCs, and analysis for 1,4-
Dioxane is performed for every other sample over time at each residential well (i.e., 40 analyses per year
for 1,4-Dioxane), and a cost of approximately  $150 per analysis for 1,4-Dioxane, this should add
approximately $8,000 per year of cost for analysis and reporting.  The actual frequency for 1,4-Dioxane
analysis should be worked out by site stakeholders, and could possibly be different for wells in different
locations. The RSE team recommendation, however, is that residential wells not be excluded from all
future analysis for 1,4-Dioxane base on one result of "non-detect".
                                         29

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6.1.3        TIGHTEN INSTITUTIONAL CONTROLS REGARDING GROUND WATER USE AND
            DOCUMENT APPROACH REGARDING 1,4-DioxANE DETECTIONS

As discussed in Section 5.1, the RSE team agrees with the fourth five-year review that the process for
documenting and implementing the institutional controls should be improved. Based on the RSE site visit
and the documents reviewed, it appears that the current implementation of the institutional controls is
likely effective but not fully documented or formalized. Furthermore, it was stated during the RSE site
visit that if 1,4-Dioxane is detected at "high enough levels" (assumed to be 4 ug/1, which is the MTCA
Method B cleanup level), Spokane County then provides bottled water and subsequently pays for a hook-
up to public water. However, the RSE team is not aware if this approach has been formally documented
as part of the remedy, and recommends that this be documented more clearly. The RSE does not have a
basis for quantifying the cost of implementing this recommendation to tighten and document the
institutional controls, buts suspects it could cost on the order of $40,000 to address this recommendation
for the entire site.


6.2     RECOMMENDATIONS TO REDUCE COSTS

None are provided above and beyond the potential cost savings associated with recommendations in  other
categories.
6.3     RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT
6.3.1        MODIFICATIONS TO WATER LEVEL MAPS

It is recommended that future water level maps include posted data values. If necessary, the plots can be
zoomed in to the area of interest (using the limits and scale properties in Surfer) so the labels can be
viewed. Also, it is best to avoid use of water levels from pumping wells, but if they are to be used it
should be clearly noted on the water levels maps. Also, in some cases the site operator estimates values
where water levels could not be collected based on historical/recent data that are available. It is
recommended that any estimated water levels be clearly documented on figures and/or tables associated
with the water levels. Implementing this recommendation is not expected to have any cost impact.
6.3.2        OTHER SUGGESTED MODIFICATIONS TO QUARTERLY REPORTS

The quarterly reports present an impressive amount of information. It is recommended that an executive
summary be included to indicate any important (i.e., non-routine) changes or observations from the
reporting period. Also, there are some instances where concentrations for domestic wells are reported as
"ND" and it is recommended that the detection limits be included (i.e., "1 U" or "< 1"). Implementing
this recommendation is not expected to have any cost impact.
                                        30

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6.4     CONSIDERATIONS FOR GAINING SITE CLOSE OUT
6.4.1        CONSIDER SHUT DOWN TEST OF REMAINING ACTIVE EXTRACTION WELLS

As discussed in Section 5.1, the RSE team is not certain that the current groundwater extraction from the
east and west systems adds to the overall protectiveness of the remedy.  The RSE team believes it is
technically reasonable to consider a shut-down test of the remaining extraction wells, with monitoring to
determine if concentrations increase significantly downgradient of the landfill (including at the new
monitoring well west of extraction well CP-W3 recommended in Section 6.1.1).

A shut-down test seems technically appropriate given that source area strength has been reduced due to
previous groundwater extraction associated with the remedy, plus engineering controls for the closed
landfill such as the cap. The concentrations at the remedy extraction wells are quite low (except CP-E2,
which removes water from the basalt at a very low rate). There  are many areas at distance from the
landfill with relatively low COC concentrations that are nevertheless above cleanup standards (i.e., a
diffuse plume over a large area), and the overall extent of the COC plume  has not been changed
dramatically since the remedy began operation.  It is not clear that the current P&T system will achieve
the goal of remediating groundwater to cleanup levels throughout the  entire impacted area.  The impacted
areas away from the landfill are being addressed with a combination of domestic sampling, institutional
controls, and water hookups, and this seems appropriate. This shut down test and associated monitoring
can help determine if a final remedy at the site should or should not include P&T, and can also indicate if
a TI waver should be considered as part of the final remedy. Given the low concentrations of COCs over a
large area, there are no in-situ technologies that could reasonably be suggested to achieve cleanup levels
throughout the plume.  If the shutdown test indicates that the P&T system provides no significant benefit
with respect to achieving cleanup levels, and there are no identified alternatives that are likely to achieve
cleanup goals throughout the plume, then evaluating a TI waiver as part of the final remedy may be
appropriate.

Although a shut-down test may be technically reasonable, it is beyond the scope of the RSE to determine
how to implement such a test given the existing ROD, Consent Decree, and EPA policy. It is anticipated
that this would require substantial work among the stakeholders to develop an acceptable approach and
work plan. The approach and work plan would need to establish a monitoring program and related
triggers for turning back on the P&T system based on observed concentrations and concentration trends.
The existing compliance monitoring wells west of the landfill, plus the suggested new monitoring well
west of CP-W3, would provide a good network for monitoring potential plume migration to the west after
a shut down test is initiated. Groundwater flow in the lower aquifer near CP-W1 was reported to be on
the order of 0.6 feet/day (approximately 200 feet/year) per year in the 1991 Final Phase 1 Engineering
Report, and the pertinent compliance wells are on the order of 1,000 feet west of the western extraction
wells, so the shut down test will have to be monitored initially for years to determine if there are
unacceptable results. The RSE team has no basis for calculating the required level of effort for
establishing a shut down test approach and work plan. The RSE team notes that a shut-down test should
not be implemented until effectiveness recommendations 6.1.1 to 6.1.3 provided above are all
implemented, to ensure protectiveness of the remedy during the shutdown test and to better monitor the
shutdown test.

A shutdown test would likely lead to significant annual cost savings.  It would eliminate approximately
$45,000 per year of electrical usage, and approximately $15,000 of materials and supplies (such as  the
anti-scaling chemical and other miscellaneous supplies). It is assumed that quarterly sampling at the
extraction wells would continue, but it would eliminate process monitoring analysis costs for influent and
                                          31

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effluent (approximately 24 samples per year for VOCs plus toxicity testing), which likely would save
approximately $4,000 per year. We assume that some significant savings would be realized on labor
(perhaps a savings of $70,000 from the estimated $215,000 per year for the current system, since there
would still be labor associated with monitoring, reporting, landfill gas control, etc). These add up to
approximately $134,000 per year of savings.  We anticipate that the work plan developed to implement a
shut-down test may include some additional sampling frequency at selected wells west of the landfill,
perhaps reducing the net savings to approximately $125,000 per year. It is noted, however, that this
recommendation for a shut-down test is made primarily with regard to potential for achieving site
closeout, and the potential cost savings associated with a shut down test should not be the primary basis
for determining  if this approach is acceptable to all stakeholders.

Implementing this recommendation will preclude the need to add additional water level monitoring points
to better resolve capture zones for the extraction wells.  If the extraction system is expected to operate for
a long time into the future, then additional water level measurement locations would be recommended for
drawing improved potentiometric surface maps, particularly at locations near the extraction wells (to
preclude the use of water levels at extraction wells) to be consistent with EPA guidance regarding capture
zone evaluation.  Therefore, it is likely that the addition of multiple new water level measurement points
would be appropriate if a shut-down test is not anticipated, but we have not quantified the costs since we
believe the  shut-down test is merited.

Although this recommendation for a shut-down test is not being made based on sustainability
considerations, a shut-down test would also have positive results with respect to sustainability.  The
current system uses approximately 700,000 kWh per year of electricity, and the vast majority of that
would be eliminated (electricity would still be required for the LFG system, which we estimate is
approximately 17% of the electricity usage).  The use and transport of the anti-scaling chemical would
also be eliminated.  In sum, we estimate that implementing this recommendation would cut the calculated
greenhouse gas emissions per year (CO2e per year) from approximately 794,708 Ibs to approximately
136,903 Ibs (approximately an 83% reduction). Reductions in NOX and SOX would scale accordingly.
6.5     RECOMMENDATIONS FOR IMPROVED SUSTAINABILITY

The site team has initially implemented VFDs for motors, and has upgraded these VFDs for most of the
motors used in the remedy, which is commendable.  No specific recommendations for sustainability are
recommended. As discussed earlier, a shut-down test at the remaining extraction wells would eliminate
significant electrical usage and some supplies, but the recommendation is made on the basis of costs
savings and not sustainability.
                                          32

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                                   Table 6-1. Cost Summary Table

Recommendation


6.1.1 Add Monitoring
Well West Of CP-W3
6.1.2 Include 1,4-
Dioxane In Future
Residential Sampling (At
Some Frequency)
6.1.3 Tighten Institution
Controls Regarding
Groundwater Use And
Document Approach
Regarding 1,4-Dioxane
Detections
6.3.1 Modifications To
Water Level Maps
6.3.2 Other Suggested
Modifications To Quarterly
Reports
6.4.1 Consider Shut-
Down Test Of Remaining
Active Extraction Wells

Reason


Effectiveness

Effectiveness



Effectiveness


Technical
Improvement
Technical
Improvement

Site Closeout


Additional
Capital Costs
($}


$30,000

$0



$40,000



$0
$0
Not quantified,
potentially
substantial

Estimated
Change in
Annual Costs
($/yr)

