Final Report
Pilot Region-Based Optimization
Program for Fund-Lead Sites
in EPA Region 3
Site Optimization Tracker:
Butz Landfill Superfund Site
Jackson Township
Monroe County, Pennsylvania
EPA Region III
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Solid Waste and EPA 542-R-06-006h
Emergency Response December 2006
(5102P) www.epa.gov
Pilot Region-Based Optimization Program
for Fund-Lead Sites in EPA Region 3
Site Optimization Tracker:
Butz Landfill Superfund Site
Jackson Township
Monroe County, Pennsylvania
EPA Region III
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Site Optimization Tracker:
Butz Landfill Superfund Site
Jackson Township
Monroe County, Pennsylvania
EPA Region III
December 30, 2005
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SECTION 1:
CURRENT SITE INFORMATION FORM
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Date:
12/30/05
Filled Out By: GeoTrans, Inc.
A. Site Location, Contact Information, and Site Status
1 . Site name 2. Site Location (city and State) 3. EPA Region
. T .- 3325A North Rd, Tannersville, PA _
Butz Landfill io^n 3
loooU
4a. EPA RPM 5a. State Contact
Romuald A. Roman Paul Panek
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-3212 570-826-5434
4c. EPA RPM Email Address 5c. State Contact Email Address
roman.romuald@epa.gov panek.paul@dep.state.pa
5. Is the ground water remedy an interim remedy or a final remedy? Interim! | Final IXI
6. Is the site EPA lead or State-lead with Fund money? EPA IXI State I I
;g«»>»*»*»«»«»*!«
B. General Site Information
1 a. Date of Original ROD for Ground Water Remedy
ROD OU1 9/30/90; ROD OU2 6/20/92
2a. DateofO&F
July 2001
3. What is the primary goal of the P&T system
(select one)?
1 1 Contaminant plume containment
1 I Aquifer restoration
IXI Containment and restoration
1 I Well-head treatment
lb. Dates of Other Ground Water Decision Documents (e.g., ESD, ROD Amendment)
ESD 8/27/99
2b. Date for transfer to State
July 2011
4. Check those classes of contaminants that are
contaminants of concern at the site.
K| VOCs (e.g., TCE, benzene, etc.)
D SVOCs (e.g., PAHs, PCP, etc.)
1 1 metals (e.g., arsenic, chromium, etc.)
1 I other
5. Has NAPL or evidence of NAPL been observed at the site? Yes IXI No I I
6. What is the approximate total pumping rate? 75 gpm
7. How many active extraction wells ,,
(or trenches) are there?
9. How many samples are collected
from monitoring wells or piezometers .
each year? (e.g., 40 if 10 wells are
sampled quarterly)
11. What above-ground treatment processes are usec
IXI Air stripping
I | Carbon adsorption (liquid phase only)
1 I Filtration
IXI Off-gas treatment
1 I Ion exchange
8. How many monitoring wells are t ,
regularly sampled? -40 locations
10. How many process monitoring samples
(e.g., extraction wells, influent, effluent, etc.) ,.
are collected and analyzed each year? (e.g., 24
if influent and effluent are sampled monthly)
(check all that apply)?
1 I Metals precipitation
I | Biological treatment
O UV/Oxidation
I | Reverse osmosis
O Other
12. What is the approximate percentage of system downtime per year? 10% | | 10-20%|/\l >20% | |
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C. Site Costs
1. Annual O&M costs
O&M Category
Labor: project management, reporting,
technical support
Labor: system operation
Labor: ground water sampling
Utilities: electricity
Utilities: other
Consumables (GAC, chemicals, etc.)
Discharge or disposal costs
Analytical costs
Other (parts, routine maintenance, etc.)
O&M Total
Actual1 Annual
Costs for FY04
$39,000
$23,000
$40,000
$4,000
$2,000
$2,000
$13,000
$27,000**
$8,000
$161,000
Estimated2 Annual
Costs for FY05
$32,000
$22,000
$35,000
$7,000
$2,000
$2,500
$13,000
$18,000**
$8,000
$140,000
Estimated2 Annual
Costs for FY06
$32,000
$22,000
$18,000
$7,000
$2,000
$2,500
$13,000
$18,000**
$8,000
$122,500
The O&M total should be equal to the total O&M costs for the specified fiscal years, including oversight from
USAGE or another contractor. For costs that do not fit in one of the above cost categories, include them in the
"Other" category. If it is not possible to break out the costs into the above categories, use the categories as best
as possible and provide notes in the following box.
2. Non-routine or other costs
$3,000
$4,000
$54,000***
Additional costs beyond routine O&M for the specified fiscal years should be included in the above spaces. Such
costs might be associated with additional investigations, non-routine maintenance, additional extraction wells, or
other operable units. The total costs billed to the site for the specified fiscal years should be equal to the O&M
total plus the costs entered in item 2.
Notes on costs:
1. Costs, with the exception of the analytical costs, were provided by the RPM.
2. FY05 and FY06 costs were estimated by the ROET based on the RPM projections and discussions during the
optimization follow-up meetings.
* Decrease in sampling costs assumes the site team will reduce the ground water monitoring frequency as
communicated during the optimization project.
** Analytical costs were estimated by the site contractor based on the sampling program. The analytical costs are
not incurred by the EPA site team because the samples are analyzed by the CLP program. However, analytical
costs similar to those estimated will likely be incurred by the State when the site is transferred to the State after
LTRA. The decrease from FY05 to FY06 reflects the assumed sampling reduction.
*** The increase of $50,000 in non-routine costs represents funding the site team will use to install and connect a
source area extraction well. This funding was previously allocated toward pilot tests of another technology, but
at the suggestion of the ROET have been diverted to the installation of the extraction well.
The "Other" costs are evenly distributed between equipment and travel
The discharge or disposal costs include GAC disposal costs.
