United States
Environmental Protection
Agency
EPA 540-R-013-018
Office of Solid Waste and Emergency Response
Office of Superfund Remediation and
Technology Innovation
Optimization Review
State Road 114 Ground Water Plume Superfund Site
(Ground Water Treatment System and
Soil Vapor Extraction System)
Levelland, Hockley County, Texas
www.clu-in.org/optimization | www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
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Optimization Review
State Road 114 Ground Water Plume Superfund Site
(Groundwater Treatment System and
Soil Vapor Extraction System)
Levelland, Hockley County, Texas
Report of the Optimization Review
Site Visit Conducted at the State Road 114 Ground Water Plume Superfund Site
September 17, 2013
December 31, 2013
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EXECUTIVE SUMMARY
Optimization Background
The U.S. Environmental Protection Agency's definition of optimization is as follows:
"Efforts at any phase of the removal or remedial response to identify and implement specific
actions that improve the effectiveness and cost-efficiency of that phase. Such actions may also
improve the remedy's protectiveness and long-term implementation which may facilitate progress
towards site completion. To identify these opportunities, regions may use a systematic site review
by a team of independent technical experts, apply techniques or principles from Green
Remediation or Triad, or apply other approaches to identify opportunities for greater efficiency
and effectiveness.1,1
An optimization review considers the goals of the remedy, available site data, conceptual site model
(CSM), remedy performance, protectiveness, cost-effectiveness and closure strategy. A strong interest in
sustainability has also developed in the private sector and within federal, state, and municipal
governments. Consistent with this interest, optimization now routinely considers green remediation and
environmental footprint reduction during optimization reviews.
An optimization review includes reviewing site documents, interviewing site stakeholders, potentially
visiting the site for 1 day, and compiling a report that includes recommendations in the following
categories:
Protectiveness
Cost-effectiveness
Technical improvement
Site closure
Environmental footprint reduction
The recommendations are intended to help the site team identify opportunities for improvements in these
areas. In many cases, further analysis of a recommendation, beyond that provided in this report, may be
needed before the recommendation is implemented. Note that the recommendations are based on an
independent review and represent the opinions of the optimization review team. These recommendations
do not constitute requirements for future action, but rather are provided for consideration by the EPA
Region and other site stakeholders. Also note that while the recommendations may provide some details
to consider during implementation, the recommendations are not meant to replace other, more
comprehensive, planning documents such as work plans, sampling plans and quality assurance project
plans (QAPP).
1 EPA. 2012. Memorandum: Transmittal ofthe National Strategy to Expand Superfund Optimization Practices from Site
Assessment to Site Completion. From: James. E. Woolford, Director Office of Superfund Remediation and Technology
Innovation. To: Superfund National Policy Managers (Regions 1-10). Office of Solid Waste and Emergency Response
(OSWER) 9200.3-75. September 28.
l
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Site-Specific Background
The State Road 114 Ground Water Plume Superfund Site is located 1 mile west of the City of Levelland
in Hockley County, Texas. The site consists of a groundwater plume more than a mile long containing the
primary contaminants 1,2-dichloroethane and benzene. The source of the groundwater contamination is a
former petroleum products refinery that operated between 1939 and 1954. Environmental contamination
of groundwater and soil at the site resulted from the refining operations, associated disposal of wastes,
spills, and leaks. The former refinery property is divided into three areas of concern (AOCs): AOC 1
consists of waste disposal units on the far western portion of the property; AOC 2 consists of an area east
of AOC 1 that was used to store crude oil and refined products, distillation and cracking of crude oil, and
loading refined product; and AOC 3 consists of the area east of Evening Tower Road, which was
presumably used for storage and distillation and cracking of crude and possibly mixing additives as well
as product loading. Groundwater beneath the site is contaminated with organic compounds and metals;
sources of ongoing contamination include a petroleum hydrocarbon layer floating on the water table (light
non-aqueous phase liquid [LNAPL]), the soil matrix in the LNAPL smear zone, and a benzene vapor
plume in the vadose zone. The groundwater remedy consists of a groundwater treatment system and a soil
vapor extraction system.
Summary of CSM
The optimization review focused on current groundwater and soil vapor collection and treatment
operations. CSM components key to these operations include the contaminant distribution and plume
migration velocity, which are discussed in Section 2.4. The optimization review team believes the
presence of LNAPL over a large area, and the large extent of dissolved groundwater impacts, suggest that
groundwater will be contaminated at this site for a very long time. Therefore, primary emphasis should be
on controlling migration of the most contaminated groundwater to make sure the groundwater plume is
not expanding, and keeping annual costs as low as possible given the expected longevity of the remedy.
Summary of Findings
Key findings from this optimization review include:
The extraction wells pump less than designed. The on-site extraction wells that were intended for
mass and LNAPL removal have suffered from significant fouling issues, and the site team is
planning to stop on-site groundwater pumping, which will reduce well maintenance costs
significantly. Three off-site extraction wells (EW-5 to EW-7) are shallow and are intended to
capture the most contaminated off-site groundwater, but those wells also pump at very low rates
and have fouling issues. The other off-site extraction wells (north and east of EW-5 to EW-7)
have longer screen intervals and pump from deeper intervals, and the extraction rates are highest
from the longer-screened wells that have lower average concentrations of volatile organic
chemicals (VOCs).
Water levels have increased beneath the former refinery property, presumably as a result of
recharge of treated water at the injection wells and the on-site impoundment (playa) located west
of the treatment plant building. Water levels have decreased off site to the east, which may result
from a combination of items that include drought, overdraft of water by private irrigation wells,
and remedy pumping which extracts the highest rates from the intermediate and deep zone
remedy extraction wells furthest to the east (EW-1 to EW-4 and EW-8 to EW-10).
n
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There have been fouling problems in the reinjection wells related to barium sulfate. About 75
percent of the system discharge is currently reinjected to the eight reinjection wells and the other
25 percent is discharged to the on-site impoundment (playa) west of the treatment system. The
site team prefers to not discharge to the on-site impoundment and hopes to optimize extraction
and injection so that recharge to the impoundment is no longer needed.
The target capture zone utilized in the modeling reports is the extent of the dissolved-phase
plumes (based on the remedial goal values) in the upper and lower aquifer units. Specific zones of
capture are not easily interpreted from the potentiometric surface maps presented in the annual
reports, and the effectiveness of the capture zone is based on the particle tracks provided by the
groundwater model, using particles started in interior and the edge of the plumes.
Groundwater modeling was updated in summer 2013 and presented in the November 2013 Draft
Groundwater Model Update, which included evaluation of several alternate extraction scenarios.
All on-site shallow extraction wells are eliminated for "Scenario 3" in that report; off-site
extraction wells EW-5 to EW-7 are replaced by EW-5R to EW-7R with longer wells screens and
assumed to pump 25 gallons per minute (gpm) each, EW-8 to EW-9 pump 20 gpm, EW-10 is
reduced to 10 gpm, EW-2 to EW-3 pump 30 gpm, and both EW-1 and EW-4 are eliminated.
Total extraction is 185 gpm. The modeling results suggest that this scenario provides adequate
capture with similar extraction rates to the current system (less than 200 gpm) and also avoids
shallow pumping, which is problematic with respect to well fouling. The modeling predicts that
the extraction wells with deeper screens will provide adequate capture for contaminants in the
shallow zone and suggests the shallow zone in the eastern portion of the plume will dewater over
time (such that it does not make sense to keep existing shallow wells EW-5 to EW-7 in addition
to the suggested replacement wells).
The modeling indicates that a significant amount of treated water is recaptured, which increases
the extraction rate required for capture. Although the model simulations account for the recapture
of treated water, the modeling presented in the report does not illustrate the difference in capture
that might result if treated water was not recharged. (The model has not been used to illustrate
how much less extraction might be required to achieve similar capture if in absence of treated
water being recharged.)
The groundwater treatment system is effective at removing metals and VOCs. The air stripper
off-gas is concentrated with a zeolite wheel and then directed to one of the five cryogenic-cooling
and compression (C3) units to recover product. Although the current system meets effluent
standards, the groundwater system operates at a very high cost and energy usage (mainly a result
of the C3 system that treats air-stripper off-gas). There are likely alternative treatment approaches
for the air stripper off-gas that would require significantly less cost and energy usage.
The soil vapor extraction (SVE) system includes 62 well pairs in the defined LNAPL area. The
initial plan was for 6 years of SVE operation, and currently the SVE operation is in year four. The
primary mass removal is currently from the deep SVE (10 times higher concentrations in the deep
zone), which is resulting in removal of nearly 7,000 gallons of VOCs per month that is sold. The
concentrations in the shallow SVE wells have decreased and the site team is planning to operate
only the deep SVE wells in the future. Four of the five C3 units are for the SVE system. One is
for the shallow SVE system, and three are for the deep SVE system. The C3 system is run on a
fixed fee per month contract plus significantly high electricity use.
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The high electricity use for the C3 systems is by far the highest contributor to the environmental
footprints of the remedy, and costs these are not offset by the reuse of the recovered product. In
addition to the high energy costs that result from the C3 system, the lease/operation of the C3
system represents an extremely large cost of nearly $1.9 million per year. This amount is by far
the highest component cost of the remedy. Use of an alternative approach to treat vapors therefore
offers the greatest potential for cost savings and environmental footprint reduction for this
remedy.
During the optimization review site visit, it was stated that institutional controls still need to be
finalized.
These and other findings are detailed in Section 5 of this report.
Summary of Recommendations
The following recommendations are provided in Section 6 of this report to improve remedy effectiveness,
reduce cost, provide technical improvement, and reduce environmental footprints of the remedy.
Improving effectiveness:
Add sentinel monitoring wells if access allows
Finalize Institutional Controls (ICs)
Implement changes to extraction strategy.
Reducing cost.
Replace or eliminate the C3 systems
Reduce plant operator level of effort (for simplified system)
Reduce groundwater monitoring based on a qualitative evaluation
Reduce project management, support, and reporting (for simplified system)
Reduce well rehabilitation costs (with elimination of on-site extraction wells).
Technical improvement
Operate with only one air stripper (with modified extraction system)
Accurately record injection rates for each location
Include injection well screen lengths in well construction table
Perform simulations with no recharge of treated water.