$500

$8,000***



$0



$0
$0

(125,000)


Estimated
Change in Life-
Cycle Costs
$*

$37,500

$120,000



$40,000



$0
$0

($1,850,000)

Estimated
Change in Life-
Cycle Costs
(net present
value)
$**
$40,000

$160,000



$40,000



$0
$0

($2,500,000)

Costs in parentheses imply cost reductions
* assumes 20 years of operation with a discount rate of 0% (i.e., no discounting)
** assumes 20 years of operation with a discount rate of 3% and no discounting in the first year
***assumes 80 residential samples per year for site COCs, but only every other sample per well over time sampled
    for 1,4-Dioxane (i.e., 40 per year for 1,4-Dioxane)

-------
Table 6-2. Sustainability Summary Table for Recommendations
Recommendation
6.1.1 Add Monitoring Well
WestOfCP-W3
6.1.2 Include 1,4-Dioxane In
Future Residential Sampling (At
Some Frequency)
6.1.3 Tighten Institution
Controls Regarding Groundwater
Use And Document Approach
Regarding 1,4-Dioxane
Detections
6.3.1 Modifications To Water
Level Maps
6.3.2 Other Suggested
Modifications To Quarterly
Reports
6.4.1 Consider Shut-Down
Test Of Remaining Active
Extraction Wells
Reason
Effectiveness
Effectiveness
Effectiveness
Technical
Improvement
Technical
Improvement
Cost-Effectiveness
Effects on Sustainability
Minor
Minor
None
None
None
Major

-------
            ATTACHMENT A





SELECTED FRIGURES FROM SITE DOCUMENTS

-------
                                                 Colbert
                                         SJ  /Landfill
Figure 1.  Location of Colbert Landfill
                                                            From Fourth Five-Year Review (September 2009)

-------
:i
                                                                                                 s
                                                                                                              I   Big Meadows Rd.
                                                                                                                                s
                                                                                                                     V. v^.^^yA. M.* K
                          Approximate Scale in Feet
                                                                                                      CD-42  Approximate Location
                                                                                                              and Identification of
                                                                                                              RA Compfiance
                                                                                                              Monitoring Well
                                                                                                   ©CP-S1  Approximate Location
                                                                                                              and Wentiecatlon of
                                                                                                              RA Extraction Well

                                                                                                      ^      Route for Pipeline with
                                                                                                              Flow Direction
                                                                                                              Indicated by Arrow
                                                                                                   Source: Landau Associate* 1995
                                               Remediation Action System Components
Figure 3-2
                                                                                   From O&M Manual (Landau Associates, December 1999)

-------
                                                                                              APPROXIMATE LOCATIONS
                                                                                              OF MONITORING WELLS
                                                                                              APPROXIMATE LOCATIONS
                                                                                              OF DOMESTIC WELLS
                                                                                              APPROXIMATE LOCATIONS
                                                                                              OF EXTRACTION WELLS
                                                                                              APPROXIMATE LOCATION
                                                                                              OF PIPELINE
         Compliance
         Monitoring Well
   O    MFS Monitoring Well
Figure 8.  Groundwater Monitoring Locations
                                                                           From Fourth Five-Year Review (September 2009)

-------
Upper Aquifer             K~3
Groundwater Elevation Contours \
January 2010
(Provided by Spokane County)
Groundwater Elevation Contours
 /
             Bemhill Rd

-------
Lower Aquifer
Groundwater Elevation Contours
January 2010
(Provided by Spokane County)

-------
  .1
  1
  LU
  1
                                                               Lo Dolce Rd.
          iAPPROXIMATE EXTENT OF
           WEST INTERCEPTION SYSTEM
           AND EAST EXTRACTION
           SYSTEM CAPTURE ZONE
                                                                 SingknnMLane

                                                                          £
                                                                      COLBERT
                                                                      LANDFILL
                                                                                                N
                                                                                          Big Meadows Rd.
                                                                           APPROXIMATE EASTERN
                                                                           EDGE OF LOWER
                                                                           SAND/GRAVEL AQUIFER
                                                                              Designation and Approximate Location
                                                                              of Planned Extraction Wall
                                                                     CP-W1©  Donation and Appro
          Approximate Scale in Feet
                                                                              of Exiting Extraction Wall

                                                                          A  Appiwdmate Location of Private We»
                                                                              Downgradlent of Lower Sand/Gravel
                                                                              Aquifer Contaminant Plume
                                                                                             water Eta
                   167-1 Model-generated Grou
                       ' ConKKir Under Pumping CondWorw
                    Combined West Interception and East Extraction System Capture Zone
                                      Figure 2-7
From Final Extraction Well Plan (Landau Associates, 1992)
2-15
                                                                          LANDAU ASSOCIATES, INC.

-------
 KEY

CD-459
   B

A    A'
Designation and Approximate
Location of Phase I Monitoring Well

Approximate Location of Phase I
Pilot Extraction Well

Approximate Location of Phase I
Boring

Approximate Location of Monitoring
Well Constructed Prior to Phase I
           Location of Geologic Cross Section
                                                              CP-S1
                                                              CD-33
                                                              CD-30
                                                        Gf
      f             \

        1500          3000
        H          •
Approximate Scale in Feet
  LANDAU ASSOCIATES, INC.
                                             Geologic Cross Section Location Map
                                           4-49                                         Figure ER-4.1
                                                    From Final Phase 1 Engineering Report (Landau Associates, 1991)

-------
UI
!
                                KEY TO GEOLOGIC CROSS SECTIONS
                               -Sand
                               -Silt/Clay
            CD-40  CD-41
              i

              I
             JL      J-
                                        Fluvial sands, silts and gravels
                                        Upper Sand/Gravel Unit (Unit A), composed of gravelly, fine to coarse sand
                                        Lacustrine Unit (Unit B), composed of silt and clay with interbedded fine sand
                                        Lower Sand/Gravel Unit (Unit C), composed of gravelly, fine to coarse sand
                                        Weathered Latah Subunit (Unit Di), composed of gravelly (basalt) silt and
                                        clayey silt
                                        Latah Formation (Unit D), composed of silt, clayey silt and fine sand
                                        Basalt Unit (Unit E), composed of highly fractured to massive Basalt rock
                                        Granite Unit (Unit F), composed of Pre-Tertiary granitic rock, highly weathered
                                        with zones encountered during Phase I
Approximate location and number of monitoring well cluster, with screen intervals
shown for individual monitoring wells. Projected boring logs have dashed lines.
Nested wells are noted, and screen intervals shown.
                                        Ground water elevation line, dashed when representing a piezometric surface in
                                        a confined aquifer
                                        Contact between stratigraphic units; question marks indicate contact projection
                                        based on limited data
         LANDAU ASSOCIATES, INC.
                            Key to Geologic Cross Sections
                                                    4-50                                          Figure ER-4.2
                                                              From Final Phase 1 Engineering Report (Landau Associates, 1991)

-------
      A

     WEST



     1900



     1850 -


     1800


     1750


?    1700
 15
 I
 g   1650

 I
 JE
 m   1600 —
1550



1500



1450


1-


                                                             CCM1*
                                                                                               CD-26

                                                                                                                     CD-23
                                                                                                                           ^SpP"
                                                                                                                           RSS&HWii
>::b
                        J-t,/-*-^-%~~^<$> ^^'\J- -o: •• • •: -a •'  '. .vj.-.--_-:-vv: o-  '  o • •  a - V"
                        ^^^^Pji^^g^^s^
                                                                                                i
                                       ^^^^S^^i^v^W-^^
                                       2^P®^^P^lf^|^
                                                        -Q-.    £J^ ° "  •••" -^
    Notes:  a) Subsurface profiles shown have been generalized from data obtained during Phase I and other
           Site investigations. Variations between this profile and the acruaJ soil conditions may be
           encountered. The boring logs and the discussion in the text of Shis Report must be referenced for a
           proper understanding o1 the nature of suosudaca materials.

         b) All elevations in leet above mean sea level (MSL) based on 1929. National Geodetic Vertical Datum.
    ' Well drilled by air rotary; detailed geology noi identified in Lacustrine Aquifard Unit.
                                                                                                               0
                                                                                                                                                  600
                                                                                                                                                           A'

                                                                                                                                                           EAST


                                                                                                                                                             1900
                                                                                                                                                             1850
                                                                                                                                                            1800
                                                                                                                                                             1750
                                                                                                                                                            1700
                                                                                                                                                            1650
                                                                                                                                                            1600
                                                                                                                                        1550
                                                                                                                                        1500
                                                                                                                                                                   ns
                                                                                                                                      ~
                                                                                                                                        1450
                                                                                                                                                             1400
1200
                                                                                                                  Approximate Scale in Feet
                                                                                                                Vertical Scale Exaggeration: Sx
                                                                                       LANDAU ASSOCIATES, INC.
                                                                                                                        Geologic Cross Section A-A'
                       4-51
                                                                                                         From Final Phase 1 Engineering Report (Landau Associates, 1991) Figure GR-4.3

-------
         B
       WEST
    1900
    1850
    1800  ~
    1750  —
    1700
§   1650
i
«
"J    +++
^^:;