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D. Five-Year Review
1. Date of the Most Recent Five-Year Review 9/28/2001
2. Protectiveness Statement from the Most Recent Five-Year Review
IXI Protective I I Not Protective
Protective in the short-term Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
The five-year review was completed four months after the P&T construction, therefore, the
five-year review recommended monitoring and evaluation of P&T performance. The
environmental monitoring (20 wells, approximately ...) and P&T performance monitoring were
analyzed and evaluated in monitoring reports. The site remedy as a whole is protective and
functioning as designed. However, the upgradient end of the plume is not strongly affected by
the remedial design. The extent of the TCE plume has not significantly changed since
treatment began. The TCE concentrations in three extraction wells slowly decrease (wells 1
and 3) or remain stable (well 2). At EW-2, (the extraction well with the highest TCE
concentrations), the TCE concentrations fluctuate between 1,000 ug/L and 2,000 ug/L. The site
team is considering in-situ chemical oxidation and/or enhanced bioremediation to decrease the
hot spot within the plume and shorten the time P&T operates.
E. Other Information
If there is other information about the site that should be provided please indicate that information in the space
below. Please consider enforcement activity, community perception, technical problems to be addressed, and/or
areas where a third-party perspective may be valuable.
- The site team reports that the community sympathizes with EPA remedy.
- The site team has developed and is implementing a revised monitoring program that includes
annual sampling of most site wells. The wells that are not sampled annually will be sampled
every five years.
- GAC (for vapor only) is now changed out approximately semi-annually with 3,000 pounds
per unit
- The site team used the last of the materials for field analysis of MNA parameters and will
now discontinue MNA sampling. Consistent with the recommendation, the site team does not
plan to purchase addition materials for future field analysis.
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SECTION 2:
FOLLOW-UP HISTORY AND SUMMARIES
Note: Follow-up summaries are provided in reverse chronological order and include updated
and/or new recommendations.
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FOLLOW-UP HISTORY
Date of Original Optimization Evaluation
December 15, 2004 (Evaluation meeting)
July 29, 2005 (Final Report)
Meeting Date
July 20, 2005
October 19, 2005
Report Date
Item
July 29, 2005 Follow-Up #1 (conducted as part of pilot project)
December 30, 2005 Follow-Up #2 (conducted as part of pilot project)
Follow-Up #3
Follow-Up #4
Follow-Up #5
Follow-Up #6
Follow-Up #7
Follow-Up #8
"x" in box indicates the item has been completed
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SUMMARY OF FOLLOW-UP #2
Site or System Name
Date of This Follow-Up Summary
Date of Follow-Up Meeting or Call
(Indicate if Meeting or Call)
Butz Landfill Superfund Site
December 30, 2005
October 19, 2005 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Kathy Davies
Paul Leonard
Brian Nishitani
Eric Johnson
Peter Rich
Rob Greenwald
Doug Sutton
Kathy Yager
Steve Chang
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
GeoTrans, Inc.
U.S. EPA Region 3
U.S. EPAOSRTI
Phone
215-814-3130
215-814-3315
215-814-3350
215-814-2675
215-814-3313
410-990-4607
732-409-0344
732-409-0344
617-918-8362
703-603-9017
Email
kuluj ian. norm@epa. gov
davies .kathvtgjepa. gov
Leonard.paul(@,epa. gov
Nishitani.brian(@,epa. gov
Johnson. eric(@,epa. gov
prich(g)geotransinc.com
rgreenwald(@,geotransinc.com
dsutton(@,geotransinc.com
y ager.kathleen@epa. gov
Chang. steven(@,epa. gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Rom Roman
Affiliation
U.S. EPA Region 3 (RPM)
Phone
215-814-3212
Email
Roman.romuald(@,epa. gov
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IMPLEMENTATION STATUS OF ALL RECOMMENDATIONS UNDER CONSIDERATION BUT NOT
PREVIOUSLY IMPLEMENTED
Recommendation
Recommendation
Reason
E-2.1 Implement Institutional Controls
Protectiveness
Implementation
Status
In progress
Comments: The RPM indicated that the previous RPM had worked toward institutional controls for this site.
Current efforts involve reviewing the previous work.
Recommendation
Recommendation
Reason
E-3.2 Reduce Process Monitoring Sampling
Cost Reduction
Implementation
Status
Partially Implemented
(No further follow-up needed)
Comments: As recommended, the site team has eliminated the air stripper water discharge sample, which was
redundant with the sample collected at the system discharge location. However, in contrast to the evaluation
team recommendation, the site team will continue to collect samples from each of the recovery wells on a
quarterly basis. This is consistent with the State's preference. The evaluation team agrees that continuing
quarterly sampling of the recovery wells is a reasonable approach, particularly given the recent increase in
contaminant concentrations seen in the influent and that analysis is provided at no cost to the site through the
CLP.
Recommendation
Recommendation
Reason
E-4.2 Less System Downtime
Technical Improvement
Implementation
Status
In progress
Comments: The site team is in the process of looking for a reliable local person to provide the services
suggested in the optimization evaluation recommendation.
Recommendation
Recommendation
Reason
E-5.1 Continue with P&T Instead of Alternative Remedial Approaches
Site Closeout
Implementation
Status
Implemented
Comments: The site team has decided to continue with a P&T remedy and has discontinued pilot efforts for
other technologies as suggested in the optimization evaluation. The next step is to ask the site contractor for a
cost for an additional extraction well in the source area. There should be adequate funds to cover this additional
extraction well. The $50,000 that the site team had allocated for piloting other technologies will be put toward
the installation and operation of a new source area extraction well.
Recommendation
Recommendation
Reason
Fl-1 Consider Exit Strategy for P&T System
Site Closeout
Implementation
Status
Under consideration
Comments: The site team is considering this recommendation. The ROET acknowledges that this
recommendation is a secondary priority relative to other recommendations, such as reducing system downtime,
and secondary to other site activities, such as installing the source area extraction well. The RPM noted that
these activities will also depend on the presence of DNAPL, which remains uncertain.