Site closure:
The site team should make significant efforts to achieve consistent, cost-effective system operation
because operation will continue for many years based on the site contaminant mass. The optimization
review team does not believe that additional in situ technologies should be considered until cost-effective
operation of the current remedy is achieved. Any in situ remedy would be extremely costly because of the
large size of the contaminant plume and source area. It is unclear how effective an in situ remedy would
be at reducing the time span for remediation.
IV
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Environmental Footprint Reduction:
The most significant footprint reductions would be associated with reducing electricity use by replacing
the C3 systems as described as part of the cost savings recommendations. Estimated costs and savings
associated with these recommendations are provided. In particular, the recommendation to eliminate the
C3 systems requires the greatest capital cost, but has a short payback period and results in significant
savings with respect to cost and environmental footprints. An evaluation of estimated footprint reductions
resulting from elimination of the C3 systems is provided. In total, recommendations with the potential to
save more than $2 million per year are suggested, with estimated capital costs of less than $1 million.
v
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NOTICE
Work described herein including preparation of this report was performed by Tetra Tech for the U.S.
Environmental Protection Agency under Work Assignment #2-48 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.
VI
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PREFACE
This report was prepared as part of a national strategy to expand Superfund optimization from remedial
investigation to site completion implemented by the EPA Office of Superfund Remediation and
Technology Innovation (OSRTI). The project contacts are as follows:
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EPA Office of Superfund
Remediation and
Chip Love
EPA
Construction and Post-Construction Branch
Technology
Innovation
U.S. EPA OSRTI
Ariel Rios Building
(OSRTI)
Mailstop (5204G)
1200 Pennsylvania Ave., N.W.
Washington, DC 20460
love. chiofo1 eoa. so v
phone: 703-603-0695
Tetra Tech, Inc.
Therese Gioia
Tetra Tech, Inc.
(Contractor to EPA)
1881 Campus Commons Drive
Suite 200
Reston, VA20191
therese.sioia(2)tetratech.com
phone: 815-923-2368
Tetra Tech, Inc.
Peter Rich, P.E.
Tetra Tech, Inc.
51 Franklin Street, Suite 400
Annapolis, MD 21401
peter.richfStetratech.com
phone: 410-990-4607
Vll
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LIST OF ACRONYMS
%
Percent
ligfL
Micrograms per liter
AOC
Area of concern
bgs
Below ground surface
BMP
Best management practices
Btu
British thermal unit
C3
Cryogenic-cooling and compression
ccf
Hundred cubic feet
CCRA
Consumer Cooperative Refinery Association
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CLP
Contract Laboratory Program
co2
Carbon dioxide
C02e
Carbon dioxide equivalents of global warming potential
COC
Contaminant of concern
CSIA
Compound-specific isotope analysis
CSM
Conceptual site model
1,2-DCA
1,2-dicholoroethane
DBSA
Daniel B. Stephens & Associates, Inc.
EA
EA Engineering, Science, and Technology, Inc.
EPA
U.S. Environmental Protection Agency
ERA
Ecological risk assessment
ft2
Square feet
ft/d
Feet per day
ft/vr
Feet per year
GAC
Granular activated carbon
GEO
Good Earthkeeping Organization, Inc.
GHG
Greenhouse gas
gpd
Gallons per day
gpm
Gallons per minute
HAP
Hazardous air pollutant
HDPE
High-density polyethylene
ICs
Institutional controls
kW
Kilowatts
kWh
Kilowatt hour
lbs
Pounds
If
Linear feet
LNAPL
Light non-aqueous phase liquid
LTM
Long-term monitoring
MAROS
Monitoring and Remediation Optimization System
MCL
Maximum Contaminant Level
MFC
Motor Fuels Corporation
mg/kg
Milligrams per kilogram
mg/m3
Milligrams per cubic meter
MMBtu
Million British thermal units
NAPL
Non-aqueous phase liquid
Vlll
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NOx
Nitrogen oxides
O&M
Operation and maintenance
OSRTI
Office of Super fund Remediation and Technology Innovation
OSWER
Office of Solid Waste and Emergency Response
OU
Operable unit
PCL
Protective concentration limit
PDB
Passive diffusion bag
ppmv
Parts per million by volume
P&T
Pump and treat
PM
Particulate matter
QAPP
Quality Assurance Project Plan
RAO
Remedial action objective
RC
Restrictive covenant
ROD
Record of Decision
RSE
Remediation system evaluation
SCADA
Supervisory Control and Data Acquisition
scfm
Standard cubic feet per minute
SEFA
Spreadsheets for Environmental Footprint Analysis
SOx
Sulfur oxides
SVE
Soil vapor extraction
TAC
Texas Administrative Code
TCEQ
Texas Commission on Environmental Quality
TIFSD
Technology Innovation and Field Services Division
TDS
Total dissolved solids
TSS
Total suspended solids
TVHC
Total volatile hydrocarbons
VOC
Volatile organic compound
IX
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TABLE OF CONTENTS
EXECUTIVE SUMMARY 1
NOTICE vi
PREFACE vn
LIST OF ACRONYMS vm
1.0 INTRODUCTION 1
1.1 Purpose 1
1.2 Team Composition 2
1.3 Documents Reviewed 3
1.4 Quality Assurance 5
1.5 Persons Contacted 5
2.0 SITE BACKGROUND 6
2.1 Location 6
2.2 Site History 6
2.2.1 Historical Land use and Facility Operations 6
2.2.2 Chronology of Enforcement and Remedial Activities 6
2.3 Potential Human and Ecological Receptors 7
2.4 Existing Data and Information 7
2.4.1 Sources of Contamination 7
2.4.2 Geology Setting and Hydrogeology 8
2.4.3 Soil Contamination 9
2.4.4 Soil Vapor Contamination 9
2.4.5 Groundwater Contamination 9
2.4.6 Surface Water Contamination 9
3.0 DESCRIPTION OF PLANNED OR EXISTING REMEDIES 10
3.1 Existing Remedies 10
3.1.1 Groundwater Extraction 10
3.1.2 Groundwater Treatment 11
3.1.3 Soil Vapor Extraction and Treatment 12
3.2 Remedial Action Objectives and Standards 13
3.3 Monitoring Programs 13
3.3.1 Treatment Process Monitoring 13
3.3.2 Long-Term Monitoring (LTM) for Groundwater 13
3.4 Air and Water Discharge Standards 14
4.0 CONCEPTUAL SITE MODEL 16
5.0 FINDINGS 17
5.1 General Findings 17
5.1.1 Groundwater Pumping, Groundwater Flow, and Plume Capture 17
5.1.2 Groundwater Treatment 20
5.1.3 Soil Vapor Extraction 20
5.1.4 Groundwater Monitoring 21
X
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5.1.5 Institutional Controls (ICs) 21
5.1.6 Suggestions by Site Team for Potential System Modifications 22
5.2 Components or Processes That Account for Majority of Annual Costs 22
5.2.1 Labor and Truck 23
5.2.2 Groundwater Sampling 23
5.2.3 Chemical Costs 23
5.2.4 Utilities 24
5.2.5 C3 System 24
5.3 Approximate Environmental Footprint Associated with Remedy 24
5.3.1 Energy, Air Emissions, and Greenhouse Gases 24
5.3.2 Water Resources 25
5.3.3 Land and Ecosystems 26
5.3.4 Materials Usage and Waste Disposal 26
5.4 Safety Record 26
RECOMMENDATIONS 27
6.1 Recommendations to Improve Effectiveness 27
6.1.1 Add Sentinel Monitoring Wells If Access Allows 27
6.1.2 Finalize Institutional Controls (ICs) 27
6.1.3 Implement Changes to Extraction Strategy 28
6.2 Recommendations to Reduce Costs 28
6.2.1 Replace/Eliminate the C3 Systems 28
6.2.2 Reduce Plant Operator Level of Effort 29
6.2.3 Reduce Groundwater Monitoring 29
6.2.4 Reduce PM/Support/Reporting 30
6.2.5 Reduce Well Rehabilitation Costs 30
6.3 Recommendations for Technical Improvement 31
6.3.1 Evaluate Operation with Only One Air Stripper For
Modified System 31
6.3.2 Accurately Record Injection Rates for Each Location 31
6.3.3 Include injection Well Screen Lengths in Well Construction Table 31
6.3.4 Perform Simulations With No Recharge of Treated Water 31
6.4 Considerations for Gaining Site Closeout 32
6.5 Recommendations Related to Environmental Footprint Reduction 32
6.5.1 Replace/Eliminate the C3 Systems 32
6.6 Summary 32
xi
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LIST OF TABLES
Table 1: Optimization Review Team Composition 2
Table 2: Persons Contacted During Optimization Review 5
Table 3: Number of Long-Term Monitoring Locations (Three Recent Events) 14
Table 4: Water Discharge Limits for Selected COCs 15
Table 5: Am Discharge Limits 15
Table 6: Summary of Annual Operating Costs 23
Table 7: Summary of Energy and AirAnnual Footprint Results 25
Table 8: Summary of Recommendations and Associated Costs 33
APPENDICES
Appendix A: Select Figures from Site Documents
Appendix B: Informational Quotes - Anguil Thermal Oxidizer
Appendix C: Input Summary for SEFA Footprint Analysis
ATTACHMENTS
1 SEFAFootprinting Spreadsheets (electronic files)
xii
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1.0 INTRODUCTION
1.1 Purpose
During fiscal years 2000 and 2001, independent site optimization reviews called Remediation System
Evaluations (RSE) were conducted at 20 operating Fund-lead pump and treat (P&T) sites (that is, those
sites with P&T systems funded and managed by Superfund and the states). As a result of the opportunities
for system optimization that arose from those RSEs, the U.S. Environmental Protection Agency Office of
Superfund Remediation and Technology Innovation (OSRTI) has incorporated RSEs into a larger post-
construction complete strategy for Fund-lead remedies, as documented in Office of Solid Waste and
Emergency Response (OSWER) Directive No. 9283.1 -25, Action Plan for Ground Water Remedy
Optimization. Concurrently, the EPA developed and applied the Triad Approach to optimize site
characterization and development of a conceptual site model (CSM). The EPA has since expanded the
definition of optimization to encompass investigation-stage activities using Triad Approach best
management practices (BMP) during design and RSEs. The EPA's definition of optimization is as
follows:
"Efforts at any phase of the removal or remedial response to identify and implement
specific actions that improve the effectiveness and cost-efficiency of that phase. Such
actions may also improve the remedy's protectiveness and long-term implementation
which may facilitate progress towards site completion. To identify these opportunities,
regions may use a systematic site review by a team of independent technical experts,
apply techniques or principles from Green Remediation or Triad, or apply other
approaches to identify opportunities for greater efficiency and effectiveness. " 2
As stated in the definition, optimization refers to a "systematic site review", indicating that the site as a
whole is often considered in the review. Optimization can be applied to a specific aspect of the remedy
(for example, focus on long-term monitoring [LTM] optimization or focus on one particular operable unit
[OU]), but other components of the site or remedy are still considered to the degree that they affect the
focus of the optimization. An optimization review considers the goals of the remedy, available site data,
the CSM, remedy performance, protectiveness, cost-effectiveness and closure strategy. A strong interest
in sustainability has also developed in the private sector and within federal, state and municipal
governments. Consistent with this interest, OSRTI has developed a Green Remediation Primer
(www.cluin.org/greenremediation) and now routinely considers green remediation and environmental
footprint reduction during optimization evaluations.