                                                                                                                                                                         1900
                                                                                                                                                                                                                      1850
                                                                                                                                                                                                                      1800
                                                                                                                                                                                                                      1750
                                                                                                                                                                                                                      1700    ?
                                                                                                                                                                                                                             g
                                                                                                                                                                                                                             5
                                                                                                                                                                                                                             u.,

                                                                                                                                                                                                                      1650   I
                                                                                                                                                                                                                            a
                                                                                                                                                                                                                            LU
                                                                                                                                                                                                                      1600
                                                                                                                                                                                                                      1550
                                                                                                                                                                                                                      1500
                                                                                                                                                                                                                      1450
                                                                                                                                                                                                                      1400
         Notes:  a) Subsurface profiles shown have been generalized from data obtained during Phase i and other
                  Site investigations. Variations between this protile and the actual soil conditions may be
                  encountered. The boring logs and (he discussion m the text of this Report must be referenced lor a
                  proper understanding of the nature of subsurface materials.

                b) Ail elevations in feet above mean sea level (MSL) based on 1929, National Geodetic Vertical Datum.
         • Pilot Well included in cross section to show screen interval, geologic information is based on
          adjacent monitoring well boring data.
                                                                                                                                                                                          600
                                                                                                                                                           1200
                                                                                                                                                                                Approximate Scale in Feet
                                                                                                                                                                             Vertical Scale Exaggeration:  6x
                                                                                                                        LANDAU  ASSOCIATES,  INC.
                                                                                                                                                                                             Geologic Cross Section B-B'
                                      4-52
                                                                                                                                                                        From Final Phase 1 Engineering Report (Landau Associates, 1991) Figure ER-4.4

-------
                  c
                 WEST

              1900  r—
              1850
              1800 —
              1750 —

                                                    Coiluvium
         S    1700  -
          §   1850

          1
          01
              1600  -
1550
            LJttie
          Spokane
            River
                   !
              1500 -
              1450
              1400




                                                                                                                              •  :
                                                                                                                            J:.Ja5!?>yTf?'"> S ^ —S t * t / S
                                                                          -•
    C'

   EAST


— I 1900



    1850


    1800


    1750


    1700
I
    1650
                                                                                                                                                                                                                                    1600
                                                                                                                                                                                                                                                 1550
                                                                                                                                                                                                                                   1500
                                                                                                                                                                                                                                    1450
                                                                                                                                                                                                                                    1400
                                                                                                                                                                                                                                           LL_
                                                                                                                                                                                                                                           c


                                                                                                                                                                                                                                           1
                   Notes:  a) Subsurface profiles shown have been generalized from data obtained during Phase I and other
                             Site investigations. Variations between this profile anc) the actual soil conditions may be
                             encountered. The boring logs and the discussion in the text of this Report musi be referenced for a
                             proper understanding of the nature of subsurface materials.

                          t)} AH elevations In feet above mean sea level (USL) based on 1929, National Geodetfc Vertical Datum.
                    * Well drilled by air rotary; detailed geology not identified in Lacustrine Aqurtard Unit.
                   " Ground waier in CD-4(U) appears to be perched. However, an underlying aquitard is not identified on ihe bonng iog.
                                                                                                                                                                                                          600
                                                                                                                                                                                                            1200
                                                                                                                                                                                  Approximate Scale in Feet
                                                                                                                                                                               Vertical Scale Exaggeration:  6x
                                                                                                                                            LANDAU  ASSOCIATES,  INC.
                                                                                                                                                                                                     Geologic Cross Section C-C'
                                                      4-53
                                                                                                                                                                                 From Final Phase 1 Engineering Report (Landau Associates, 1991)FiQUf6 ER-4.5

-------
         D
       WEST
    1900
    1850
    1800
    1750
^   1700
 c  1650
    1600
    1550
    1500
    1450
    1400
CD-3*
(nested)


                                                                                  CD-24
                                         CD-43
                                                                                     I

                                                                              CD-21  | CP-E1           CS-9
                    CoNuvium
  o::y.:'^.:-^i^^av'P:':^v>'1$*&;$jgjji%''"^T^lr'-r^  :-^-^S-^-N0:g^

;||Sl||l|§i|il|^lft^|p-^:h ^
                             -'L >4. -.' • .^V . ^^' ' J ' -
                                                                                            +  ++
                                                                                            + +•» +
                                                                                                    +++ +

     Notes:  a) Subsurface profiles shown have been generalized from data obtained during Phase I and other
             Site investigations, Vanations between mis profile and ihe actual soli conditions may be
             encountered. Tha boring logs and the discussion in the text of this Report must be referenced for a
             proper understanding ol the nature of subsurface materials.

           b) All elevations in feet afeove mean sea !eve§ (MSL) based on 1929, National Geodetic Vertical Datum.
     ' Well dotted by air rotary; detailed geology in Lacustrine Aqultard Unit based on CD-43 boring data.
                                                                                800
                                                                                            D'
                                                                                          EAST
                                                                                                                                             1900
                                                                                                                                             1850
                                                                                              1800
                                                                                              1750
                                                                                              1700  &
                                                                                              1650
                                                                                              1600
                                                                                              1550
                                                                                              1500
                                                                                              1450
                                                                                              1400
                                                                                                                                                   0)
                                                                                                                                                   ID
                                                                                                                                                   u_
                                                                                                                                                   2
                                                                                                               1200
                                                                      Approximate ScgJs in Feel
                                                                    Vertical Scale Exaggeration: 6x
              •
                                                                                   LANDAU ASSOCIATES,  INC.
                                                                                                   Geologic Cross Section D-D'
         4-54
                                                                                From Final Phase 1 Engineering Report (Landau Associates, 1991) Figure ER-4.6

-------
    1900  r-
    1850
    1800  -
    1750  -
S   170°
c
Q
1
LLJ
    1600  -
    1550 -
    1500  -
    1450  -
   1400

        E


      NORTH

                                                                                            CD-5*

                                                                                         {single well, with

                                                                                         multiple screen

                                                                                           intervals)
        Notes:  a) Subsurface profiles sfiown have been generalized from daia obtained during Phase I and other

                Site investigations. Vanations between this profile and (tie actual soil conditions may be

                encountered. The boring logs and the discussion in the text of this Report must be referenced lor a

                proper understanding of the nature of subsurface materials.


              b) All elevations In feel above mean sea level (MSI) based on 1929. National Geodetic Vertical Datum.
        * Weil drilled by air rotary; detailed geology not identified in Lacustrine Aquhard Unit.
                                                                                                               SOUTH





                                                                                                                 -]  1900
)• *^ o'«'LJ'**• •#• P-'o *: c-/.y *UjXT^ 7f**"''•**-&&•/ivvw ^-^•'" 'P T?iV->i











   •-.'''"       .'• • '-.',.""• -..;"•'. ''; ' ' -.•T^T^^-.-.Ti. j. LS. O^^AU. f . —^, -\^J'

                                    ^^^^^
                                                                   ••b.-.--..-
                                                    ^^'i^^::S:^'0-^:^^-y:^
                                                       ^^
                                                    ^^
   Jjjjitijik ^ pS^S^.^^^^§^i^
   V^y^o:^Qi;v^^
   o;^.:;?.^^vfe;d:; ^^^^^•ft::^:-^:> i"-^'.? ::-t?;:^v: -*^p£:
                                                                                                '•^^^•fs'tf^--^'-^
                                                                                                 .•0-...-;... .LJ.fl--.-,.-. .- .-:«v-
                                                                                                 • '.av. Pi1.'"•.:I--U.'.'-n:-l-'tf;
 0" TV • ./I t - ".VO ' ' "  ' / .  ' ' O' •"" " ^J ' ' H ' ' ' ' (I' '-"•''« '• ' ' "• '• '" Vn ' ' • • ' ''O" ' f\'- m -**' "."• • j. L • - /- -A" ;r^
./;g:.:.?;Q-:.°-.;t..;o: ^^y-vor-^'-'^:-'-"^^ ?^>'Q:-^'''-^ "^••••p;°^



'-:^:' 'vS-^ ':$S -^o^cV^?'0^^1 '^'• v'fS";- fe*^§:^ -^:'- si$~
                                                                                  m^m^S^m
                                                              Wiim^ii^mii^^m^^
                                                              li^^pS I i^§^|^^fcSfe
                                                              fe  rt-;.:.^^;^^3-^;.::-^^^::-^;:-^^;.
                                                                                                                            g

                                                                                                                            LU
                                                                                                                                             -n
                                                                                                                                             CD
                                                                                                      600          1200
                                                                                             Approximate Scale in Feet

                                                                                           Vertical Scale Exaggeration: 6x

                                                                               LANDAU  ASSOCIATES,  INC.
                                                                                                                        Geologic Cross Section E-E'
           4-55
                                                                                                      From Final Phase 1 Engineering Report (Landau Associates, 1991) Figure ER-4.7

-------
                            F
                          NORTH
                       1900
                       1850
                       1800
                  _   1750
                  g
                   g
                   CD
                   o
                       1700  :-
                   CD
                   Qj   1650
                       1600
                       1550
                       1500  —
                       1450



                                                          CD-1 *
                                                                                  CD-21
                                                                    CD-4*
                                                                    (nested)
                                                                                         CS-13
                                     C8-100
CD-26
CD-6*
(nested)

                                         &&&?m$$&



••K:wti-'y-'':.':':'&jf^:'
                                                          mr^&mz?;.