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Recommendation
Recommendation
Reason
Fl-2 Revise Vapor Phase GAC Replacement Schedule
Cost Reduction
Implementation
Status
Under consideration
Comments: The site team is considering this recommendation, although the RPM indicated that the State does
not view this favorably. In the mean time, the GAC continues to be switched out on a semi-annual basis.
Key for recommendation numbers:
* E denotes a recommendation from the original optimization evaluation
* Fl, F2, etc. denote recommendations from the first, second, etc. follow-up meeting
* The number corresponds to the number of the recommendation as stated in the optimization
evaluation or follow-up summary where the recommendation was provided
RECOMMENDATIONS PREVIOUSLY IMPLEMENTED OR THAT WILL NOT BE IMPLEMENTED
Recommendation
Reason
Protectiveness
Implementation
Status
Will not be implemented
Recommendation
£-2.2 Attempt to Sample Nearby Supply Wells for Residences that are not Attached
to the Water Line
Comments: The site team has attempted to access these wells in the past but have repeatedly been refused access.
The evaluation team understands these limitations. Other monitoring between the source area and these two wells
shows non-detect, stable, and/or decreasing trends, so sampling of these two wells is not crucial, as long as these
favorable trends continue.
Recommendation
Recommendation
Reason
E-3.1 Proceed with Reduction of Ground Water Sampling Frequency
Cost Reduction
Implementation
Status
Implemented
Comments: The site team reports that these changes have been implemented.
Recommendation
Recommendation
Reason
E-3.3 Eliminate Analysis of MNA Parameters
Cost Reduction
Implementation
Status
Implemented
Comments: The site team reports that these changes have been implemented.
Recommendation
Recommendation
Reason
E-4.1 More Timely Ground Water Monitoring Report Submittals
Technical Improvement
Implementation
Status
Implemented
Comments: The site team reports that these changes have been implemented.
Key for recommendation numbers:
* E denotes a recommendation from the original optimization evaluation
* Fl, F2, etc. denote recommendations from the first, second, etc. follow-up meeting
* The number corresponds to the number of the recommendation as stated in the optimization
evaluation or follow-up summary where the recommendation was provided
-------
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
The increase in influent concentration to one extraction well that was noted during the
previous follow-up meeting has since declined to historical levels, perhaps confirming
that the increase was a temporary rebound that may have occurred while the P&T system
was not functioning for an extended period of time.
The Bio-Traps installed by the site team and referenced in the previous follow-up report
generated ambiguous results. The site team is discontinuing pilot efforts of alternative
technologies to P&T and is continuing with the P&T remedy.
The next Five-Year review will occur in 2006. The sampling data from the recent April
2005 event and from one more event in December will be used for the Five-Year review.
NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP
None.
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SUMMARY OF FOLLOW-UP #1
Site or System Name
Date of This Follow-Up Summary
Date of Follow-Up Meeting or Call
(Indicate if Meeting or Call)
Butz Landfill Superfund Site
July 29, 2005
July 20, 2005 - Meeting
ROET MEMBERS CONDUCTING THE FOLLOW-UP EVALUATION:
Name
Norm Kulujian
Brian Nishitani
Kathy Davies
Peter Rich
Rob Greenwald
Doug Sutton
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
GeoTrans, Inc.
Phone
215-814-3130
215-814-2675
215-814-3315
410-990-4607
732-409-0344
732-409-0344
Email
kuluj ian. norm(g),epa. gov
nishitani.brian@epa. gov
davies .kathy@epa. gov
prich(@,geotransinc.com
rgreenwald(@,geotransinc.com
dsuttontgigeotransinc.com
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Rom Roman
Bruce Rundell
Affiliation
U.S. EPA Region 3 (RPM)
U.S. EPA Region 3 (Hydro)
Phone
215-814-3212
215-814-3317
Email
Roman.romuald(@,epa. gov
Rundell.bruce(@,epa.gov
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IMPLEMENTATION STATUS OF PREVIOUSLY IDENTIFIED RECOMMENDATIONS
Recommendation
Recommendation
Reason
2.1 Implement Institutional Controls
Protectiveness
Implementation
Status
In progress
Comments: The site team continues to work toward implementing institutional controls.
Recommendation
2.2 Attempt to Sample Nearby Supply Wells for Residences that are not Attached to
the Water Line
Recommendation
Reason
Protectiveness
Implementation
Status
Will not implement
Comments: The site team has attempted to access these wells in the past but have repeatedly been refused access.
The evaluation team understands these limitations. Other monitoring between the source area and these two
wells shows non-detect, stable, and/or decreasing trends, so sampling of these two wells is not crucial, as long as
these favorable trends continue.
Recommendation
Recommendation
Reason
3.1 Proceed with Reduction of Ground Water Sampling Frequency
Cost Reduction
Implementation
Status
Implemented
Comments: The site team has developed and is implementing a revised monitoring program that includes annual
sampling of most site wells. The wells that are not sampled annually will be sampled every five years. The site
team has not yet calculated the estimated savings from this new sampling program.
Recommendation
Recommendation
Reason
3.2 Reduce Process Monitoring Sampling
Cost Reduction
Implementation
Status
Partially Implemented
Comments: As recommended, the site team has eliminated the air stripper water discharge sample, which was
redundant with the sample collected at the system discharge location. However, in contrast to the evaluation team
recommendation, the site team will continue to collect samples from each of the recovery wells on a quarterly
basis. The evaluation team agrees that continuing quarterly sampling of the recovery wells is a reasonable
approach, particularly given the recent increase in contaminant concentrations seen in the influent and that
analysis is provided at no cost to the site through the CLP.
Recommendation
Recommendation
Reason
3.3 Eliminate Analysis of MNA Parameters
Cost Reduction
Implementation
Status
Implemented
Comments: The site team used the last of the materials for field analysis of MNA parameters and will now
discontinue MNA sampling. Consistent with the recommendation, the site team does not plan to purchase
addition materials for future field analysis.