The optimization review included reviewing site documents, visiting the site for 1 day and compiling this
report, which includes recommendations in the following categories:
Protectiveness
Cost-effectiveness
2
EPA. 2012. Memorandum: Transmittal ofthe National Strategy to Expand Superfund Optimization Practices from Site
Assessment to Site Completion. From: James. E. Woolford, Director Office of Superfund Remediation and Technology
Innovation. To: Superfund National Policy Managers (Regions 1-10). Office of Solid Waste and Emergency Response
(OSWER) 9200.3-75. September 28.
1
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Technical improvement
Site closure
Environmental footprint reduction.
The recommendations are intended to help the site team identify opportunities for improvements in these
areas. In many cases, further analysis of a recommendation, beyond that provided in this report, may be
needed before the recommendation is implemented. Note that the recommendations are based on an
independent evaluation and represent the opinions of the optimization review team. These
recommendations do not constitute requirements for future action, but rather are provided for
consideration by the EPA Region and other site stakeholders. Also note that while the recommendations
may provide some details to consider during implementation, the recommendations are not meant to
replace other, more comprehensive, planning documents such as work plans, sampling plans and quality
assurance project plans (QAPP).
The national optimization strategy includes a system for tracking consideration and implementation of the
optimization review recommendations and includes a provision for follow-up technical assistance from
the optimization review team as mutually agreed on by the site management team and EPA OSRTI.
Environmental contamination of groundwater and soil occurred at the State Road 114 Ground Water
Plume Superfund Site as a result of petroleum refining operations and associated waste disposal activities,
leaks and spills. The groundwater remedy consists of a groundwater extraction and treatment system and
a soil vapor extraction (SVE) system. The groundwater system is intended to achieve hydraulic
containment of the contaminant plume and restore the Ogallala aquifer to its beneficial use as a drinking
water supply. The SVE system removes light non-aqueous phase liquid (LNAPL) and organic vapors in
the vadose zone.
The site was selected by the EPA OSRTI for optimization review based on a nomination from EPA
Region 6. The optimization review is focused on current operational effectiveness and efficiency of the
remedial systems. The optimization review includes discussion and evaluation of ongoing contamination
sources, discharge criteria, and an operating cost breakdown. Other components of the site remedy are
considered only as they relate to the remedial systems.
1.2 Team Composition
The optimization review team consisted of the individuals listed in Table 1.
Table 1: Optimization Review Team Composition
Nil liK1
Affiliation
Phone
Email
Chip Love
EPA HQ
703-603-0695
love. chiD(ฎ.eDa. 20V
Peter Rich
Tetra Tech, Inc.
410-990-4607
Deter. richfStetratech. com
Rob Greenwald
Tetra Tech, Inc.
503-223-5388
rob.sreenwaldfSJtetratech.com
Carolyn Pitera*
Tetra Tech, Inc.
703-390-0621
carolvn.Diteraf5)tetratech.com
*Did not attend site visit.
2
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1.3 Documents Reviewed
The following documents were reviewed in support of the optimization review. The reader is directed to
these documents for additional site information that is not provided in this report.
Technical Memorandum Phase I Remedial Investigation, Daniel B. Stephens & Associates, Inc.,
March 2003
Draft Technical Memorandum Phase II Remedial Investigation, State Road 114 Ground Water
Plume Superfund Site, Levelland, Texas, Daniel B. Stephens & Associates, Inc., April 2004
Analysis of Pumping Test of the Ogallala Aquifer at Area 1, State Road 114 Ground Water Plume
Superfund Site, Levelland, Texas, Daniel B. Stephens & Associates, Inc., May 2004
Analysis of Pumping Test of the Ogallala Aquifer at Area 2, State Road 114 Ground Water Plume
Superfund Site, Levelland, Texas, Daniel B. Stephens & Associates, Inc., May 2004
Soil Analysis Data Quality Objectives, State Road 114 Ground Water Plume Superfund Site,
Daniel B. Stephens & Associates, Inc., October 2004
Final Remedial Investigation Report, State Road 114 Ground Water Plume Superfund Site,
Levelland, Texas, Daniel B. Stephens & Associates, Inc., August 2005
Groundwater Modeling for Remediation System Design, State Road 114 Ground Water Plume
Superfund Site, Daniel B. Stephens & Associates, Inc., August 2005
Feasibility Study Report, State Road 114 Ground Water Plume Superfund Site, EA Engineering,
Science and Technology, Inc., January 2008
EPA Announces Proposed Plan, State Road 114 Ground Water Plume Superfund Site, Hockley
County, Texas, EPA, January 2008
Record of Decision, State Road 114 Ground Water Plume Superfund Site, Superfund Division
EPA Region 6, March 2008
Final Remedial Design ReportWell Construction, State Road 114 Ground Water Plume
Superfund Site, Levelland, Hockley County, Texas, EA Engineering, Science and Technology,
Inc., November 2008
Final Remedial Design Report-Ground Water, State Road 114 Ground Water Plume Superfund
Site, EA Engineering, Science and Technology, Inc., February 2009
Superfund Preliminary Close Out Report, State Road 114 Ground Water Plume Superfund Site,
Levelland, Hockley County, Texas, EPA, August 2009
Superfund Site Update, State Road 114 Ground Water Plume Superfund Site, EPA, September
2009
Interim Remedial Action Report (Revision 01), State Road 114 Ground Water Plume Remedial
Action, EA Engineering, Science and Technology, Inc., August 2010
3
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Superfund Site Update, State Road 114 Ground Water Plume Superfund Site, EPA Region 6,
September 2010
Results for SR-114 pH Pilot Test to Resolve Injection Well Failure, State Road 114 Ground Water
Plume Superfund Site, PowerPoint Presentation, EA Engineering, Science and Technology, Inc.,
October 2011
Ground Water Sampling Report, August 2011 Quarterly Sampling Event, Long Term Response
Action, State Road 114 Ground Water Plume Superfund Site, EA Engineering, Science and
Technology, Inc., December 2011
Annual Operation & Maintenance Report, 1 September 2010 through 31 August 2011, Long
Term Response Action, State Road 114 Ground Water Plume Superfund Site, EA Engineering,
Science and Technology, Inc., March 2012
Ground Water Sampling Report, December 2011 Quarterly Sampling Event, Long Term
Response Action, State Road 114 Ground Water Plume Superfund Site, EA Engineering, Science
and Technology, Inc., March 2012
Ground Water Sampling Report, May 2012 Quarterly Sampling Event, Long Term Response
Action, State Road 114 Ground Water Plume Superfund Site, EA Engineering, Science and
Technology, Inc., September 2012
Application of Horizontal Air Sparging to the Groundwater Remedy, State Road 114 Ground
Water Plume Superfund Site, Daniel B. Stephens & Associates, Inc., February 2013
Evaluation of Changes in Water Levels at the State Road 114 Superfund Site at the State Road
114 Superfund Site, Daniel B. Stephens & Associates, Inc., February 2013
Ground Water Sampling Report, November 2012 Quarterly Sampling Event, Long Term
Response Action, State Road 114 Ground Water Plume Superfund Site, EA Engineering, Science
and Technology, Inc., February 2013
Annual Operation & Maintenance Report, 1 September 2011 through 31 August 2012, Long
Term Response Action, State Road 114 Ground Water Plume Superfund Site, EA Engineering,
Science and Technology, Inc., May 2013
Power Consumption Metric for 2010, 2011, 2012, 2013
Xcel Energy Utility Bills, September 2009 - February 2013
PowerPoint slides presented by the site team during the September 17, 2013, optimization review
site visit
Draft Groundwater Model Update, State Road 114 Ground Water Plume, EA Engineering,
Science and Technology, Inc., November 19, 2013
In addition, Luis Vega from EA Engineering, Science and Technology, Inc. (EA), provided remedy cost
information for September 2011 to August 2012 and for September 2012 to August 2013 via e-mail after
the site visit for the optimization review was conducted.
4
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1.4 Quality Assurance
This optimization review utilizes existing environmental data to evaluate remedy performance and to
make recommendations to improve the remedy. The optimization review team evaluates the quality of the
existing data before the data are used for these purposes. The evaluation for data quality includes a brief
review of how the data were collected and managed (where practical, the site QAPP is considered), the
consistency of the data with other site data, and the use of the data in the optimization review. Data that
are of suspect quality are either not used as part of the optimization review or are used with the quality
concerns noted. Where appropriate, this report provides recommendations to improve data quality.
1.5 Persons Contacted
The following individuals associated with the site were present for the site visit:
Table 2: Persons Contacted During Optimization Review
iNninc
Afllliiilion
]0-m nil
Vince Malott
EPA Region 6
malott.vincentfS)eDa.20v
Alan Henderson
Texas Commission on Environmental Quality (TCEQ)
Luis Vega
EA Engineering, Science, and Technology, Inc.
Danny Leaks
EA Engineering, Science, and Technology, Inc.
Plant Operator (not including GEO Systems)
Tim Startz
EA Engineering, Science, and Technology, Inc.