LU
1
Notes:  a> Subsurfacs profiles shown hava been generated from da;a obiainsd during Phase i and other
         Sits investigations. Variations between this profile and the actual soil conaitions may be
         encountered. The bonng logs and the discussion in the text of this Report must be referenced tor a
         proper understanding of the nature of subsurface maienals,

      b) All elevations In feet above mean sea level (MSI) based on 1929. National Geodetic Vertical Datum.
                              Well drilled by air rotary: deiailed geology not identified in Lacustrine Aquitard Unit.
                             1 Ground water in CD-4(U) appears to be perched.  However, an underlying aquitarct is not identified on ihe boring log.
                                                                                                                                                                   0
                                                                                    600
                                            1200
                                                                           Approximate Scale in Feet
                                                                         Vertical Scale Exaggeration: 6x

                                                                                                                                                                                   F'

                                                                                                                                                                                 SOUTH
1
                                                                                                                      1900
                                                                                                                                                                                     1850
                                                                                                                                                                                     1800
                                                                                                                                                                                     1750   _
                                                                                                                                                                                            S.
                                                                                                                                                                                             =•
                                                                                                                                                                                             
-------
                                                                       •  APPROXIMATE LOCATIONS
                                                                          OF EXTRACTION WELLS
    Supplemental Sampling Location:

    •    PCE Detected

    •    PCE Not Detected

Figure 25.  PCE concentrations detected in Lower Aquifer during Supplemental Sampling
                                                         From Fourth Five-Year Review (September 2009)

-------
                                                             *           A1  1
                                                               to OolMAv_C-j
                                       CD-61   CO-*4C2
                                              Q0.58
                                                    34.3 11.9
                                        CD-45C2         O   54.5
                                            O    7.29
                                                                          i
                                                                     LANDiTILL
                                                                              .87
                                                      13A'
                                                 Trwtmont
                                                 Focillty
                                                                                 ,.  APPROXIMATE LOCATIONS
                                                                                    OF MONITORING WELLS
                                                                                    APPROXIMATE LOCATIONS
                                                                                    OF DOMESTIC WELLS
                                                                                 .  APPROXIMATE LOCATIONS
                                                                                    OF EXTRACTION WELLS
                                                                                    APPROXIMATE LOCATION
                                                                                    Of PIPEUNE
                                                                    . C-5.  C-3
                                                                   D-1   C-4
    Supplemental Sampling Location:

    0    1,1-DCE Detected

    •    1,1-DCE Not Detected
Figure 26.  1,1-DCE concentrations detected in Lower Aquifer during Supplemental Sampling
                                                                 From Fourth Five-Year Review (September 2009)

-------
          Note: It was stated to the RSE team that the TCE concentrations for CD-7E1 and CD-4E1 indicated on this figure
          are incorrect and should be "swapped".
                                                                               ,   APPROXIMATE LOCATIONS
                                                                                  Of MONITORING WELLS
                                                                                  APPROXIMATE LOCATIONS
                                                                                  OF DOMESTIC WELLS
                                                                               .   APPROXIMATE LOCATIONS
                                                                                  OF EXTRACTION WELLS
                                                                                 APPROXIMATE LOCATION
                                                                                 OF PIPELINE
    Supplemental Sampling Location:

             TCE Detected

             TCE Not Detected
Figure 27.  TCE Concentrations detected in Lower Aquifer during Supplemental Sampling
                                                            From Fourth Five-Year Review (September 2009)

-------
                                        CD-61   CD-44C2
                                                                   Big Meadows Ra
                                                                        -
                                                                                           APPROXIMATE  LOCATIONS
                                                                                           OF MONITORING WELLS
                                                                                           APPROXIMATE LOCATIONS
                                                                                           OF DOMESTIC  WELLS
                                                                                           APPROXIMATE LOCATIONS
                                                                                           OF EXTRACTION WELLS
                                                                                           APPROXIMATE LOCATION
                                                                                           OF PIPELINE
 9   Upper Aquifer

 O   Lower Aquifer
                                                •A
(_)   Detection in 2008 (below Performance Standard)

   Figure 28.  Domestic well monitoring locations (2004 - 2008)
                                                                        From Fourth Five-Year Review (September 2009)

-------
           Note:"system shutdown" on this figure refers to shutdown of the southern extraction well system.
                            South Interception System: Trichloroethene
                     (x xk M at XOKK * it MM x )< it it gg
               1/1/1996    1/1/1998    1/1/2000     1/1/2002    1/1/2004    1/1/2006     1/1/2008
           -CP-S1
.CP-S4 -*— CP-S5 -*— CP-S6	System Shutdown	Performance Criteria (5 ug/L)
Figure 9.  Concentration of TCE in South Interception System Extraction Wells
                           South Interception System:  Tetrachloroethene
                                                         m mm mmmmlmmm mmmm mmm m mm
                                                                                        	J
1/1/1994     1/1/1996    1/1/1998    1/1/2000     1/1/2002
                                                             1/1/2004    1/1/2006
                                                                1/1/2008
           CP-S1
CP-S4
                            CP-S5
CP-S6
System Shutdown
Performance Criteria (0.7 ug/L)
Figure 10. Concentration of PCE in South System Extraction Wells
                                                             From Fourth Five-Year Review (September 2009)

-------
                          West Interception System:  1,1-Dichloroethene
              1/1/1996
   1/1/1998
    1/1/2000
    1/1/2002
1/1/2004
 1/1/2006
 1/1/2008
               -CP-W1
   -CP-W2
  -CP-W3
 -CP-W1 Shutdown	Performance Criteria (7 ug/L)
Figure 11.  Concentration of 1,1-DCE in West System Extraction Wells
                            West Interception System: Trichloroethene
              1/1/1996
   1/1/1998
    1/1/2000
    1/1/2002
1/1/2004
1/1/2006
1/1/2008
           • CP-W1
• CP-W2
• CP-W3
CP-W1 Shutdown
    •Performance Criteria (5 ug/L)
Figure 12.  Concentrations of TCE in West System Extraction Wells
                                                            From Fourth Five-Year Review (September 2009)

-------
                            East Extraction System:  1,1-Dichloroethene
  350
  300
  250
    0
   1/1/1994
1/1/1996
1/1/1998
1/1/2000
1/1/2002
1/1/2004
1/1/2006
1/1/2008
                          -CP-E1
                    -CP-E2 —A—CP-E3	Performance Criteria (7 ug/L)
                                                 From Fourth Five-Year Review (September 2009)
Figure 13.  Concentrations of 1,1 -DCE in East System Extraction Wells
                            East Extraction System:  Tetrachloroethene
   1/1/1994     1/1/1996
           1/1/1998
           1/1/2000    1/1/2002    1/1/2004    1/1/2006
                                              1/1/2008
                      •CP-E1
                  • CP-E2
                 • CP-E3 •
                •Performance Criteria (0.7 ug/L)
Figure 14.  Concentrations of PCE in East System Extraction Wells
                                                             From Fourth Five-Year Review (September 2009)

-------
   400



   350



   300



   250
   200
                             East Extraction System:  Trichloroethene
   150



   100
    1/1/1994    1/1/1996    1/1/1998    1/1/2000    1/1/2002    1/1/2004    1/1/2006    1/1/2008
                     •CP-E1 -•— CP-E2 -*— CP-E3	Performance Criteria (5 ug/L)
Figure 15.  Concentrations of TCE in East System Extraction Wells
                                                           From Fourth Five-Year Review (September 2009)

-------
Figure 6-1 Colbert Landfill 1,4-Dioxane Sampling Locations April 2008
                                     pling Well Locations
Colbert Landfill 1,4-
                            6-3
                      From Quarterly Progress Report, Second Quarter 2009 (Spokane County)

-------
     Figure 6-2 Colbert Landfill 1,4-Dioxane Concentrations vs. Time
                        1,4-Dioxane Results
/  /  /-/  /  *
<*   ^
//
#   ^
 25
 20
 10
/   /   /
                        1,4-Dioxane Results
                              z
                  \
                             6-5
                          From Quarterly Progress Report, Second Quarter 2009 (Spokane County)

-------
Table 6-2 1,4-Dioxane Sampling Field and Analysis Results



              (April 2008 through April 2009)
StationlD
1Q73D-1
1073D-1
1073D-1
1073D-1
1073D-1
1073D-2
1073D-2
1073D-2
1073D-2
1073D-2
1473M-1
1473M-1
1473M-1
1473M-1
1473M-1
1573A-1
1573A-1
1573A-1
1S73A-1
CD-40C1
CD-40C1
CD-40C1
CD-40C1
CD-40C1
CD-40C1
CD-40C1
CD-40C1
CD-40C1
CP-S1
CP-S1
CP-S1
CP-S1
CP-S1

SampleDate
4/8/2008
7/8/2008
10/7/2008
2/3/2009
4/14/2009
4/8/2008
7/8/2008
7/8/2008
10/7/2008
4/15/2009
4/8/2008
7/8/2008
10/7/2008
2/3/2009
4/14/2009
7/8/2008
10/7/2008
2/3/2009
4/14/2009
4/8/2008
4/8/2008
7/8/2008
10/7/2008
10/7/2008
2/3/2009
2/3/2009
4/15/2009
4/15/2009
4/9/2008
7/8/2008
10/7/2008
2/3/2009
4/16/2009