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Recommendation
Recommendation
Reason
4.1 More Timely Ground Water Monitoring Report Submittals
Technical Improvement
Implementation
Status
Implemented
Comments: The most recent ground water monitoring report was submitted approximately two months after the
sampling event.
Recommendation
Recommendation
Reason
4.2 Less System Downtime
Technical Improvement
Implementation
Status
Under consideration
Comments: The site team continuing to consider this recommendation.
Recommendation
Recommendation
Reason
5.1 Continue with P&T Instead of Alternative Remedial Approaches
Site Closeout
Implementation
Status
Under consideration
Comments: The site team has been considering using enhanced bioremediation at the site. The RPM has
requested $50,000 for a pilot effort. Thus far, the site team has purchased and installed Bio-Traps in an attempt to
identify the type of microorganisms that are present. The site team's focus is on addressing the former source
area, which is located at the landfill, upgradient of the extraction wells. The evaluation team favors continued
focus on P&T at this point rather than on the use of in-situ technologies and suggests that if the site team is
considering removing additional mass that this be accomplished through the installation of another extraction well
in the former source area.
OTHER CHANGES, UPDATES, OR SIGNIFICANT FINDINGS SINCE LAST FOLLOW-UP
The influent concentration to one extraction well has increased by half an order of
magnitude. The increase is presumably due to rebound that may have occurred while the
P&T system was not functioning for an extended period of time. However, the data have
not yet been interpreted to confirm this presumption. The RPM will provide the most
recent report to the evaluation team so that the evaluation team can consider possible
reasons for the increases and what the implications might be for the remedy as a whole.
The site team has installed Bio-Traps as indicated in the followup to Recommendation
5.1 to determine which microorganisms are present for bioremediation. The site team is
awaiting results. This effort is in conjunction with a pilot test to evaluate the use of
bioremediation for the former source area.
The next Five-Year review will occur in 2006. The sampling data from the recent April
2005 event and from one more event in December will be used for the Five-Year review.
NEW OR UPDATED RECOMMENDATIONS FROM THIS FOLLOW-UP
1. As the P&T system continues to operate, influent concentrations will eventually decline,
effectively reducing the P&T system's ability to remove mass. Decreasing
-------
concentrations and a reduction in P&T system effectiveness at removing mass would
likely suggest attenuation of the residual source material (e.g., DNAPL), and it may
become appropriate and more cost-effective to change the remedy to MNA (existing data
suggest natural attenuation is occurring) or enhanced bioremediation through the addition
of nutrients in select locations. The evaluation team suggests deferring further
consideration of MNA and nutrient injection to a later date when the P&T system's
effectiveness is diminishing. However, it is likely appropriate to start considering the set
of site conditions and site data that would signal the appropriate time for a change in
remedy. The set of conditions would likely consider the potential for plume migration in
the absence of pumping and a comparison of mass removal through natural attenuation
and mass removal through P&T. The cost for developing such an exit strategy for the
P&T system might be $15,000
The site team currently changes the vapor GAC on a semi-annual basis but cannot switch
the lead and lag units due to the system plumbing. As a result, the site team changes out
both GAC units even though only the lead unit generally requires a changeout. The site
team could change out the lead unit on a semi-annual basis and the lag unit on an annual
basis. This approach would help save resources (approximately $3,500 per year) by
reducing the number of unnecessary replacements of the lag unit while maintaining an
effective lag unit that can prevent discharges to the atmosphere.
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UPDATED COST SUMMARY TABLE
Recommendation
Reason
Implementation
Status
Estimated
Capital Costs
($)
Actual Capital
Costs
($)
Estimated Change
in Annual Costs
($/yr)
Actual Change in
Annual Costs
(S/yr)
Original Optimization Evaluation Recommendations
2 . 1 Implement Institutional
Controls
2.2 Sample Nearby Supply
Wells for Residences that are
not Attached to the Water Line
3.1 Proceed with Reduction of
Ground Water Sampling
Frequency
3.2 Reduce Process Monitoring
Sampling
3.3 Eliminate Annual
Laboratory Analysis of MNA
Parameters
4.1 More Timely Ground
Water Monitoring Report
Submittals
4.2 Less System Downtime
5 . 1 Continue with P&T Instead
of Alternative Remedial
Approaches
Protectiveness
Protectiveness
Cost Reduction
Cost Reduction
Cost Reduction
Technical
Improvement
Technical
Improvement
Site Closeout
In progress
Will not be
implemented
Implemented
Partially
Implemented*
Implemented
Implemented
In progress
Implemented
$15,000
$2,000
$0
$0
$0
$0
$0
$0
Not yet quantified
$0
($10,000)**
Not yet quantified
Not quantified***
$0
$0
($17,000)
Minimal due to use
of CLP laboratory
($10,000)
$0
$5,200
$0
Not yet quantified
$0**
Not yet quantified
Not quantified***
New or Updated Recommendations from Follow-up #1, July 20, 2005
1. Consider Exit Strategy for
P&T System
2. Revise Vapor Phase GAC
Replacement Schedule
Site Closeout
Cost Reduction
Under
Consideration
Under
Consideration
$15,000
$0
$0
($3,500)
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New or Updated Recommendations from Follow-up #2, October 19, 2005
None.
Costs in parentheses imply cost reductions.
* The site team has implemented part of the recommendation but will not implement the remaining portion of it. Therefore, no further follow-up is required for this
recommendation.
** The site team will realize savings by avoiding the purchase of additional test kits that would have been used over several years. Therefore, the savings associated
with this recommendation is more appropriately characterized as a reduction of SI 0,000 in capital expenditures rather than a reduction of $10,000 in ongoing
annual expenditures.
*** The costs and savings associated with implementing this r commendation have not been quantified, but as a result of this recommendation, the site team is not
moving forward with pilot tests of alternative technologies. The $50,000 allocated to these pilot tests will be used toward the installation and operation of a source
area extraction well.
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APPENDIX: A
ARCHIVE OF TECHNICAL ASSISTANCE PROVIDED BY THE ROET
Note: Technical assistance items are provided in reverse chronological order.