Stan Wallace
EA Engineering, Science, and Technology, Inc.
Jay Snyder
EA Engineering, Science, and Technology, Inc.
Carol Winell
Good Earthkeeping Organization, Inc. (GEO)
Joe Chwirka
Daniel B. Stephens & Associates, Inc. (DBSA)
Faraq Botros
Daniel B. Stephens & Associates, Inc. (DBSA)
EPA retains EA for operation and maintenance of the remedial systems and groundwater monitoring. EA
subcontracts Daniel B. Stephens & Associates, Inc. (DBSA) for hydrogeology support and Good
Earthkeeping Organization, Inc. (GEO) for the cryogenic-cooling and compression (C3) plant operation
that is part of the treatment process. EA also subcontracts other firms for well rehabilitation, maintenance
of specific items (electrical, controls, and metals filtration system), and process sample analysis.
5
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2.0 SITE BACKGROUND
This section is a summary based on information in the documents reviewed.
2.1 Location
The State Road 114 Ground Water Plume Superfund Site is located within the Levelland Oil Field along
Evening Tower Road, 1 mile west of the City of Levelland in Hockley County, Texas. The site is
bordered by State Highway 114, undeveloped land, and a railroad line. The area is relatively flat with
topography generally sloping gently to the southeast. Other properties within 1 mile of the site include
agricultural, commercial/industrial, recreational, and residential areas. The site location is shown on
Figure 1 included in Appendix A.
2.2 Site History
2.2.1 Historical Land use and Facility Operations
The source of the groundwater contamination is a 64-acre former petroleum products refinery with a
production capacity of 5,500 barrels/day of gasoline, tractor fuels, diesel, distillate products, and fuel oils.
It was operated from its construction in 1939 to 1945 by Motor Fuels Corporation (MFC) and by the
Consumers Cooperative Refinery Association (CCRA) from 1945 to 1954. Prior to 1939, the refinery
property was undeveloped farm and grassland. The refinery facilities were dismantled or demolished
between 1954 and 1958. Subsequently, the property was divided into various parcels and sold in 1958.
Currently, most of the site area is occupied by Farmers Co-Op Elevator Association offices, warehouses,
and grain storage facilities constructed prior to 1987 in the central and eastern portion of the site.
The former refinery property is divided into three areas of concern (AOCs). AOC 1 is located on the far
western portion of the property and includes the playa (15-acre basin), the central, northern, southern, and
southeastern impoundments, five tar pits, and a large excavated area. The playa basin, impoundments and
pits received brine water, waste oil, off-specification refined fuel, and runoff. AOC 2 includes the area
east of AOC 1 and west of Evening Tower Road and was used to store crude oil and refined product,
distill and crack crude oil, and load refined product. AOC 3 consists of the east side refinery (east of
Evening Tower Road) and was used for storing, distilling, and cracking crude oil and presumably for
storing and mixing additives and loading refined product. Reported leaks from process equipment and
spills throughout the refinery area resulted in comingling of crude oil and off-specification petroleum
products with wastewaters and other liquid wastes disposed of in the disposal units, pits, and excavated
area.
2.2.2 Chronology of Enforcement and Remedial Activities
Predecessors of the Texas Commission on Environmental Quality (TCEQ) (Texas Water Commission
and Texas Natural Resource Conservation Commission [TNRCC]) began groundwater contamination
investigations at the site in 1990. TNRCC investigations conducted from 1997 through 2000 with
involvement of the EPA indicated elevated groundwater concentrations for 1,2-dichloroethane (1,2-
DCA), benzene, arsenic, manganese, vanadium, and other contaminants of concern (COCs) in several
residential and commercial wells, one irrigation well and several municipal wells in the vicinity of the
site. The TNRCC investigated the Farmers Co-Op and oil field service-related businesses, including
Edward's Transport, Inc. and Well-Co Oil Service, Inc. along the south side of State Highway 114 as
6
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potential sources contributing to the groundwater plume, along with the former refinery. No conclusive
evidence was identified for confirming one or more sources.
The TNRCC and EPA installed and maintained point-of use groundwater filtration systems to address the
COCs in the affected private and public water supply wells. Subsequently, the TCEQ completed the
remedial investigation in 2005; the EPA completed the feasibility study and supplemental investigation,
ecological assessment, and additional groundwater sampling in 2008, and issued the Record of Decision
(ROD) for the site on March 31, 2008. The site-wide remedy specified in the ROD included excavation of
surface soil contaminated with copper and zinc (completed in April 2009), installation of a new municipal
water supply system (completed in July 2009 followed by removal of the filtration systems), and
installation of a groundwater extraction and treatment system and soil vapor extraction system. The
current remedial systems began operation in September 2009. The EPA is currently operating the
groundwater and SVE systems and anticipates transferring operation and maintenance of the groundwater
system to the TCEQ in September 2020. (The SVE system operation, if it is still ongoing, will not be
transferred.)
2.3 Potential Human and Ecological Receptors
Groundwater comprises approximately one-third of the City of Levelland's drinking water supply. In
addition, some businesses and residences in the plume area obtain drinking water, irrigation water, or both
from private wells. The Ogallala aquifer is the only source of high-quality drinking water in the site area.
Benzene, 1,2-DCA, arsenic, and 1,2-dibromoethane in groundwater present a risk to human receptors who
may use unfiltered groundwater from private wells. However, all residences and businesses with affected
water wells have been connected to the municipal water supply line installed in 2009, and groundwater is
no longer used for potable purposes in the area.
With regard to soil contamination, a 2006 human health risk assessment indicated that since current land
use is commercial/industrial (that is, non-residential), human health exposure to existing COCs in soil is
considered acceptable, and current and future commercial/industrial carcinogenic risks do not present an
unacceptable risk to on-site workers. A 2006 ecological risk assessment (ERA) indicated a potential
unacceptable risk to ecological receptors in areas within AOC 1 (abandoned drum hot spot) and AOC 2
(west side hot spot) based on copper and zinc concentrations in soil above the ecological screening
criteria of 61 milligrams per kilogram (mg/kg) for copper and 120 mg/kg for zinc in soil. The ERA did
not identify any unacceptable risk to waterfowl and mammals and aquatic wildlife receptors that may
come in contact with the playa sludge.
2.4 Existing Data and Information
2.4.1 Sources of Contamination
Sources of ongoing contamination at the site include LNAPL (petroleum hydrocarbon layer floating on
the water table), the soil matrix in the LNAPL smear zone, and a benzene vapor plume in the vadose
zone.
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2.4.2 Geology Setting and Hydrogeology
Local geology is composed of the following units, from top to bottom:
Fine-grained sand and clay (approximately the upper 20 feet)
Caliche-bearing fine sand (approximately 70 feet thick)
Sandstone (approximately 10 feet thick)
Sands that increase in coarseness with depth (approximately 75 to 120 feet thick)
Clay aquitard that is encountered at approximately 175 to 215 feet below ground surface (bgs).
The water table or saturated zone of the Ogallala aquifer is encountered at approximately 140 feet bgs,
and the saturated thickness varies across the site from approximately 40 to 80 feet. Direction of
groundwater flow is to the east-northeast.
The Remedial Design Report (EA, February 2009) indicates the following with respect to aquifer
parameters:
Hydraulic conductivity - After two aquifer tests at the SR 114 site were completed using test
wells screened across the entire saturated thickness (that is, both the shallow and deep zones), the
average hydraulic conductivity of the aquifer was determined to be 14 feet per day near the
leading edge of the plume and 20 feet per day near the mid-plume. However, based on the
location of paleochannels and the general thickening of course-grained sediments, the average
aquifer hydraulic conductivity probably increases east of the plume front.
Storage coefficient - Values for storage coefficient of 0.005 and 0.034 in the plume front and
mid-plume areas were calculated based on the results of the two aquifer tests conducted at the
site.
The storage coefficient values reported based on the aquifer tests indicate semi-confined conditions. The
area is quite arid and very little net recharge from precipitation is anticipated. The Remedial Design
Report indicates that groundwater recharge in the Levelland area may be greater as a result of infiltration
of imported Canadian River Municipal Water Authority water and infiltration of focused storm runoff, as
has been observed to the east within the City of Lubbock.
The Annual Report for September 2011-August 2012 states that "The magnitude of the gradient is
approximately 0.004 ft per ft." but is not clear if that value is pre-remedy or post-remedy. Based on
potentiometric maps in the Annual Report for September 2011 to August 2012, the observed hydraulic
gradient appears to be higher, and a value of approximately 0.0067 appears to be more representative of
current conditions.
Assuming a hydraulic conductivity of 14 to 20 feet per day (ft/d) from the aquifer tests, an
approximate hydraulic gradient magnitude of 0.0067 (from recent potentiometric surface maps),
and porosity of 0.2 to 0.3, the groundwater flow velocity under current conditions would be
expected to be on the order of 100 to 250 feet per year (ft/yr).
Assuming a hydraulic conductivity of 14 to 20 ft/d from the aquifer tests, an approximate
hydraulic gradient magnitude of 0.004 (assumed for pre-remedy conditions), and porosity of 0.2
8
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to 0.3, the pre-remedy groundwater flow velocity would be expected to be on the order of 70 to
150 fit/yr.
Higher hydraulic gradients under current conditions (relative to pre-remedy conditions) are consistent
with higher water levels beneath the former refinery property and lower water levels off site that have
been observed in recent years, which is reportedly a combined result of the remedy (recharge of treated
water on the former refinery property and remedy extraction off site) and regional factors (drought and
off-site, non-remedy irrigation pumping) that are discussed in the Annual Report for September 2011-
August 2012.
2.4.3 Soil Contamination
The September 2009 Superfund Site Update states the following: 'The soil remedy was completed in
April 2009. Soil contaminated with copper and zinc from the former refinery was excavated and buried
on-site to eliminate potential ecological risks in the area." The optimization review did not focus on soil
contamination.
2.4.4 Soil Vapor Contamination
Soil vapor contamination is expected because the site contaminants include volatile organic compounds
(VOC) (for example, benzene) and the site remedy includes soil vapor extraction.