Analyte
1,4-Oioxane
1 ,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1 ,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1 ,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1,4-Dioxane
1 ,4-Dloxane
1 ,4-Dioxane
1 ,4-Dloxane
1,4-Dioxane
1.4-DIoxane

Result
2.2
2
2.3
2.1
2
2.9
2.3
2.1
2.9
2
2
2
2
2
2
2
2.4
2
2
12
13
11
12
12
10
9.9
8.5
8.3
9.4
15
20
18
11

Qualifier

U


U




U
u
u
U
u
U
y

U
U















Units
IKJ/L
ug/L
uq/L
ug/L
ug/L
ug/L
uq/L
uq/L
uq/L
ug/L
ug/L
ug/L
ug/L
uq/L
ug/L
uq/L
uq/L
ug/L
ug/L
uq/L
uq/L
ug/L
ug/L
uq/L
uq/L
uq/L
ug/L
uq/L
uq/L
ugfl^
ug/L
ug/L
ug/L

Temperature
9.2
13
11.1
10.6
10.9
10.3
11.9

11.9
10.2
10.3
11.9 .
11.2
10
10.4
12.9
11.3
8.1
10.7
9.6

10.2
9.9

9.9


9.4
10.5
11.1
11.6
9.5
11
(degress Cl
PH
8.01
7.92
8.01
8.04
8.02
7.94
8.01

8.01
7.91
7.61
7.55
7.62
7.6
7.52
7.52
7.54
7.52
7.49
7.8

7.8
7.65

7.72


7.69
7.27
7.22
7.18
7.21
7.29

Conductivity
412
396
389
372
393
411
397

394
404
535
504
451
497
502
521
515
525
500
531

503
510

519


518
665
486

722
735
(umhos/cm)
Turbidity

0.08
0.19
0.23
0.36

0.09

0.73
0.49

0.2
0.17
0.18
0.15
0.19
0.12
1.1
0.9
0.34

0.16
0.12

0.3


0.29
0.25
0.15
0.32
0.69

(NTU)
Depth to Water
1.79
2.76
2.89
2.99
4.76

2.11

3.11
1.25




90
93.03
92.87
93.31
93.26
8.75

9.81
10.01

10.01


8.55
84.56
90.78
87.08
79.96
89.7
(FT)
                            6-4
                              From Quarterly Progress Report, Second Quarter 2009 (Spokane County)

-------
                       ATTACHMENT B





REFERENCE VALUES FOR SUSTAINABILITY FOOTPRINT CALCULATIONS

-------
Colbert Landfill Superfund Site
General Scope
                                                                                                            Green Remediation - Inventory of Energy, Material, Waste, and Other Remedy Aspects
                                                                                                                                                                  Pump and Treat System
                                                                                                                                Input for Pump and Treat System
Typical Scope Items
Useful Information
- Air stripper operation and off-gas emissions
- Landfill gas extraction, exhaust treatment, and emissions
- Laboratory analysis for process sampling and groundwater monitoring
- Commute for labor not included because staff is assumed to be on-site for other related activities
Labor, Mobilizations, Mileage, and Fuel
Participant











Crew Size











Number of
Days











Hours
Worked Per
Day











Total Hours
Worked











Trips to
Site











Roundtrip
Miles to
Site











Mode of Transport.











Fuel Type











Total Miles
Traveled











Miles Per
Gallon











Total Fuel
Used











Activity or Notes











Equipment Use, Mobilization, and Fuel Usage
Equipment Type
Other









HP
2









Load Factor
0.5









Equip. Fuel
Type
Gasoline









Gallons Fuel
Used per
Hour
0.054









Total Hours
Operated
56









Gallons
Fuel Used
On-Site
3.024









Trips to Site










Distance to
Site










Total Miles
Traveled










Transport Fuel
Type










Miles per
Gallon










Gallons Fuel
Used for
Transport.










Activity or Notes
Generator use for well sampling (2hours per well)









Electricity Usage
Equipment Type












HP









N/A
N/A
N/A
% Full Load












Efficiency












Totals
Electrical
Rating (kW)












0
Hours Used













Energy
Used (kWh)












703000
Notes












Total electricity usage from bills
                                        Natural Gas Usage
Equipment Type












Heat Load
(btu/hr)












Power Rating
(btu/hr)












Effiency












Totals
Total Hours
Used













Btus
Required













Total Therms
Used













Activity or Notes














-------
Colbert Landfill Superfund Site
Materials Usage
                                                                                                                              Input for Pump and Treat System
Material Type
GAC: regenerated
Sequestering agent
















Unit
Ibs
Ibs
















Quantity
4400
2000
















Trips
1
1
















Total Miles
Transporte
d
1000
2400
















Mode of Transport.
TruckB (5-15 tons)
Truck A (< 5 tons)
















Fuel Type
Diesel
Diesel
















Fuel Use Rate
7.2
8.5
















Total Fuel Use
138.9
282.4
















Notes
Assumed roundtrip distance
Round trip from Carson, CA
















                                                                                         gptm = gallons per ton-mile
Waste Generation
                                                                                 Green Remediation - Inventory of Energy, Material, Waste, and Other Remedy Aspects
                                                                                                                                       Pump and Treat System

                                                                                    Laboratory Analysis
Parameter and Notes
Total analytical cost
Other
Other
Other
Other
Other
Other
Other
Other
Other



Unit Cost













Totals
Number
of
Samples













0
Total Cost
$22,000












22000
Waste Type
Non-hazardous
Hazardous
Recyclable oil
Hauled to POTW
For incineration
Unit
tons
tons
tons
tons
tons
Quantity





Trips





Total Miles
Transport.





Mode of Transport.





Fuel Type





Fuel Use Rate





Total Fuel Use





Notes





                                                                                         gptm = gallons per ton-mile
On-Site Water Usage
Resource Type
Public water (1000 x gal.)
Extracted GW #1 (1000 x gals)
Extracted GW #2 (1000 x gals)
Surface water (1000 x gals)
Reclaimed water (1000 x gals)
Stormwater (1000 x gals)
Quantity

341640000




Use of Resource

P&T water extracted




Fate of On-Site Water Usage
Discharge Location
Discharge to surface water
Reinjected to aquifer
Discharge to POTW
Discharge to atmosphere
Public Use
Irrigation
Industrial process water
Other beneficial use
Quantity
341640000







Activity or Notes
treated P&T water







Other
Item
On-site HAP emissions
On-site GHG emissions
On-site GHG reductions
On-site NOx reductions
On-site SOx reductions
On-site PM reductions
Quantity
200
822206.071




Activity or Notes
emissions from air stripper and LFG off-gas (all VOCs emitted assumed to be HAPs)
Methane emitted in extracted landfill gas
(CO2 not included in GHG emissios because waste would degrade to CO2 if not landfilled)




-------
                                         Landfill Gas Emissions




Compound Emitted
methane MW= 16









Ext. Rate
(cfm)
20






Total greenhouse gas emissions (GHGs)



Cone, by
Volume
9%









Mass
Emitted
(Ibs/yr)
39153
0
0
0
0
0
0

Global
Warming
Potential
(Ibs
C02e/lb)
21








Total
C02e*
Emitted
(Ibs)
822206
0
0
0
0
0
0
822206.1
Notes:
                28.3 L   Imole   \44Qmin   365 days          I pound
                            • x —:	x	x MW x
              ft3    24.1 L    day

where
Me = mass emitted (pounds per year)
Q = flow rate (cfm)
C = concentration by volume
MW = molecular weight (grams / mole)
divide ppmv by 106 to obtain  C
divide ppbvbylO9 to obtain  C
                                          year
454 grams

-------


Totals

ON-SITE

Energy
Diesel (on-site)
Gasoline (on-site use)
On-site electricity use

Other
On-site process emissions (HAPs)
On-site process emissions (GHGs)
ON-SITE TOTAL

ELECTRICITY GENERATION
Electricity production


TRANSPORTATION
Diesel (off-site use)
Gasoline (off-site use)
Electricity transmission
TRANSPORTATION TOTAL

OFF-SITE OTHER

Materials
Diesel Produced
GAC: regenerated
Gasoline Produced
Sequestering agent

Off-Site Services
Laboratory Analysis
OFF-SITE OTHER TOTAL




gal
gal
MWh


Ibs
Ibs C02e



MWh



gal
gal
MWh





gal
Ibs
gal
S


S

Quantity
Used







0
3.024
703


200
822206.07



703



421.3
0
703





421.3
4400
3.024
6600


22000

Parameters Used, Extracted, Emitted, or Generated for P&T
Energy
Conv.
Factor







139
124
3400


0
0



7800



139
124
410





18.5
9.6
21
8.83


6.49

Used
Mbtu

8,471,922.




0
375.
2,390,200.


0
0
2,390,575.


5,483,400.



58,561.
0
288,230.
346,791.




7,794.
42,240.
64.
58,278.


142,780.
251,156.
CO2e
Conv.
Factor







22.5
19.6
0


0
1



150



22.5
19.6
18





2.7
2
4.4
1.36


1

Emitted
Ibs

990,775.




0
59.
0


0
822,206.
822,265.


105,450.



9,479.
0
12,654.
22,133.




1,138.
8,800.
13.
8,976.


22,000.
40,927.
NOx
Conv.
Factor







0.17
0.11
0


0
0



0.36



0.17
0.11
0.0432





0.0064
0.025
0.008
0.0065


0.0048

Emitted
Ibs

617.




0
0
0


0
0
0


253.