-------
Technical assistance has not been provided by the ROET to date.
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APPENDIX: B
BASELINE SITE INFORMATION SHEET AND
OPTIMIZATION EVALUATION REPORT
-------
Streamlined
Optimization Evaluation Report
Butz Landfill Superfund Site
Jackson Township
Monroe County, Pennsylvania
EPA Region III
July 29, 2005
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SECTION 1:
BASELINE SITE INFORMATION FORM
-------
Date: 1/14/05
Filled Out By: GeoTrans, Inc.
A. Site Location, Contact Information, and Site Status
1 . Site name 2. Site Location (city and State) 3. EPA Region
. T .- 3325A North Rd, Tannersville, PA _
Butz Landfill io^n 3
loooU
4a. EPA RPM 5a. State Contact
Romuald A. Roman Paul Panek
4b. EPA RPM Phone Number 5b. State Contact Phone Number
215-814-3212 570-826-5434
4c. EPA RPM Email Address 5c. State Contact Email Address
roman.romuald@epa.gov panek.paul@dep.state.pa
5. Is the ground water remedy an interim remedy or a final remedy? Interim! | Final IXI
6. Is the site EPA lead or State-lead with Fund money? EPA IXI State I I
;g«»>»*»*»«»«»*!«
B. General Site Information
1 a. Date of Original ROD for Ground Water Remedy
ROD OU1 9/30/90; ROD OU2 6/20/92
2a. DateofO&F
July 2001
3. What is the primary goal of the P&T system
(select one)?
1 1 Contaminant plume containment
1 I Aquifer restoration
IXI Containment and restoration
1 I Well-head treatment
lb. Dates of Other Ground Water Decision Documents (e.g., ESD, ROD Amendment)
ESD 8/27/99
2b. Date for transfer to State
July 2011
4. Check those classes of contaminants that are
contaminants of concern at the site.
K| VOCs (e.g., TCE, benzene, etc.)
D SVOCs (e.g., PAHs, PCP, etc.)
1 1 metals (e.g., arsenic, chromium, etc.)
1 I other
5. Has NAPL or evidence of NAPL been observed at the site? Yes IXI No I I
6. What is the approximate total pumping rate? 75 gpm
7. How many active extraction wells ,,
(or trenches) are there?
9. How many samples are collected US'
from monitoring wells or piezometers _q
each year? (e.g., 40 if 10 wells are
sampled quarterly) (2005)
11. What above-ground treatment processes are usec
IXI Air stripping
I | Carbon adsorption (liquid phase only)
1 I Filtration
IXI Off-gas treatment
1 I Ion exchange
8. How many monitoring wells are 20 westbay
regularly sampled? wells
10. How many process monitoring samples
(e.g., extraction wells, influent, effluent, etc.) ,
are collected and analyzed each year? (e.g., 24
if influent and effluent are sampled monthly)
(check all that apply)?
1 I Metals precipitation
I | Biological treatment
O UV/Oxidation
I | Reverse osmosis
O Other
12. What is the approximate percentage of system downtime per year? 10% | | 10-20%|XI >20% | |
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C. Site Costs
1. Annual O&M costs
O&M Category
Labor: project management, reporting,
technical support
Labor: system operation
Labor: ground water sampling
Utilities: electricity
Utilities: other
Consumables (GAC, chemicals, etc.)
Discharge or disposal costs
Analytical costs
Other (parts, routine maintenance, etc.)
O&M Total
Actual Annual Costs
for FY03
$25,000
$33,000
$46,000
$4,000
$2,000
$3,000
$15,000
$27,000
$11,000
$173,000
Actual Annual Costs
forFY04
$39,000
$23,000
$40,000
$4,000
$2,000
$2,000
$13,000
$27,000
$8,000
$161,000
Projected Annual
Costs for FY05
$32,000
$22,000
$35,000
$7,000
$2,000
$2,500
$13,000
$18,000
$8,000
$140,000
The O&M total should be equal to the total O&M costs for the specified fiscal years, including oversight from
USAGE or another contractor. For costs that do not fit in one of the above cost categories, include them in the
"Other" category. If it is not possible to break out the costs into the above categories, use the categories as best
as possible and provide notes in the following box.
2. Non-routine or other costs
$7,000
$3,000
$4,000
Additional costs beyond routine O&M for the specified fiscal years should be included in the above spaces. Such
costs might be associated with additional investigations, non-routine maintenance, additional extraction wells, or
other operable units. The total costs billed to the site for the specified fiscal years should be equal to the O&M
total plus the costs entered in item 2.
Notes on costs:
Other costs include equipment and travel
Equipment $5,000
Travel $6,000
$4,000
$4,000
$4,000
$4,000
Non-routine costs include repairs, snow removal, replace components, electrical work,
fencing, etc.
The discharge or disposal costs include GAC disposal costs.
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D. Five-Year Review
1. Date of the Most Recent Five-Year Review 9/28/2001
2. Protectiveness Statement from the Most Recent Five-Year Review
IXI Protective I I Not Protective
Protective in the short-term Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
The five-year review was completed four months after the P&T construction, therefore, the
five-year review recommended monitoring and evaluation of P&T performance. The
environmental monitoring (20 wells, approximately ...) and P&T performance monitoring were
analyzed and evaluated in monitoring reports. The site remedy as a whole is protective and
functioning as designed. However, the upgradient end of the plume is not strongly affected by
the remedial design. The extent of the TCE plume has not significantly changed since
treatment began. The TCE concentrations in three extraction wells slowly decrease (wells 1
and 3) or remain stable (well 2). At EW-2, (the extraction well with the highest TCE
concentrations), the TCE concentrations fluctuate between 1,000 ug/L and 2,000 ug/L. The site
team is considering in-situ chemical oxidation and/or enhanced bioremediation to decrease the
hot spot within the plume and shorten the time P&T operates.