2.4.5 Groundwater Contamination
The groundwater contaminant plume is approximately 1.2 miles long and extends approximately 0.7 mile
to the east-northeast beyond the edge of the eastern boundary of the site. Specific COCs in groundwater
include benzene, 1,2-DCA, arsenic and manganese. A defined arsenic plume is not evident at the site. The
manganese plume is caused by reducing conditions in the aquifer that results from the VOC
contamination. The benzene plume attenuates within a shorter distance than the 1,2-DCA plume. The 1,2-
DCA plume is the driver of groundwater remediation because it has migrated the greatest distance in the
shallow, intermediate and deep zones and the plume extends downgradient under residences. Figures
showing the extent of the groundwater impacts are included in Appendix A.
The facility operated as early as 1939, so groundwater could have been contaminated as long ago as 64
years. The plume transport distance is approximately 6,000 feet for 1,2-DCA, which is a conservative
VOC constituent because it does not strongly sorb to aquifer material and therefore is transported at
velocity close to that of groundwater. Groundwater flow velocities of 70 to 150 ft/yr (presented earlier for
pre-remedy conditions) are consistent with a plume 6,000 feet long that developed from sources starting
as early as 1939.
2.4.6 Surface Water Contamination
The closest surface water bodies are a 15-acre playa basin and associated sludge pits on the western
portion of the site. Surface water generally flows along natural drainage channels from the perimeter of
the former refinery property toward the 15-acre playa. Surface water discharges to the surrounding
environment are not indicated by the off-site drainage patterns. The nearest stream is Yellow House
Draw, which is located approximately 7.5 miles northwest.
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3.0
DESCRIPTION OF PLANNED OR EXISTING REMEDIES
3.1 Existing Remedies
The purpose of the groundwater extraction and treatment system and the SVE system is to address
groundwater and soil contamination by reducing LNAPL and organic vapor in the source area and
providing hydraulic containment of the plume. Institutional controls (IC) are intended to prevent exposure
of potential receptors to contaminants. The ultimate objective for the remedial systems is to restore the
Ogallala aquifer to its beneficial use as a drinking water supply. The remedial systems consist of
groundwater extraction wells, an oil/water separator, a coagulation/filtration process, air strippers,
groundwater re-injection wells, soil vapor extraction wells, C3 technology, and granular activated carbon
(GAC) to treat off-gases from the air strippers and soil vapor extraction system.
The C3 systems, manufactured by GEO, combine cryogenic-cooling and compression processes with
regenerative adsorption to recover VOCs from a vapor stream as a non-aqueous phase liquid (NAPL).
The C3 system equipment includes a series of air/air heat exchangers and refrigerated heat exchangers,
automatic drains and a proprietary regenerative adsorber, as well as electrical service panels, gauges, and
control systems, housed in enclosed trailers. The C3 system equipment lowers the temperature of the
vapors to approximately -45ฐF, resulting in condensation of the contaminants in the vapors into a NAPL
product. The NAPL is temporarily stored in in two 6,500-gallon fiberglass reinforced plastic tanks (same
as those used for the oil/water separator that treats extracted groundwater from on-site wells) for periodic
removal to a licensed fuel recycler or re-blender. Effluent vapors from the C3 system are then conveyed
to vapor GAC vessels (two 5,000-pound vessels in series) for final polishing and discharge to the
atmosphere.
The process configuration is shown in the Process Flow Schematic included in Appendix A. The C3
technology is implemented with five separate units, as follows:
One unit (C3 System 21) is for treatment of off-gas from the air strippers associated with
groundwater treatment, after those vapors are concentrated by a Munters zeolite wheel.
One unit (C3 System 22) is for treatment of vapors from the shallow SVE system.
Three units (C3 Systems 23 A, 23B, and 23C) are for treatment of vapors from the deep SVE
system.
The following sections describe the components of the remedial systems and operations in more detail.
3.1.1 Groundwater Extraction
The groundwater extraction network consists of 11 on-site wells and 10 off-site wells. Of these 21
extraction wells, 14 are shallow extraction wells (bottom of screen interval from 158 to 164 feet bgs), four
are intermediate extraction wells (bottom of screen interval from 185 to 200.5 feet bgs), and three are
deep extraction wells (bottom of screen interval from 205 to 210 feet bgs). The intermediate and deep
extraction wells have long screens that include a portion of the screen in the shallow zone. (Top of screen
is typically on the order of 150 feet bgs for the intermediate and deep extraction wells.)
10
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The 11 on-site wells were located for source containment and mass recovery, whereas the 10 off-site
wells were located between 800 and 2,000 feet northeast of the site to contain the leading edge of the
groundwater plume. All extraction wells are equipped with electric submersible pumps, vaults, downhole
pressure transducers, pressure gauges, valves, magnetic flow meters, totalizers, control panels with
Supervisory Control and Data Acquisition (SCADA) controls, and radios to transmit water level data,
operating pressure, instantaneous and totalized flow data to the control station in the treatment building.
Total system extraction design flow rate was anticipated to be 281 gallons per minute (gpm) with 66 gpm
from the shallow on-site wells and 215 gpm from the off-site wells, but the actual groundwater extraction
rate has been close to 200 gpm total as a result of fouling issues in the shallow on-site wells and the three
shallow off-site wells.
3.1.2 Groundwater Treatment
3.1.2.1. LNAPL Removal
Groundwater from on-site extraction wells flows to an oil/water separator, which recovers LNAPL from
the influent water. The recovered LNAPL is stored in two 6,500-gallon fiberglass-reinforced plastic tanks
located outside the treatment building for periodic removal to a licensed fuel blender. Water from the
oil/water separator is combined with water from the off-site wells in a 12,500-gallon equalization tank
(Tank T-l) and is then directed for treatment.
3.1.2.2. Metal Coagulation andpH Adjustment
Groundwater is treated for the removal of metals (arsenic and manganese) using (1) a coagulation process
by chemical addition, followed by (2) flocculent removal in two parallel filtration vessels using
adsorptive media filters, and subsequently (3) pH adjustment. The treated water is then directed to the air
strippers for removal of benzene and 1,2-DCA.
Chemicals used for the coagulation of metals and pH adjustment include sodium hypochlorite and sulfuric
acid (replaced in September 2013 by carbon dioxide [C02]). A 12.5 percent sodium hypochlorite solution
is used to oxidize arsenic, iron, and manganese in the influent groundwater. Sulfuric acid (recently
replaced by C02) is added to lower the pH of the water after air stripping. Sodium hydroxide would be
used if necessary (it has not been needed) to adjust the pH of the water entering the air strippers for
organics removal. All chemicals are metered using automated control systems.
3.1.2.3. Filtration
The flocculent is removed in two parallel filtration vessels using an adsorptive media filter. The two
flocculent filtration vessels are backwashed with water from the system effluent tank (Tank T-4)
approximately every 8 hours using a 4-minute backwash cycle. The resulting backwash water is
transferred to a 20,000-gallon reclamation tank (Tank T-3) for settling. The minimal waste sludge volume
is collected and managed as nonhazardous solid waste, and a sump pump returns the remaining water
back to the equalization tank (Tank T-l).
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3.1.2.4.
Organics Removal via Air Stripping
Groundwater from the metals treatment is split into two streams and an anti-scaling chemical is injected
into each stream before flow enters two low-profile seven-tray strippers to remove benzene, 1,2-DCA,
and other organic constituents. Off-gases from the air strippers are routed to a Munters zeolite wheel
concentrator. The zeolite wheel concentrator is located on a covered reinforced-concrete slab located
adjacent to the treatment plant building. The unit is designed to handle 2,600 to 7,000 standard cubic feet
per minute (scfm) of VOC-laden air and uses a corrugated mineral fiber substrate permanently bonded
with a proprietary mix of hydrophobic zeolite and other inorganic compounds to adsorb VOCs from the
air stream. The concentrated vapors from the zeolite wheel are sent to one of the cryogenic-cooling and
compression units (C3 System 21). Any other vapors from the zeolite wheel are discharged to the
atmosphere.
3.1.2.5. BagFilters and Reinjection of Treated Groundwater
Treated groundwater from the air strippers is directed to a 10,000-gallon effluent storage tank, pumped
through bag filters (four vessels, 25 microns), and then pumped through a high-density polyethylene
(HDPE) line to eight injection wells for re-injection into the full thickness of the aquifer. The eight
injection wells are located approximately 2,000 feet due north from the on-site extraction wells. Initially,
there were four injection wells (as indicated on the process schematic in Appendix A), but as a result of
flow limitations an additional injection well was added adjacent to each of the original injection wells in
late 2010. It was explained during the optimization review site visit that the new injection wells share
panels with the original injection wells in the SCADA system, and as a result the individual flow rates for
injection wells are not reported by the SCADA system. Excess water not re-injected is discharged to the
playa, an on-site impoundment west of the treatment plant that functions as a recharge basin.
SVE wells were installed to remove VOCs from the vadose zone and reduce LNAPL extent in the source
zone beneath the former refinery property. The SVE wells operate in conjunction with the on-site
groundwater extraction well network, which in concept lowers the water table and increases the effective
interval for vapor collection (which may be offset at this site by recharge of treated water).
The SVE well network consists of 62 shallow well/deep well pairs (for a total of 124 SVE wells). The
shallow wells are screened from 70 to 90 feet bgs and the deeper wells are screened from 110 to 140 feet
bgs. Vacuum is applied to the SVE wells to extract soil vapor and direct it to the SVE manifold located
within the treatment plant building. The SVE manifold is composed of 12 deep-zone vapor conveyance
circuits and 12 shallow-zone vapor conveyance circuits, for a total of 24 connection points. As designed,
the SVE treatment system will treat up to 1,250 scfm from the deep zone and 417 scfm from the shallow
zone.
3.1.3.2. Soil Vapor Treatment
Soil vapors from the shallow and deep circuits are treated in separate, parallel treatment trains consisting
of knockout tanks to remove entrained moisture, followed by the C3 system (C3 System 22 for the
shallow SVE wells and C3 Systems 23 A/B/C for the deep SVE wells) and then vapor GAC for off-gas
treatment. Condensate from the knockout tanks is transferred to the groundwater treatment system.
Effluent vapors from the knockout tanks are compressed with air compressors, then stored in a receiver
vessel, and then passed through a heat exchanger to lower the temperature to near-ambient temperatures.