72.
0
30.
102.




3.
110.
0
43.


106.
262.
SOx
Conv.
Factor







0.0054
0.0045
0


0
0



1



0.0054
0.0045
0.12





0.013
0.015
0.019
0.0049


0.0036

Emitted
Ibs

971.




0
0
0


0
0
0


703.



2.
0
84.
86.




5.
66.
0
32.


79.
182.
PM
Conv.
Factor







0.0034
0.0005
0


0
0



0.088



0.0034
0.0005
0.0106





0.0003
0
0.0005
0.0005


0.0004

Emitted
Ibs

82.




0
0
0


0
0
0


62.



1.
0
7.
8.




0
0
0
3.


9.
12.
Air Toxics
Conv.
Factor







5E-06
4E-05
0


1
0



0.0393



5E-06
4E-05
0.0047





0.0001
0
0.0002
0.0002


0.0001

Emitted
Ibs

235.0446




0
0.0001
0


200.
0
200.0001


27.6279



0.0022
0
3.3153
3.3175




0.0506
0
0.0005
1.188


2.86
4.0991

-------
                                                                                                                  Power Sources and Global Emissions Factors for Electricity Provided by
                                                                                                    State of Washington Department of Commerce, 2010 Utility Fuel Mix Report for Inland Power & Light
Type

Biomass
Coal
Geothermal
Hydro
Natural Gas
Nuclear
Oil
Solar
Wind
Other
Total based on kWh at plant

Percentage
Used*

0%
5%
0%
82%
2%
8%
0%
0%
3%
0%
100%

Water (gal/kWh)
Full Load
55
0.63
0
0
0.57
0.55
0.55
0
0
0


Adjusted
0
0.0315
0
0
0.0114
0.044
0
0
0
0
0.1

CO2e (Ibs/kWh)
Full Load
0
2.4
0
0
1.4
0.024
1.9
0
0
0


Adjusted
0
0.12
0
0
0.028
0.00192
0
0
0
0
0.15

NOx (Ibs/kWh)
Full Load
0.0015
0.0067
0
0
0.0012
0.000056
0.0036
0
0
0


Adjusted
0
0.000335
0
0
0.000024
0.0000045
0.0000000
0
0
0
0.00036

SOx (Ibs/kWh)
Full Load
0.00060
0.015
0
0
0.012
0.000131
0.0041
0
0
0


Adjusted
0
0.00075
0
0
0.00024
0.00001048
0
0
0
0
0.001

PM (Ibs/kWh)
Full Load
0.000084
0.0017
0
0
0.000088
0.0000126
0.00029
0
0
0


Adjusted
0
0.000085
0
0
0.00000176
0.000001008
0
0
0
0
0.000088

HAPs (Ibs/kWh)
Full Load
0
0.0007
0
0
0.000193
0.0000053
0.0000902
0
0
0


Adjusted
0
0.000035
0
0
0.00000386
0.000000424
0
0
0
0
0.0000393

Lead (Ibs/kWh)
Full Load
0
0.00000024
0
0
1.31E-08
5.2E-09
0.00000129
0
0
0


Adjusted
0
0.000000012
0
0
2.62E-10
4.16E-10
0
0
0
0
0.00000001

Mercury (Ibs/kWh)
Full Load
0
0.000000042
0
0
2.9E-09
4.6E-10
1.01E-08
0
0
0


Adjusted
0
2.1E-09
0
0
5.8E-11
3.68E-11
0
0
0
0
0.000000002

Dioxins (Ibs/kWh)
Full Load
0
3.8E-13
0
0
0
2.9E-15
1.04E-12
0
0
0


Adjusted
0
1.197E-14
0
0
0
1.276E-16
0
0
0
0
1E-14

Notes:
- Water consumption for thermoelectric power plants U.S. Average - 0.47 gallons per kWh*
- Water consumption for hydroelectric power assumed to be 0 gallons per kWh (i.e., considers evaporation from reservoir as non-additive)
- Water consumption for coal resource extraction and fuel processing - 0.16 gallons per kWh**
- Water consumption for uranium resource extraction and fuel processing - 0.082 gallons per kWh**
- Water consumption for natural gas resource extraction and fuel processing - 0.10 gallons per kWh**
- Water consumption for biomass based on 55 gallons per kWh***
- CO2e, Nox, SOx, and PM emissions from NREL LCI for each fuel type ****
* Consumptive Water Use for U.S. Power Production, December 2003 • NREL/TP-550-33905
** Gleick PH. Water and energy. Annu. Rev. Energy Environ. Vol 19, 1994. p 267-99.
*** The Water Footprint of Energy Consumption : an Assessment of Water Requirements of Primary Energy Carriers, Winnie Gerbens-Leenes, Arjen Hoekstra, Theo an der Meer, ISESCO Science and
Technology Vision, Volume 4 - Number 5, May 2008
**** "NREL LCI" refers to the U.S. Dept.  of Energy, National Renewable Energy Laboratory (NREL), Life-Cycle Inventory Database (www.nrel.gov/lci) maintained by the Alliance for Sustainable Energy,
LLC.

-------
      Electricity and Energy Used for the Production, Transmission, and On-Site Use of Electricity

For the purpose of this study, the sum of the "energy used" for "electricity production", "electricity
transmission", and "on-site electricity use" equals the total amount of energy used to generate the 1
MWh used by the consumer. According to the U.S. Dept. of Energy
(GridWorks: Overview of the Electric Grid http://sites.energetics.com/gridworks/grid.html)
approximately power plants have a thermal efficiency of approximately 33% and the transmission of
electricity results in a loss of approximately 10% of the electricity produced.  In addition, the National
Renewable Energy Laboratory (Consumptive Water Use for U.S. Power Production December 2003 •
NREL/TP-550-33905) states that thermoelectric plants use approximately 5% of the gross electricity
produced for on-site demand (i.e., parasitic loads).

This study assumes that the 33% thermal efficiency includes the 5% parasitic load.

For use of 1 MWh of electricity on-site, the following calculations illustrate the electricity and energy
used.
G=P+T+U
G= 5%G+10%G+ 1
G(l- 15%)=  1
G = 1.18

where
G= electricity generated (MWh)
P= parasitic load (MWh):5% of G
T= transmission loss(MWh)'.\0% of G
U = energy used onsite(MWh)

P= 5% x 1.18= 0.06 MWh
T= 10% x 1.18= 0.12 MWh
EU + ET = 77 x E,
            3,413 btu
Ev = IMWhy,        = 3,
              3,413 btu
ET= 0.12 MWh x         = 4Wbtu
E>=
     (3,413+410)
        33%
Er = 11,584- 3,413- 410= l,16\btu

•where
Ej = energy input (btu)
Ep = energy lost electricity production
    (thermal loss and parasitic load) (btu)
ET = energy lost electricity transmission (btu)
Eu = energy used onsite in the form of
     electricity (btu)
n = thermal efficiency'(33%)

-------
                                                                                                              Default Environmental Footprint Conversion Factor References
Material/Fuel/Service
Gasoline (on-site use)
Green Indicator
Energy Used
Electricity Used
All Water Used
Potable Water Used
Groundwater Extracted
CO2e Emitted
NOx Emitted
SOx Emitted
PM Emitted
Solid Waste Generated
Haz. Waste Generated
Air Toxics Emitted
Mercury Released
Lead Released
Dioxins Released
Value
124




19.6
0.11
0.0045
0.00054


0.000039
0
0
0
Units
Mbtu/gal
MWh/gal
galxlOOO/gal
galxlOOO/gal
galxlOOO/gal
Ibs/gal
Ibs/gal
Ibs/gal
Ibs/gal
tons/gal
tons/gal
Ibs/gal
Ibs/gal
Ibs/gal
Ibs/gal
Assumptions
The reference provides the higher heating value of gasoline as 5.218 MMBTU per barrel and defines a barrel as 42 gallons. This converts to
approximately 124 Mbtu/gallon.
not applicable — no electricity used when gasoline is combusted on-site or in transportation
not applicable — no water used when gasoline is combusted on-site or in transportation
not applicable — no water used when gasoline is combusted on-site or in transportation
not applicable — no water used when gasoline is combusted on-site or in transportation
The reference provides CO2e emitted as 8.81 kg of CO2 per gallon. This converts to 19.4 pounds per gallon. Additionally, N2O and CH4 emissions are
provided as g/gal. Values are converted to Ibs/gal using a global warming potential (GWP) of 1 for carbon dioxide, 21 for methane, and 310 for nitrous
oxide.
NREL LCI reported the amount of gasoline in liters required to transport one ton-kilometer (tkm) and provided outputs to nature in kg. The output
(nitrogen oxides) generated from transporting 1 tkm was divided by the amount of gasoline required to transport 1 tkm, and the units of the result were
converted from kg/L to Ibs/gallon.
NREL LCI reported the amount of gasoline in liters required to transport one ton-kilometer (tkm) and provided outputs to nature in kg. The output (sulfur
oxides) generated from transporting 1 tkm was divided by the amount of gasoline required to transport 1 tkm, and the units of the result were converted
from kg/L to Ibs/gallon.
NREL LCI reported the amount of gasoline in liters required to transport one ton-kilometer (tkm) and provided outputs to nature in kg. The output
(Particulates, > 2.5 um, and < lOum) generated from transporting 1 tkm was divided by the amount of gasoline required to transport 1 tkm, and the units
of the result were converted from kg/L to Ibs/gallon.
not applicable — no waste generated when gasoline is combusted on-site or in transportation (solid waste and waste oil from maintenance would be
tracked separately)
not applicable — no waste generated when gasoline is combusted on-site or in transportation (solid waste and waste oil from maintenance would be
tracked separately)
Not available in NREL LCI transport files. Summed hazardous air pollutants emitted from combusting gasoline in industrial equipment. NREL LCI provides
results in kg per L combusted. Converted this to pounds per gallon by multiplying by 3.785 and multiplying by .2.2
EUROPA ELCD - Reference does not indicate a release of mercury.
EUROPA ELCD - Reference does not indicate a release of lead
EUROPA ELCD - Reference does not indicate a release of dioxins.
Information Source
Climate Leader GHG Inventory EPA-430--K-08-004, May 2008