E. Other Information
If there is other information about the site that should be provided please indicate that information in the space
below. Please consider enforcement activity, community perception, technical problems to be addressed, and/or
areas where a third-party perspective may be valuable.
- Community sympathizes with EPA remedy.
- Ground water sampling and reporting is being changed from semi-annual to annual frequency,
therefore, the associated FY05 costs may be further reduced.
- GAC (for vapor only) is changed out approximately quarterly with 3,000 pounds per unit
- Analytical costs inlcuded on cost table are primarily for natural attenuation parameters.
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SECTION 2:
STREAMLINED OPTIMIZATION EVALUATION
FINDINGS AND RECOMMENDATIONS
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Date of Evaluation Meeting:
Butz Landfill Superfund Site
December 15, 2004 Date of Final Report: July 29, 2005
ROET MEMBERS CONDUCTING THE STREAMLINED OPTIMIZATION EVALUATION:
Name
Norm Kulujian
Kathy Davies
Peter Schaul
Peter Rich
Doug Sutton
Steve Chang (by phone)
Jean Balent (by phone)
Affiliation
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
GeoTrans, Inc.
GeoTrans, Inc.
U.S. EPAOSRTI
U.S.EPAOSRTI
Phone
215-814-3130
215-814-3315
215-814-3183
410-990-4607
732-409-0344
202-564-1709
Email
Kurujian.norm(g)epa.gov
Davies.kathy(g),epa.gov
schaul.peter(@,epa.gov
prich(g),geotransinc.com
dsutton(g)geotransinc.com
Chang. steve(g),epamail. epa. gov
Balent.j eant@,epa. gov
SITE TEAM MEMBERS (INCLUDING CONTRACTORS) INTERVIEWED
Name
Rom Roman
Jim Feeney
Bruce Rundell
Affiliation
U.S. EPA Region 3 (RPM)
U.S. EPA Region 3
U.S. EPA Region 3 (Hydro)
Phone
215-814-3212
215-814-3190
215-814-3317
Email
Roman.romuald(@,epa.gov
Feenev.jim(@,epa.gov
Rundell.brucefg.epa.gov
1.0 SIGNIFICANT FINDINGS BEYOND THOSE REPORTED ON SITE INFORMATION FORM
The evaluation team observed an RPM who appears to be an effective manager of a complex
site, making decisions based on a comprehensive understanding of the site that considers the
hydrogeology, engineering, costs, and relationships with other entities. The RPM appears to
effectively utilize Regional technical resources (e.g., hydrogeologists), and Regional
Management appears to be well informed regarding site progress. The observations and
recommendations herein are not intended to imply a deficiency in the work of either the
designers or operators, but are offered as constructive suggestions in the best interest of the EPA
and the public. Recommendations made herein obviously have the benefit of site
characterization data and the operational data unavailable to the original designers.
Findings beyond those reported on the site information form include the following:
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The ground water contamination reaches deep bedrock (up to 300 feet below ground
surface). The contaminant plume is extensive, approximately 0.6 square miles in area.
Contamination has historically been pulled in multiple directions, presumably caused by
former pumping from former domestic wells.
EPA has extended a waterline through the neighborhood, effectively creating a local water
authority, placing nearby residences on public water, and eliminating any reasonable
potential receptors. Some of the old supply wells have been converted into monitoring wells.
Two wells in the area have remained on well water, but these residences were not
contaminated at the time of the Remedial Investigation and were never officially considered
part of the site.
The objective of the P&T system is plume containment and mass removal in the high
concentration area, allowing attenuation of the remaining larger portion of the plume. The
extraction wells were originally placed based on high TCE concentrations and to capture that
high-concentration area. The remaining portion of the plume would be expected to attenuate
naturally. The TCE concentrations at the extraction wells EW-1, EW-2, and EW-3 decreased
by 96%, 86%, and 77%, respectively, from system startup (May 2001) to June 2004. The
system now treats on average over 400 pounds per year at an average operating cost of
$164,000 per year.
As the remedy has progressed, the site team has reduced ground water monitoring from an
initial frequency of monthly to quarterly and then to semi-annually. In 2005, the site team
will further reduce the ground water sampling frequency to annually but will increase the
number of locations sampled. Overall, the number of samples collected per year should
decrease from approximately 40 to 35. The sampling has included sampling for natural
attenuation parameters with both field and laboratory methods. Laboratory analysis for
natural attenuation parameters were discontinued in September 2003. Field colorimetric
samplers, which were purchased in bulk, were utilized for the last time in April 2005 to test
for dissolved oxygen, ferric and total iron, carbon dioxide, and sulfide.
System monitoring includes aqueous samples from the following locations collected on a
monthly basis: each of the three extraction wells, the air stripper water discharge, and the
discharge location. Additionally, system monitoring includes air samples collected from the
following locations: air stripper air discharge, between the carbon units, after the second
carbon unit, and an outside air sample. Air monitoring was originally conducted on a
monthly schedule but was reduced over time to quarterly and then recently (December 2004)
to semi-annually.
The system operates efficiently and is only visited once per month; however, there are a
number of power outages due to storms and high winds that shut down the system. In
addition, there have been a number of problems with the telemetry system that is used to
monitor the system remotely. Within the one-year time span from Summer 2003 through
Summer 2004, there were at least four instances of electrical storms and one instance of high
winds that resulted in power outages. There were at least three instances of computer or
phone-line problems that required additional site visits to repair the telemetry system.
However, there was only one instance where the telemetry system notified the site team of a
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problem (a leak) that was not power related. A few instances of vandalism were also
reported, but these were only evident from site visits and not from remote monitoring. In
addition, mice have been eating the insulation on the electrical wiring. A length of 1,200 feet
of wire was damaged by mice in December 2003. EPA will be modifying its efforts to the
control this problem by using new traps and a sonic system to repel mice.
The reports are very good, including pertinent information and useful cross-sections.
However, there is a substantial delay in receiving the reports. The report summarizing
March 2003 was dated August 2004 and previous reports had at least five to six month
delays. The delay in submitting the August 2004 report was largely the result of an extensive
reinterpretation of the site hydrogeology.