3.1.3
Soil Vapor Extraction and Treatment
3.1.3.1.
Soil Vapor Extraction
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After the heat exchanger, the vapors are transferred to the C3 system and subsequently to the GAC
vessels for final polishing before discharge to the atmosphere.
3.2 Remedial Action Objectives and Standards
The March 2008 ROD identifies the following remedial action objectives (RAOs) for groundwater at the
site. (The numerical criteria used to measure progress toward meeting the groundwater RAOs are
presented in Section 3.4.)
Prevent human exposure to the contaminated groundwater above acceptable risk levels within the
organic contaminant plume;
Prevent or minimize further migration of the organic contaminant plume exceeding the remedial
goals (plume containment);
Prevent or minimize further migration of contaminants from source materials (such as LNAPL) to
groundwater (source control); and,
Return groundwater within the organic contaminant plume to its expected beneficial uses
wherever practicable (aquifer restoration).
The RAO for soil at the site is:
Prevent exposure of ecological receptors to COCs above acceptable limits in the AOC 1
abandoned drum hot spot; specifically the remedial goals for soil are 61 mg/kg for copper and
120 mg/kg for zinc.
3.3 Monitoring Programs
3.3.1 Treatment Process Monitoring
The process monitoring program consists of process water and process air sampling, as follows:
The process water sampling includes system influent and system effluent. Samples are collected
twice per month and are analyzed for VOCs and metals.
The process air sampling includes influent from the shallow SVE network, influent from the deep
SVE network, influent to the vapor GAC (that is, combined sample from after the C3 systems),
and effluent from the vapor GAC. Samples are collected twice per month and are analyzed for
total volatile hydrocarbons (TVHC) and VOCs.
Process monitoring samples are analyzed by Trace Analysis, Inc., in Lubbock, Texas.
3.3.2 Long-Term Monitoring (LTM) for Groundwater
Groundwater monitoring is performed at different types of wells on a somewhat irregular basis. Table 3
summarizes the different types of sampling locations, and the number of sampling locations in the three
recent events described in the Annual Report for September 2011-August 2012. It was stated during the
optimization review site visit that the conceptual plan is to sample three times per year, but funding has
limited the sampling to two or three events per year.
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Table 3: Number of Long-Term Monitoring Locations (Three Recent Events)
Tvpe
December 2011
Miiv 2012
August 2012
Monitoring Wells
46 total PDBs
at 39 locations
(VOCs only)
Low flow sampling at 38
locations
(VOCs and total metals)
3 PDBs
(VOCs only)
47 total PDBs
at 39 locations
(VOCs only)
Extraction Wells
15 operating EWs
(VOCs only)
19 operating EWs
(VOCs and total metals)
19 operating EWs
(VOCs and total metals)
Private Water Supply
Wells
2 wells from tap,
pre-filtration
(VOCs only)
22 wells from tap
(VOCs and total metals)
+
2 wells from tap,
pre- and post- filtration
(VOCs only)
2 wells from tap,
pre- and post- filtration
(VOCs and total metals)
Injection Wells
micropurge sampling at 3
wells
(total metals only)
EWs = Extraction Wells PDB = Passive Diffusion Bag VOCs = Volatile Organic Compounds
The routine groundwater monitoring samples are analyzed at an EPA-approved Contract Laboratory
Program (CLP) laboratory currently at no cost to the project. However, in the future when the
groundwater treatment system transfers to the state, laboratory costs will be incurred; therefore,
equivalent commercial laboratory costs are estimated in Section 5.2.
The Annual Report for September 2011-August 2012 indicates that the May 2012 event also included
non-routine sampling for general chemistry analysis and compound-specific isotope analysis (CSIA), as
follows:
Groundwater samples for general chemistry analyses from 20 extraction wells and three injection
wells
Groundwater samples for CSIA from 11 monitoring wells and five extraction wells.
Groundwater samples for the general chemistry analysis were collected to better evaluate water quality
and aquifer conditions that may be altering the performance of the injection well and extraction well
pumps. General chemistry parameters included alkalinity, sulfate, hardness, total dissolved solids (TDS),
and total suspended solids (TSS), and these samples were analyzed at Trace Analysis, Inc., in Lubbock,
Texas. CSIA samples were collected from 16 wells transecting the 1,2-DCA plume to evaluate the
degradation of 1,2-DCA in the shallow water-bearing zone and were analyzed by Isotope Tracer
Technologies, Inc., in Waterloo, Ontario, Canada, to perform carbon compound-specific stable isotope
ratio measurements for 1,2-DCA in groundwater.
3.4 Air and Water Discharge Standards
Treatment system influent and relevant discharge limits are included in Table 4 (water) and Table 5 (air)
for selected parameters that have influent concentrations that typically exceed the discharge limit and
therefore require treatment. (Note that arsenic influent concentration for groundwater has only
sporadically exceeded the discharge limit.) System operation consistently meets the discharge limits.
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Table 4: Water Discharge Limits for
Selected COCs
I'.ir.iiiii'iiT
\ii*ปiinI 24. 2012 1 n 11 iii-iii
l)iM-|i.iri!i' 1 i in 11
1,2-Dichloroethane (1,2-DCA)
57.8 fig/L
5 ng/L1
Benzene
1,040 fig/L
5 ng/L1
Arsenic
<10 fig/L
10 fig/L1
Iron
360 fig/L
300 ng/L2
Manganese
1420 fig/L
1,100 iig/V
1 Maximum Contaminant Level (MCL)
2 Secondary MCL (not a discharge criterion)
3 TCEQ protective concentration limit (PCL) for residential drinking water
Table 5: Air Discharge Limits
I'.ir.iiiii'iiT
\ii*ปiinI 24. 2012 Inlliu ni
1 iinii
Benzene
7.9 lbs/hr
0.056 lbs/hr
Total Volatile Hydrocarbon
(TVHC)
389 lbs/hr3
1.0 lbs/hr
lbs/hr - pounds per hour
1 Discharge criteria for benzene are based on 30 Texas Administrative Code (TAC) 106.262 and TVHC is based on 30 TAC
106.533.
2 Calculation of influent air in lbs/hr assumes 1,200 standard cubic feet per minute (scfrn) of soil vapor extraction (SVE)
flow from deep wells, 400 scfrn from shallow wells, and 400 scfrn from air stripper concentrate, and used influent results
in milligrams per cubic meter (mg/m3) for the shallow and deep SVE systems (Table 2 of Annual Report for September
2011-August 2012). For groundwater, influent mass flux is based on the mass per month calculated to be removed by the
air stripper (Table 5 of Annual Report for September 2011-August 2012).
3 Typical influent mass is about 80 lbs/hr based on reported 7,000 gallons/month light non-aqueous phase liquid (LNAPL)
recovery.
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4.0 CONCEPTUAL SITE MODEL
The optimization review focused on current groundwater and soil vapor collection and treatment
operations. CSM components key to these operations include the contaminant distribution and plume
migration velocity that were discussed in Section 2.4. The optimization review team believes the presence
of LNAPL over a large area, and the large extent of dissolved groundwater impacts, suggest that
groundwater will be contaminated at this site for a very long time. Therefore, primary emphasis should be
on controlling migration of the most contaminated groundwater to make sure the groundwater plume is
not expanding and keeping annual costs as low as possible given the expected longevity of the remedy.
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5.0 FINDINGS
The observations provided below are the interpretations of the optimization review team and are not
intended to imply a deficiency in the work of the system designers, system operators, or site managers;
rather, they are offered as constructive suggestions in the best interest of the EPA and the public. These
observations have the benefit of being formulated based on operational data not available to the original
designers. Furthermore, it is likely that site conditions and general knowledge of treatment have changed
over time.
5.1 General Findings
5.1.1 Groundwater Pumping, Groundwater Flow, and Plume Capture
Eleven of the extraction wells (EW-11 to EW-21) are on-site wells that are pumped primarily for mass
removal of VOCs in the shallow zone source area. The on-site extraction wells have well screen lengths
of 15 to 20 feet and were designed to pump approximately 6 gpm each, for a total on-site design
extraction rate of 66 gpm. However, these wells actually pump at much lower rates than the design rate
(typically 20 gpm or less in total) and also remove only a small volume of LNAPL each year (less than
100 gallons per year). These wells extract groundwater with high dissolved concentrations of 1,2-DCA
and benzene. The 1,2-DCA concentrations typically exceed 100 micrograms per liter (|ig/L) and in some
cases 500 |ig/L, and the benzene concentrations typically exceed 5,000 jig/L and in some cases 20,000
jig/L. The on-site well pumps are plagued with fouling problems because of the high levels of TDS in the
upper unit; the current practice is to replace pump ends approximately three times per year. The site team
is planning to stop on-site groundwater pumping, which will reduce well maintenance costs significantly.
The remaining 10 extraction wells are located off site and were designed to extract a total of 215 gpm.
These 10 off-site extraction wells include the following:
Three of the off-site extraction wells (EW-5, EW-6, and EW-7) are shallow zone wells with 15-
foot screen intervals and are located just north of SR 114 and approximately 1,200 feet east of the
closest on-site extraction well (EW-11). These wells were intended to intercept the shallow plume
in the vicinity of these wells, where concentrations are relatively high, so that portions of the
aquifer that are deeper or further downgradient would clean up over time. These wells were
designed to pump 10 gpm each (30 gpm total) but actually only pump several gpm each or less.
Similar to the on-site extraction wells, the 1,2-DCA concentrations typically exceed 100 jig/L at
EW-5 to EW-7 and in some cases 500 |ig/L, and the benzene concentrations typically exceed
5,000 fig/L at EW-5 to EW-7.