Climate Leader GHG Inventory EPA-430--K-08-004, May 2008
NREL LCI File:
SS_Transport, single unit truck, gasoline powered.xls
NREL LCI File:
SS_Transport, single unit truck, gasoline powered.xls
NREL LCI File:
SS_Transport, single unit truck, gasoline powered.xls


NREL LCI File:
SS_gasoline combusted in industrial equipment.xls
EUROPA file location:
Lorry transport; Euro 0, 1, 2, 3, 4 mix; 22 t total weight, 17,3 t max payload (excluding fuel supply):
http://lca.jrc.ec.europa.eu/lcainfohub/datasets/elcd/processes/b444f4d2-3393-lldd-bdll-
0800200c9a66_02.00.000.xml
"NREL LCI" refers to the U.S. Dept. of Energy, National Renewable Energy Laboratory (NREL), Life-Cycle Inventory Database (www.nrel.gov/lci) maintained by the Alliance for Sustainable Energy, LLC.
Environmental Footprint Analysis - Romic Facility, East Palo Alto, CA

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                                                                                                                  Default Environmental Footprint Conversion Factor References
Material/Fuel/Service
Diesel (off-site use)
Green Indicator
Energy Used
Electricity Used
All Water Used
Potable Water Used
Groundwater Extracted
CO2e Emitted
NOx Emitted
SOx Emitted
PM Emitted
Solid Waste Generated
Haz. Waste Generated
Air Toxics Emitted
Mercury Released
Lead Released
Dioxins Released
Value
139




22.5
0.17
0.0054
0.0034


0.0000052
0
0
0
Units
Mbtu/gal
MWh/gal
galxlOOO/gal
galxlOOO/gal
galxlOOO/gal
Ibs/gal
Ibs/gal
Ibs/gal
Ibs/gal
tons/gal
tons/gal
Ibs/gal
Ibs/gal
Ibs/gal
Ibs/gal
Assumptions
The reference provides the higher heating value of diesel as 5.825 MMBTU per barrel and defines a barrel as 42 gallons. This converts to approximately
139 Mbtu/gallon.




The reference provides CO2e emitted as 10.15 kg of CO2 per gallon. This converts to 22.3 pounds per gallon. Additionally, N2O and CH4 emissions are
provided as g/gal. Values are converted to Ibs/gal using a global warming potential (GWP) of 1 for carbon dioxide, 21 for methane, and 310 for nitrous
oxide.
NREL LCI reported the amount of diesel in liters required to transport one ton-kilometer (tkm) and provided outputs to nature in kg. The output (nitrogen
oxides) generated from transporting 1 tkm was divided by the amount of diesel required to transport 1 tkm, and the units of the result were converted
from kg/Lto Ibs/gallon.
NREL LCI reported the amount of diesel in liters required to transport one ton-kilometer (tkm) and provided outputs to nature in kg. The output (sulfur
oxides) generated from transporting 1 tkm was divided by the amount of diesel required to transport 1 tkm, and the units of the result were converted
from kg/Lto Ibs/gallon.
NREL LCI reported the amount of diesel in liters required to transport one ton-kilometer (tkm) and provided outputs to nature in kg. The output
(Particulates, > 2.5 um, and < lOum) generated from transporting 1 tkm was divided by the amount of diesel required to transport 1 tkm, and the units of
the result were converted from kg/L to Ibs/gallon.
not applicable — no waste generated when diesel is combusted on-site or in transportation (solid waste and waste oil from maintenance would be tracked
separately)
not applicable — no waste generated when diesel is combusted on-site or in transportation (solid waste and waste oil from maintenance would be tracked
separately)
Not available in NREL LCI transport files. Summed hazardous air pollutants emitted from combusting diesel in industrial equipment. NREL LCI provides
results in kg per L combusted. Converted this to pounds per gallon by multiplying by 3.785 and multiplying by .2.2
EUROPA ELCD - Reference does not indicate a release of mercury.
EUROPA ELCD - Reference does not indicate a release of lead
EUROPA ELCD - Reference does not indicate a release of dioxins.
Information Source
Climate Leader GHG Inventory EPA-430--K-08-004, May 2008

Climate Leader GHG Inventory EPA-430--K-08-004, May 2008
NREL LCI File:
SS_Transport, single unit truck, diesel powered.xls
NREL LCI File:
SS_Transport, single unit truck, diesel powered.xls
NREL LCI File:
SS_Transport, single unit truck, diesel powered.xls


NREL LCI File:
SS_diesel combusted in industrial equipment.xls
EUROPA file location:
Lorry transport; Euro 0, 1, 2, 3, 4 mix; 22 t total weight, 17,3 t max payload (excluding fuel supply):
http://lca.jrc.ec.europa.eu/lcainfohub/datasets/elcd/processes/b444f4d2-3393-lldd-bdll-
0800200c9a66_02.00.000.xml
EUROPA ECLD refers to the European Reference Life Cycle Database (ELCD core database), version II compiled under contract on behalf of the European Commission -DC 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}
Environmental Footprint Analysis - Romic Facility, East Palo Alto, CA

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                                                                                                Default Environmental Footprint Conversion Factor References
Material/Fuel/Service
Diesel Produced
Green Indicator
Energy Used
Electricity Used
All Water Used
Potable Water Used
Groundwater Extracted
CO2e Emitted
NOx Emitted
SOx Emitted
PM Emitted
Solid Waste Generated
Haz. Waste Generated
Air Toxics Emitted
Mercury Released
Lead Released
Dioxins Released
Value
18.5
0.00059
0.00077


2.7
0.0064
0.013
0.00034
0.00000036
0
0.00012
0.000000048
0.0000015
3E-14
Units
Mbtu/gal
MWh/gal
galxlOOO/gal
galxlOOO/gal
galxlOOO/gal
Ibs/gal
Ibs/gal
Ibs/gal
Ibs/gal
tons/gal
tons/gal
Ibs/gal
Ibs/gal
Ibs/gal
Ibs/gal
Assumptions
EUROPA ELCD - All forms of energy summed and converted to Mbtus per gallon of product.
Not provided by EUROPA ELCD. NREL LCI includes electricity usage for crude oil, in refinery with an allocation to diesel. Electricity from crude oil, in
refinery (allocated to diesel) and crude oil, at production are included.
EUROPA ELCD - Sum of "water", "surface water", "groundwater", and "river water". Negative values (indicating return of water to the hydrosphere) were
not included. Sea water was also not included. Result converted to thousands of gallons per gallon of product
Not applicable — no local potable water used during diesel production.
Not applicable — no local or on-site ground water extracted during diesel production.
EUROPA ELCD - Sum of total global warming potential for carbon dioxide, methane, and nitrous oxide released to atmosphere. A global warming
potential of 21 is used for methane and a global warming potential of 310 is used for nitrous oxide. Results converted to pounds of carbon dioxide
equivalents per gallon of product.
EUROPA ELCD - Sum of nitrogen oxides emitted to atmosphere. Results converted to pounds of NO x per gallon of product.
EUROPA ELCD - Sum of sulfur oxides emitted to atmosphere. Results converted to pounds of SO x per gallon of product.
EUROPA ELCD - Sum of particulate matter (PM 10 and smaller) emitted to atmosphere. Results converted to pounds of PM per gallon of product.
EUROPA ELCD - Sum of all listed wastes (demolition debris) except for radioactive wastes, slag, and mining wastes, which would likely not be disposed of
in a landfill.
EUROPA ELCD - "Chemical waste, toxic" converted into tons per pound of product. No hazardous waste is listed in EUROPA for diesel production,
suggesting that little or no hazardous waste is produced as a result of these activities.
EUROPA ELCD - Sum of all hazardous air pollutants and groups of contaminants as defined by EPA (HAPs) emitted to atmosphere. Reported as pounds per
gallon of product.
EUROPA ELCD - Sum of all mercury and mercury compounds released to air or water. Reported as pounds per gallon of product.
EUROPA ELCD - Sum of all lead and lead compounds released to air or water. Reported as pounds per gallon of product.
EUROPA ELCD - Sum of all dioxins released to air or water. Reported as pounds per gallon of product.
Information Source
Primary NREL LCI File:
-SS_crude oil, in refinery.xls
Secondary NREL LCI File:
-SS_crude oil, at production.xls
EUROPA file location: Diesel at refinery:
http://lca.jrc.ec.europa.eu/lcainfohub/datasets/html/processes/244524ed-7b85-4548-b345-
f58dc5cf9dac_02.00.000.html
Environmental Footprint Analysis - Romic Facility, East Palo Alto, CA