All site data is provided in electronic format to the Site Team by the contractor. These data
include all laboratory and field data provided in an Access database designed by the
Region and all site maps provided in CAD format. These data are incorporated into an
Intranet-based GIS system and used to track remedial progress.
2.0 RECOMMENDATIONS TO IMPROVE SYSTEM PROTECTIVENESS
2.1 IMPLEMENT INSTITUTIONAL CONTROLS
With the assistance of the county, the site team plans to implement institutional controls to
prevent anyone in the neighborhood (i.e., within the "ring of the waterline") from using
ground water. The site team should continue to work on those controls with the county to
have them implemented in a timely manner. EPA efforts for coordinating and/or
participating in these activities might cost $15,000 assuming contractor support for meetings
and other support tasks are required.
2.2 ATTEMPT TO SAMPLE NEARBY SUPPLY WELLS FOR RESIDENCES THAT ARE NOT
ATTACHED TO THE WATER LINE
Two relatively nearby residences with private wells (RIO and RW14) were apparently not
connected to the water line. These two wells were not impacted at the time of the Remedial
Investigation and therefore have not been included as part of the site. It is recommended that
the site team consider sampling these two wells to confirm that they are still not
contaminated. Historical sampling results indicate the residential pumping, in general, has
had an effect on plume migration, and confirming that these two wells are still not impacted
would be prudent. Implementing this recommendation should not require a significant cost
increase because the analyses would likely be provided by the CLP. Efforts associated with
sample collection and access might cost $2,000.
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3.0 RECOMMENDATIONS TO REDUCE SYSTEM COST
3.1 PROCEED WITH REDUCTION OF GROUND WATER SAMPLING FREQUENCY
The site team has planned to reduce the ground water sampling frequency from semi-annual
to annual in year 2005 but to increase the number of locations sampled. Overall, the number
of samples collected per year should decrease from about 40 to about 35. It is recommended
that the site team proceed with this plan, and, as a result, reduce the ground water monitoring
reporting to annual as well. The reduction in sampling should save approximately $10,000
per year. In addition, the reduction in reporting should save approximately $7,000 per year.
3.2 REDUCE PROCESS MONITORING SAMPLING
Process monitoring currently includes monthly sampling of the 3 extraction wells, the air
stripper discharge, and the system outfall. Because the system has operated efficiently on a
regular maintenance schedule, it is recommended that one of the discharge samples be
eliminated. In addition, instead of three extraction well samples per month, a single system
influent sample could be taken and the individual extraction wells could be sampled on an
annual basis. This would reduce the number of samples by 33 per year. Cost savings would
be relatively minor given that samples are analyzed by the CLP and costs are not charged to
the site.
3.3 ELIMINATE ANALYSIS OF MNA PARAMETERS
The site has gathered extensive MNA data and believes that additional analysis will not
provide additional value. The evaluation team supports the site team's suggestion of
dropping the MNA sampling and analysis from the monitoring program once the supplies for
field analyses are depleted, and only resuming this analysis in the future based on the
foreseen need. The associated cost savings from not purchasing additional supplies is likely
on the order of $10,000 per year, which represents a large portion of the current analytical
costs.
4.0 RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT
4.1 MORE TIMELY GROUND WATER MONITORING REPORT SUBMITTALS
The ground water monitoring report for the March 2003 event is dated August 2004 and
other quarterly reports have taken five or six months to be produced. With annual sampling
and reporting, the report should generally be produced within approximately 8 weeks of the
ground water sampling event (or within one month of receiving results from the EPA lab, if
that takes longer than a typical lab). This faster turnaround time should not require an
increase in cost.
7
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4.2 LESS SYSTEM DOWNTIME
Significant downtime has previously occurred due to computer, lightning, and wiring issues.
Those issues should be properly addressed to reduce system downtime. Damage to the
system from lightning appears to be relatively limited or is not reported. Rather, the primary
problem appears to be loss of power during lightning storms and/or high winds. It appears
that even if the system had adequate lightning protection, failures at other points in the
electricity grid could result in power failures. As a result, it is likely not cost-effective to
evaluate or invest in lightning protection. Rather, the site team needs reliable notification
when the system loses power so that it can be restarted promptly. The computer/telemetry
problems have made the remote monitoring unreliable in many instances, and at times, the
site team has had to increase the frequency of site visits.
The site team should consider identifying a local person that can visit the site once per week
to provide routine checks for leaks, power outages, or other problems. When problems
occur, the person could notify the site team, and the site team can make the determination if a
problem needs to be addressed immediately or if the problem can be resolved during the next
regularly scheduled site visit. Apparently, the air stripper and the other system components
work very reliably and do not require much attention. The person would not require
extensive training. Therefore, the visits should be relatively inexpensive, and this person
would be able to report any problems with vandalism or other items that would not be
evident from remote monitoring. A local person might be paid $100 per visit to conduct
routine checks and make a followup phone call from the site. A checklist could be made
available for the person to fill out for each visit so a written record is available. This
recommendation might require $5,200 per year to implement, but equal or greater savings
would likely be realized from eliminating repairs and extra site visits for the telemetry
system.
5.0 RECOMMENDATIONS To SPEED SITE CLOSEOUT
5.1 CONTINUE WITH P&T INSTEAD OF ALTERNATIVE REMEDIAL APPROACHES
DNAPL is likely present and continuing to serve as a source of ground water contamination.
The contaminant plume is deep and relatively extensive. For example, the area impacted
with over 1,000 ug/L is approximately 500,000 square feet in area. The P&T system appears
to be providing mass removal, but the plume shape has changed little. It is unlikely that the
aquifer will be restored in a reasonable time frame, and the evaluation team believes that
meeting ARARs will likely be technically impracticable at this site. However, before
making this determination, the site team should likely continue operation of the P&T system
for several more years (e.g., five to 10 years) to confirm this suspicion.