Four of the off-site extraction wells (EW-4, EW-8, EW-9, and EW-10) are intermediate zone
wells with 40-foot screen intervals.
o EW-8, EW-9 and EW-10 are located north of EW-5 to EW-7, and were designed to pump
at 25 gpm each. When operating, EW-8 and EW-9 achieve a rate on the order of 15 to 25
gpm, but EW-10 achieves lower rates (generally less than 15 gpm). These intermediate
zone wells have much lower V OC concentrations than the shallow extraction wells to the
west (on site) or to the south (off site). The 1,2-DCA concentrations at EW-9 and EW-10
are typically less than 50 |ig/L, and benzene concentrations are generally below the
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Maximum Contaminant Level (MCL) of 5 jig/L. The 1,2-DCA concentrations at EW-8
have been increasing from generally less than 50 jig/L in 2009 and 2010 to 72 jig/L in
May 2012 to 110 jig/L in August 2012. Similarly, the benzene concentrations at EW-8
have been increasing from "non-detect" in 2009 and 2010 to 40 jig/L and 27 jig/L in
2011 to 200 jig/L and 870 jig/L in 2012. This increasing trend could indicate the plume is
being pulled down by relatively deep extraction at this well and the three deep extraction
wells (EW-1 to EW-3).
EW-4 is located farther northeast than EW-9 and EW-10. EW-4 was designed to pump at
30 gpm, and it generally pumps when operational at 20 to 40 gpm. EW-4 has even lower
VOC concentrations than EW-9 and EW-10. The 1,2-DCA concentrations at EW-4 are
typically less than 10 |ig/L, and benzene concentrations are generally below the MCL of
5 |ig/L. Pumping from this well was stopped in 2013.
Three of the off-site extraction wells (EW-1, EW-2, and EW-3) are deep zone wells with 50- to
60-foot screen intervals located approximately 1,000 to 1,500 feet east of EW-5 to EW-10. These
wells were designed to pump 30 gpm each, and they generally achieve rates of 20 to 30 gpm or
higher. These wells have concentrations similar to intermediate zone wells EW-9 and EW-10 that
are located farther upgradient, with 1,2-DCA concentrations typically less than 50 jig/L and
benzene concentrations generally below the MCL of 5 jig/L.
The site team indicated that the plume is deeper east of EW-5 to EW-10 because a slight clay layer may
be absent to the east of those extraction wells, or because there are private irrigation wells with deeper
well screens to the east of those extraction wells. The intermediate and deep zone wells were intended to
provide containment of the leading edge of the plume, with the hope that other remedy items such as
SVE to remove mass and shallow extraction from farther upgradient to contain the highest concentrations
in groundwater would allow for the leading edge of the plume to clean up over time. This
downgradient portion of the plume is in an area of houses and irrigation, so it is preferable that the
downgradient portion of the plume be remediated as quickly as possible.
Monitoring wells to the east of extraction wells EW-5 to EW-10 are sparse as a result of access
limitations, and the downgradient extent of impacts is not fully delineated by site monitoring wells for
this reason. For instance, MW-30I is located downgradient of extraction well EW-3 (see Figure 2 in
Appendix A) and has slightly elevated concentrations of 1,2-DCA, typically on the order of 10 |ig/L. The
site monitoring wells are, however, augmented by sampling at private wells, which are also illustrated on
Figure 2 in Appendix A. The private wells located downgradient of the easternmost extraction wells
typically have VOC concentrations below standards, with the exception of well Smith-01, located
adjacent to MW-30I discussed above, which has slightly elevated concentrations of 1,2-DCA, typically on
the order of 15 jig/L. It cannot be stated with certainty if VOC impacts above standards extend much
farther east than MW-30I and Smith-01.
The Annual Report for September 2011-August 2012 documents changes in water levels that have
occurred since 2008. Water levels have increased on the former refinery property, presumably because of
recharge of treated water at the injection wells and the on-site impoundment located west of the treatment
plant building. Water levels have decreased off site to the east, which may result from a combination of
items that include drought, overdraft of water by private irrigation wells, and remedy pumping, which
extracts the highest rates from the intermediate and deep zone remedy extraction wells farthest east (EW-
1 to EW-4 and EW-8 to EW-10).
The target capture zone utilized in the modeling reports is the extent of the dissolved-phase plumes (based
on the remedial goal values) in the upper and lower aquifer units. Specific zones of capture are not easily
18
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interpreted from the potentiometric surface maps presented in the annual report, and the effectiveness of
the capture zone is based on the particle tracks provided by the groundwater model, using particles started
in the interior and the edge of the plumes. Groundwater modeling was updated in summer 2013 and
presented in Draft Groundwater Model Update (November 2013), which included the following:
Addition of a fourth model layer to represent the clay that separates the shallow zone from the
intermediate/deep zones at the site. (Where the clay is not assumed to be present, the properties of
the layer above and below are assigned for that model layer.)
Use of remedy extraction rates more consistent with observed rates, particularly at shallow
extraction wells.
Evaluation of scenarios where some or all of the shallow on-site extraction is eliminated.
Evaluation of scenarios that include different configurations for remedy pumping (and changes to
the injection rates based on changes to the total extraction rate), as follows:
o Scenario 1: On-site extraction wells EW-11 through EW-16 are shut off and EW-17
through EW-21pump 2 gpm. Off-site extraction wells EW-5 to EW-7 pump 2 gpm, EW-
8 to EW-10 pump 20 gpm, and EW-1 to EW-4 pump 30 gpm. Total extraction is 196
gpm.
o Scenario 2: All on-site shallow extraction wells are eliminated. Off-site extraction wells
EW-5 to EW-7 pump 2 gpm, three additional shallow wells near EW-5 to EW-7 are also
added at 2 gpm, EW-8 to EW-10 pump 20 gpm, EW-1 to EW-3 pump 30 gpm, and EW-4
is eliminated. Total extraction is 162 gpm.
o Scenario 3\ All on-site shallow extraction wells are eliminated. Off-site extraction wells
EW-5 to EW-7 are replaced by EW-5R to EW-7R with longer wells screens and assumed
to pump 25 gpm each, EW-8 to EW-9 pump 20 gpm, EW-10 is reduced to 10 gpm, EW-2
to EW-3 pump 30 gpm, and both EW-1 and EW-4 are eliminated. Total extraction is 185
gpm.
The modeling presented in the November 2013 Draft Groundwater Model Update suggests that Scenario
3 provides adequate capture with similar extraction rates to the current system (less than 200 gpm) and
also avoids shallow pumping, which is problematic with respect to well fouling. The modeling predicts
that extraction wells with deeper screens will provide adequate capture for contaminants in the shallow
zone and suggests the shallow zone in the eastern portion of the plume will dewater over time (such that it
does not make sense to keep existing shallow wells EW-5 to EW-7 in addition to the suggested
replacement wells).
The modeling indicates that a significant amount of treated water is recaptured, which increases the
extraction rate required for capture. This recapture makes it difficult to use a simple calculation to
estimate the extraction rate required for capture, and use of a numerical model for evaluating capture is
more appropriate given that a lot of the treated water is recaptured. Although the model simulations
account for the recapture of treated water, the modeling presented in the report does not illustrate the
difference in capture that might result if treated water was not recharged. (The model has not been used to
illustrate how much less extraction might be required to achieve similar capture if in absence of treated
water being recharged.)
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5.1.2
Groundwater Treatment
The groundwater treatment system is effective at removing metals and VOCs. There have been fouling
problems in the reinjection wells related to barium sulfate. The injection wells require maintenance and
have required rehabilitation at a frequency of approximately once per year. The site team began testing
C02 instead of sulfuric acid in September 2013 for adjusting pH down after air stripping to see if the
fouling is alleviated. About 75 percent of the system discharge is currently reinjected to the eight
reinjection wells and the other 25 percent is discharged to the on-site impoundment west of the treatment
system. The site team prefers to not discharge to the on-site impoundment and hopes to optimize
extraction and injection so that recharge to the impoundment is no longer needed. The site team has met
with the City of Levelland to review the option of providing the treated water to the city as a further
means to supplement its existing water supply, potentially which would mitigate the issue of recharge to
the impoundment.
The air stripper off-gas is concentrated with the zeolite wheel and then directed to one of the C3 units to
recover product. This C3 system includes a 150-horsepower compressor. The air stripper off-gas is very
dilute, so the unit cost to recover product is extremely high. The site team has been considering treating
the off-gas with vapor GAC instead of the C3 system.
With the current flow of less than 200 gpm and future flow likely less than 200 gpm (per Scenario 3 of
the modeling described above, which has total extraction rate of 185 gpm), it is possible that one stripper
could be taken off-line. The site team reports that the stripper effluent pumps might have to be replaced to
allow the stripper to be taken offline.
Chemical use in the groundwater treatment system includes about 13 gallons per day (gpd) of 12.5
percent sodium hypochlorite and about 18 gpd of 93 percent sulfuric acid. As stated above, the sulfuric
acid was replaced by carbon dioxide in September 2013 (onel80-liter size C02 bottle every 2.5 days).
The sand filter backwashes (4-minute cycle) occur every 8 hours automatically. Sludge disposal has been
only one truck of wet sludge in 4 years. Decant water is bled back into the system influent.
Although the current system meets effluent standards, the groundwater system operates at a very high cost
and energy usage (mainly because of the C3 system that treats air-stripper off-gas). There are likely
alternative treatment approaches for the air stripper off-gas that would require significantly less cost and
energy usage. These options are discussed in subsequent sections of this report.
5.1.3 Soil Vapor Extraction
The SVE system includes 62 well pairs in the defined LNAPL area. The initial plan was for 6 years of
SVE operation, and currently the SVE operation is in year four. The primary mass removal is currently
from the deep SVE, which is resulting in removal of nearly 7,000 gallons of VOCs per month. The
combined concentration from the shallow SVE system is generally less than 100 milligrams per cubic
meter (mg/m3) of benzene and less than 7,000 mg/m3 of TVHC, whereas the combined concentration
from the deep SVE system is generally more than 1,000 mg/m3 of benzene and more than 70,000 mg/m3
of TVHC (10 times higher concentrations in the deep zone). The concentrations in the shallow wells have
decreased and the site team is planning to operate only the deep SVE wells in the future. The site team
indicated that the state pays 10 percent of the SVE system cost, but the total cost of the SVE system
would not be turned over to the state (TCEQ) after 10 years (unlike operation of the groundwater
extraction and treatment system). Some deep SVE wells have also been shut down based on an informal
criterion of approximately 100 parts per million by volume (ppmv) total VOC shutdown level. Additional
SVE wells are being considered on the west and northeast sides of the SVE network.