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                                                                                                Default Environmental Footprint Conversion Factor References
Material/Fuel/Service
GAC: regenerated
Green Indicator
Energy Used
Electricity Used
All Water Used
Potable Water Used
Groundwater Extracted
CO2e Emitted
NOx Emitted
SOx Emitted
PM Emitted
Solid Waste Generated
Haz. Waste Generated
Air Toxics Emitted
Mercury Released
Lead Released
Dioxins Released
Value
9.6
0.00044
0.0064


2
0.025
0.015
0
0
0
0
0
0
0
Units
Mbtu/lbs
MWh/lbs
galxlOOO/lbs
galxlOOO/lbs
galxlOOO/lbs
Ibs/lbs
Ibs/lbs
Ibs/lbs
Ibs/lbs
tons/I bs
tons/I bs
Ibs/lbs
Ibs/lbs
Ibs/lbs
Ibs/lbs
Assumptions
Calculated using information from the cited reference. See support file for calculations.
Calculated using information from the cited reference. See support file for calculations.
Calculated using information from the cited reference. See support file for calculations.
Not applicable — no local potable water used.
Not applicable — no local or on-site ground water extracted.
Calculated using information from the cited reference. See support file for calculations.
Not calculated
Information not available. To be added when additional information becomes available.
Information not available. To be added when additional information becomes available.
Information not available. To be added when additional information becomes available.
Information not available. To be added when additional information becomes available.
Information not available. To be added when additional information becomes available.
Information not available. To be added when additional information becomes available.
Information Source
Use of Adsorbents for the Removal of Pollutants from Wastewaters, by Gordon McKay,
published by CRC Press, 1995, ISBN 0849369207
Environmental Footprint Analysis - Romic Facility, East Palo Alto, CA

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                                                                                                Default Environmental Footprint Conversion Factor References
Material/Fuel/Service







Gasoline Produced







Green Indicator
Energy Used
Electricity Used
All Water Used
Potable Water Used
Groundwater Extracted
CO2e Emitted
NOx Emitted
SOx Emitted
PM Emitted
Solid Waste Generated
Haz. Waste Generated
Air Toxics Emitted
Mercury Released
Lead Released
Dioxins Released
Value
21
0.00059
0.00079


4.4
0.008
0.019
0.00052
0.00000042
0
0.00016
0.000000085
0.0000022
3.1E-14
Units
Mbtu/gal
MWh/gal
galxlOOO/gal
galxlOOO/gal
galxlOOO/gal
Ibs/gal
Ibs/gal
Ibs/gal
Ibs/gal
tons/gal
tons/gal
Ibs/gal
Ibs/gal
Ibs/gal
Ibs/gal
Assumptions
EUROPA ELCD - All forms of energy summed and converted to Mbtus per gallon of product.
Not provided by EUROPA ELCD. NREL LCI includes electricity usage for crude oil, in refinery with an allocation to diesel. Electricity from crude oil, in
refinery (allocated to diesel) and crude oil, at production are included.
EUROPA ELCD - Sum of "water", "surface water", "groundwater", and "river water". Negative values (indicating return of water to the hydrosphere) were
not included. Sea water was also not included. Result converted to thousands of gallons per gallon of product
Not applicable — no local potable water used during gasoline production.
Not applicable — no local or on-site ground water extracted during gasoline production.
EUROPA ELCD - Sum of total global warming potential for carbon dioxide, methane, and nitrous oxide released to atmosphere. A global warming
potential of 21 is used for methane and a global warming potential of 310 is used for nitrous oxide. Results converted to pounds of carbon dioxide
equivalents per gallon of product.
EUROPA ELCD - Sum of nitrogen oxides emitted to atmosphere. Results converted to pounds of NO x per gallon of product.
EUROPA ELCD - Sum of sulfur oxides emitted to atmosphere. Results converted to pounds of SO x per gallon of product.
EUROPA ELCD - Sum of particulate matter (PM 10 and smaller) emitted to atmosphere. Results converted to pounds of PM per gallon of product.
EUROPA ELCD - Sum of all listed wastes (demolition debris) except for radioactive wastes, slag, and mining wastes, which would likely not be disposed of
in a landfill.
EUROPA ELCD - "Chemical waste, toxic" converted into tons per pound of product. No hazardous waste is listed in EUROPA for diesel production,
suggesting that little or no hazardous waste is produced as a result of these activities.
EUROPA ELCD - Sum of all hazardous air pollutants and groups of contaminants as defined by EPA (HAPs) emitted to atmosphere. Reported as pounds per
gallon of product.
EUROPA ELCD - Sum of all mercury and mercury compounds released to air or water. Reported as pounds per gallon of product.
EUROPA ELCD - Sum of all lead and lead compounds released to air or water. Reported as pounds per gallon of product.
EUROPA ELCD - Sum of all dioxins released to air or water. Reported as pounds per gallon of product.
Information Source






Primary NREL LCI File:
-SS_crude oil, in refinery.xls
Secondary NREL LCI File:
-SS_crude oil, at production.xls
EUROPA file location: Gasoline at refinery:
http://lca.jrc.ec.europa.eu/lcainfohub/datasets/html/processes/5f62ed77-85dO-4c99-8d2c-
be56951d8fb3 02.00.000.html






Environmental Footprint Analysis - Romic Facility, East Palo Alto, CA

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                                                                                                                      Default Environmental Footprint Conversion Factor References
   Material/Fuel/Service
                              Green Indicator
                                                     Value
                                                                       Units
                                                                         Assumptions
                                                                                                                                                                                                                                                         Information Source
     Sequestering agent
                                Energy Used
                                                      8.83
                               Electricity Used
                                                    0.00048
                               All Water Used
                                                    0.0009
                             Potable Water Used
                           Groundwater Extracted
                               CO2e Emitted
                                                      1.36
                                NOx Emitted
                                                    0.0065
                                SOx Emitted
                                                    0.0049
                                PM Emitted
                                                    0.00052
                            Solid Waste Generated
                            Haz. Waste Generated
                              Air Toxics Emitted
                                                    0.00018
                              Mercury Released
                                                  0.000000011
                               Lead Released
                                                  0.00000012
                              Dioxins Released
                                                    1.1E-13
Mbtu/S
MWh/S
                                                                    galxlOOO/S
                                                                    galxlOOO/S
                                                                    galxlOOO/S
                                                                       Ibs/S
                                                                       Ibs/S
 Ibs/S
                                                                       Ibs/S
                                                                      tons/S
                                                                      tons/S
                                                                       Ibs/S
 Ibs/S
                                                                       Ibs/S
                                                                       Ibs/S
    Based on the cited reference, approximatley 1.36 Ib of CO2 is emitted per dollar of output in the manufacturing sector.  In the absence of other
  information, it is assumed that the chemical manufacturer also has an emission profile of approximately 1.36 Ib of CO2 emitted per dollar of product.
Conversion factor estimates assume that 50% of this 1 Ib of CO2 per dollar of sample cost results from electricity use (U.S. average fuel blend) and 50% is
  due to diesel use. A pound of product can then be converted into electricity and diesel usage. The conversion factors result from this electricity and
                                                           diesel usage.
U.S. CARBON DIOXIDE EMISSIONS AND INTENSITIES OVER TIME: A DETAILED ACCOUNTING
             OF INDUSTRIES, GOVERNMENT AND HOUSEHOLDS, APRIL 2010
Environmental Footprint Analysis - Romic Facility, East Palo Alto, CA

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                                                                                                                     Default Environmental Footprint Conversion  Factor References
   Material/Fuel/Service
                              Green Indicator
                                                     Value
                                                                       Units
                                                                         Assumptions
                                                                                                                                                                                                                                                        Information Source
     Laboratory Analysis
                                Energy Used
                                                     6.49
                               Electricity Used
                                                    0.00035
                               All Water Used
                                                    0.00066
                             Potable Water Used
                           Groundwater Extracted
                               CO2e Emitted
                               NOx Emitted
                                                    0.0048
                                SOx Emitted
                                                    0.0036
                                PM Emitted
                                                    0.0004
                           Solid Waste Generated
                            Haz. Waste Generated
                             Air Toxics Emitted
                                                    0.00013
                             Mercury Released
                                                    8.4E-09
                               Lead Released
                                                 0.000000085
                              Dioxins Released
                                                    7.9E-14
Mbtu/S
MWh/S
                                                                    galxlOOO/S
                                                                    galxlOOO/S
                                                                    galxlOOO/S
                                                                       Ibs/S
                                                                       Ibs/S
 Ibs/S
                                                                       Ibs/S
                                                                      tons/S
                                                                      tons/S
                                                                       Ibs/S
 Ibs/S
                                                                       Ibs/S
                                                                       Ibs/S
 Based on the cited reference, approximatley 1 Ib of CO2 is emitted per dollar of GDP. Conversion factor estimates assume that 50% of this 1 Ib of CO2
per dollar of sample cost results from electricity use (U.S. average fuel blend) and 50% is due to diesel use. A pound of product can then be converted into
                        electricity and diesel usage. The conversion factors result from this electricity and diesel usage.
U.S. CARBON DIOXIDE EMISSIONS AND INTENSITIES OVER TIME: A DETAILED ACCOUNTING
             OF INDUSTRIES, GOVERNMENT AND HOUSEHOLDS, APRIL 2010
Environmental Footprint Analysis - Romic Facility, East Palo Alto, CA

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