The evaluation team supports additional source removal, but because P&T will likely need to
continue for a number of years regardless of the success of the source removal effort, the site
team should only consider source removal if it can be done for a relatively low cost. Given
that there is an operating P&T system at the site with additional capacity, the most cost-
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effective means of mass removal would likely be the installation of additional extraction
wells in the source area. The costs would be primarily limited to the capital costs associated
with installing the wells and minor annual costs associated with increased vapor GAC usage.
The capital costs for this option might be $100,000, and the annual costs might increase by
$3,000 per year to account for the increased GAC usage and a minimal amount of additional
electricity usage. Assuming a new extraction well would have an average concentration of
approximately 2,000 ug/L and an average flow rate of 20 gpm, approximately 200 additional
pounds of TCE could be removed per year. Over a 10-year period (without discounting), the
cost per pound removed would be approximately $65 per pound.
An in-situ technology in the source area would likely require significantly higher costs, and
there is no certainty that it would provide results that would significantly reduce the
operating lifetime of the P&T system. If, however, the site team chooses to move forward
with an in-situ technology for the source area, the evaluation team recommends in-situ
chemical oxidation over biostimulation because in-situ chemical oxidation produces quicker
results than biostimulation, is easier to apply over a select area, and can be monitored for
effectiveness more easily than biostimulation. In addition, in-situ chemical oxidation has
much less potential to negatively impact (i.e., foul) the P&T system. Anaerobic
biostimulation requires altering aquifer conditions (in general terms-lowering ORP) in the
area desired for treatment by injecting food sources such as lactate, soy oil, or molasses.
This injection is typically done to form a zone perpendicular to aquifer flow. Attempting to
form this zone in a small portion of the plume generally requires hydraulic control to prevent
outside higher ORP ground water from disturbing the treatment area. If hydraulic control is
not provided, determining the success of the injection is difficult, and having to maintain
hydraulic control defeats much of the advantages of an in-situ technology. Although
establishing hydraulic control in an unconsolidated aquifer is relatively straightforward,
establishing hydraulic control in a fractured bedrock environment can be difficult. Assuming
similar conditions as those described for the addition of another extraction well (e.g., an
average concentration of 2,000 ug/L), the removal of 1,000 pounds of TCE would require
that in-situ chemical oxidation treat approximately 14 million cubic feet of ground water
(e.g., 20 gpm x 1440 min/day x 365 days/year x 10 years). Assuming an aquifer thickness of
approximately 50 feet, this would be a treatment area of 280,000 square feet. Treatment of
an area this large might require anywhere from 10 to 100 wells. At an installation cost of
$20,000 per well, the cost for installing these wells might range from $200,000 to $2 million.
Additional costs would be required for potassium permanganate and the work and oversight
associated with injecting it. If the same mass of contamination is concentrated into a smaller
area as DNAPL, it is unlikely that the potassium permanganate would fully remove the
DNAPL, making it very likely that repeated applications would be required.
If this site did not have an effectively operating P&T system and had to choose an in-situ
remedy, the evaluation team would recommend considering biostimulation as a full-scale
remedy over in-situ chemical oxidation because the food source lasts longer in the subsurface
than oxidating chemicals and therefore fewer injection points would be needed to apply it
since natural ground water flow would spread the food source through the aquifer. However,
bioremediation in fractured bedrock aquifer is still an innovative technology. The evaluation
team knows of one site in Region 3 where it is being applied, in one well in a small plume
with hydraulic control, and results to date have been mixed. At the Butz site, a closed-loop
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pilot test consisting of an injection and extraction well and monitoring points would be
strongly suggested to effectively test the concept. This test would cost a minimum of
$150,000 based on our experience but would likely be higher at the Butz site. If the pilot
was successful, a full scale implementation might include a line of injection points extending
about 1,000 feet in a north-south orientation across the plume just east of the landfill. These
injection wells would be spaced at maximum 30 foot intervals (likely closer) to allow
injection of adequate food source quantities and downgradient coverage of the aquifer. They
would be about 250 feet deep and have screen to allow injection over the total depth of
contamination. Injection at select depths could be accomplished with packers or by nesting
wells. Assuming 35 single wells at $20,000 per well (EPA verbal estimate) the injection
points would cost $700,000. The food source and labor for injecting would require an
estimated $300,000 total (based on a proposal from a vendor for a similar site in New
Jersey). These costs do not include any planning, management or monitoring. Additional
applications of a food source would likely be required to maintain contaminant degradation.
An aggressively priced full-scale application would likely cost more than $1.2 million. The
results of a pilot test (as described above) and quotes from vendors would provide additional
information on what a more realistic cost might be. Regardless, an effective P&T system is
already operating and removing a significant amount of mass. Given the cost and uncertainty
of the success of applying biostimulation at full-scale, it appears that continuing operation of
the existing P&T system would be more cost-effective over the next several years.
PRIORITIZATION AND SEQUENCING OF RECOMMENDATIONS
None
OTHER ACTION ITEMS
None
10
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Cost Summary Table
Recommendation
2 . 1 Implement Institutional
Controls
2.2 Attempt to sample nearby
supply wells for residences that are
not attached to the water line
3 . 1 Reduce Ground Water
Sampling Frequency
3.2 Reduce Process Monitoring
Sampling
3.3 Eliminate Analysis of MNA
Parameters
4. 1 More Timely Ground Water
Monitoring Report Submittals
4.2 Less System Downtime
5 . 1 Continue with P&T instead of
alternative remedial approaches
Reason
Effectiveness
Effectiveness
Cost Reduction
Cost Reduction
Cost Reduction
Technical Improvement
Technical Improvement
Site Closeout
Estimated Additional
Capital Costs
($)
$15,000
$2,000
$0
$0
$0
$0
$0
$0
Estimated Change in
Annual Costs
($/yr)
$0
$0
($17,000)
minimal due to use of
CLP laboratory
($10,000)
$0
$5,200
$0
Costs in parentheses imply cost reductions.
11
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