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Four of the five C3 units are for the SVE system. One is for the shallow SVE system, and three are for the
deep SVE system. The C3 system is run on a fixed fee per month contract plus electricity. These units are
not concentration dependent, but they require high power use. The site team has considered purchasing a
generator or fuel cell to convert the recovered product to electricity for use on site or sale to the local
utility company. While this idea could slightly improve long-term operation and maintenance (O&M)
costs, the capital costs would be high and could be avoided altogether if a better alternative to the C3
systems was implemented (discussed in subsequent sections of the report).
5.1.4 Groundwater Monitoring
The current monitoring plan includes on-site and off-site wells sampled at somewhat irregular intervals,
with at least two events per year. There is a mixture of sampling techniques at monitoring wells, such as
passive diffusion bags (PDBs) in some events (for VOCs only) and annual low flow sampling events (for
VOCs and total metals). The site team indicated it plans to use PDBs in the future. Although some metals
are constituents of concern at the site, elevated metals (manganese, iron, and arsenic) are all likely caused
by reducing conditions caused by the VOCs. Continuing laboratory analysis of metals in monitoring well
samples on an annual basis does not appear to be critical for site cleanup, and analysis for metals could be
reduced in frequency to every 5 years. Thus, use of PDBs for monitoring of VOCs only in monitoring
wells may therefore be practical. When analyses for metals are required (perhaps infrequently as
suggested above), samples could be collected with low flow sampling or with alternative techniques that
can include metals. Total metals could still be sampled for analysis at residences and extraction wells at
any frequency desired, since those locations are not sampled with PDBs.
It was stated during the optimization review site visit that there are access restrictions that prohibit
additional monitoring in some areas. For instance, the site team indicated that additional monitoring
between extraction wells EW-1 to EW-3 is not likely to be feasible because of access restrictions. These
restrictions could hamper the ability to further delineate the plume extent to the east and to add sentinel
monitoring wells (rather than relying on private wells).
5.1.5 Institutional Controls (ICs)
The remedy defined in the ROD includes ICs. The Annual Report for September 2011-August 2012
indicates the following with respect to ICs:
"In order to protect human health and prevent future groundwater use from the shallow aquifer
on site, EPA will implement institutional controls at the site. This will consist of a Consent
Decree with the current landowner that will include a restriction on the installation of wells for
withdrawing water from the shallow aquifer. The Consent Decree will also require the landowner
to execute and record an easement running with the land that will grant right-of access for
activities related to implementing the remedy. A restrictive covenant will be used to restrict future
property use at the former refinery to non-residential uses, and thus eliminate the potential for
indoor vapor issues in a future residential use scenario. The restrictive covenant may also impose
restrictions on unauthorized drilling, excavating, digging, trenching, or any other activities that
might otherwise expose contaminated soil, which may result in potentially unacceptable risks to
receptors. A deed notification for the site will be filed with the appropriate land records office.
The deed notification will state that the property is located within a Superfund site, identify the
types of contaminants present, and describe activities that should not be conducted at the site.
During the performance of routine groundwater monitoring activities at the site, a site evaluation
will be conducted to verify that contaminated groundwater is not being used."
During the optimization review site visit, it was stated that ICs still need to be finalized, and some unit
costs for those efforts were provided by the site team (discussed in Section 6.1.2).
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5.1.6
Suggestions by Site Team for Potential System Modifications
The site team has put forth suggestions for system improvements in the Annual Report for September
2011-August 2012 as well as during the optimization review site visit. Some of these suggestions by the
site team have previously been noted in this optimization review report, but a brief listing of some of
these suggestions by the site team is provided below.
Reduce number of C3 units from five to three and eliminate the zeolite wheel concentrator. This
action would be accomplished by eliminating shallow SVE (eliminates one C3 system) and by
treating the air stripper off-gas with vapor GAC (which eliminates the zeolite wheel concentrator
and another C3 unit). Air stripper off-gas is currently concentrated by the Munters zeolite wheel
concentrator and treated in the C3 unit. This approach is extremely inefficient for the low mass
(2.4 pounds/day benzene) in the vapor stream. A booster blower (or reconfiguration of the air
stripper to suction blower) would likely be needed to run the off-gas from the stripper to the
vapor GAC. The site team is already working on this change. In addition to cost savings, this
change would likely decrease system downtime substantially because the zeolite wheel
concentrator has had many maintenance issues.
Consider reducing the number of air strippers from two to one if the extraction flow rate can be
reduced.
Use C02 in place of sulfuric acid for lowering pH in the treatment process, to reduce fouling at
the injection wells (implemented in September 2013).
Assuming three on-site C3 units remain, purchase a generator or fuel cell to produce on-site
energy from the recovered product and use the resulting electricity on site or sell the electricity to
the grid.
Drill replacement wells EW-5R to EW-7R near existing shallow zone extraction wells EW-5 to
EW-7, with long well screens, to improve extraction rates in this critical area and eliminate some
of the well fouling issues observed at EW-5 to EW-7.
Potentially add a new extraction well (shallow/intermediate) between EW-1 and EW-2.
Consider additional injection wells.
Recommendations by the optimization review team are provided in Section 6 of this optimization review
report and differ somewhat from the suggestions by the site team.
5.2 Components or Processes That Account for Majority of Annual
Costs
Ongoing annual costs for this remedy are approximately $3.2 million per year. Table 6 provides a
breakdown of the approximate annual cost estimates for operating this remedy based on total costs
provided by the site team and general averaging by the optimization review team.
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Table 6: Summary of Annual Operating Costs
Ill-Ill
\llllll.ll ( itsl
Plant Operator
One full-time employee + 15 hrs/week overtime +
truck + approx. 20 hrs/month additional support
$286,000
Project Management/Tech
Support/Reporting
$305,000
Groundwater Monitoring
Based on two passive diffusion bag (PDB) events and 1
low-flow event in a year
$139,000
Groundwater Analysis
Equivalent
CLP- no cost to site; approximately 240 VOCs and 80
total metals, plus QA/QC samples
$40,000*
Process Sampling
Four water samples and eight air samples per month
$24,000
Well/Pump Rehab
To be reduced in future if on-site extraction wells are
eliminated
$122,000
Chemicals
Antiscale and filtration
$71,000
Supplies
Includes $4,000 for bag filters and $5,000 for stripper
intake filters
$57,000
Granular Activated Carbon
None spent in FY13
$4,000
Sludge Disposal
None spent in FY13
$1,000
Electric
Approximately 509 kilowatt (kW) connected or
4,500,000 kWh/yr
$308,000
C3 System Lease
Includes on-site O&M
$1,883,000
Additional Maintenance (not C3)
Electrical contractor, PLC support, metals filtration
O&M support,
$33,000
Misc. Utilities/Service
Phone/Internet/Trash
$5,000
Fuel Recovery
Credit
($55,000)
TOTAL
S3.2MM
*No current lab costs incurred by site, but that will change after transfer to the state, so a rough estimate is
provided for approximate annual costs for an off-site lab (not including special sampling events)
A more detailed discussion of specific cost items is presented below.
5.2.1 Labor and Truck
The site team reports combined operating labor and management (including reporting) requirements of
approximately 55 hours per week, plus additional support of approximately 20 hours per month. The
truck costs are likely on the order of $1,000 per month. It is possible the labor costs could be reduced if
the system were simplified in the future such that there is less fouling and fewer systems to operate (no
zeolite wheel and no C3 systems).
5.2.2 Groundwater Sampling
The combined $139,000 sampling cost for approximately 240 sample locations translates to a unit cost of
approximately $580 per well for sampling. This amount is high in comparison with other sites, and may
be a result of the remoteness of the site.
5.2.3 Chemical Costs
Total chemical costs are $71,000 per year and include sodium hypochlorite, anti-scale and defoaming
agents, and either sulfuric acid or C02. Supplies total about $57,000 per year, and include approximately
$9,000 for bag filters and air stripper blower intake filters; it is unclear what supplies account for the
remaining $48,000 per year.
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5.2.4 Utilities
Electrical power cost in the cost summary provided to the optimization review team for September 2012
to August 2013 was approximately $308,000 (used in Table 6), and for September 2011 to August 2012
was approximately $312,000. A summary of electricity use provided to the optimization review team
indicated metered electrical use for the period September 2011 to August 2012 was approximately
4,500,000 kilowatt hours (kWh) and also indicated the average unit cost was approximately $0.057/kWh.
Dividing the reported cost of $312,000 for that period by the metered use of 4,500,000 kWh would
actually indicate a unit cost of $0.069/kWh, which is slightly higher than the unit cost included in the
utility summary provided. The difference may be related to other electrical charges such as delivery or
markup of utility charges by the contractor. The optimization review team notes that these are extremely
high total energy costs for a groundwater remediation system. The site team noted during the optimization
review site visit that approximately 75 percent of the electrical cost is for the C3 systems. Some of these
utility costs are offset by the resale of the product recovered from the C3 systems (approximately $80,000
for the period September 2011 to August 2012, and approximately $55,000 for the period September
2012 to August 2013).
5.2.5 C3 System
In addition to the high energy costs that result from the C3 system (detailed above), the lease and
operation of the C3 system represent an extremely large cost of nearly $1.9 million per year. This amount
is by far the highest component cost of the remedy. Use of an alternative approach to treat vapors
therefore offers the greatest cost savings potential for this remedy.
5.3 Approximate Environmental Footprint Associated with Remedy
The following subsections describe the environmental footprint of the site remedy, considering the five
core elements of green remediation defined by the EPA (www.cluin.org/greenremediation).
5.3.1 Energy, Air Emissions, and Greenhouse Gases
The EPA Spreadsheets for Environmental Footprint Analysis (SEFA) were used to estimate the energy
and air footprints. A summary of the SEFA inputs is presented in Appendix C, and the SEFA files are
included as an electronic attachment.
XCel Energy is the electricity provider for the site, and based on a preliminary review of Xcel Energy's
2012 Annual Report, approximately 35 percent of the electricity is generated from coal, 29 percent from
nuclear plants, 13 percent from natural gas, 12 percent from wind sources, 7 percent from hydroelectric
plants, and 4 percent from other sources (solar, biomass, oil and waste). This mix for electricity
generation was used in SEFA. For materials, the sulfuric acid used to this point in the remedy was utilized
rather than the C02 that has recently replaced that material. The materials (sodium hypochlorite, sulfuric
acid, antiscalent and defoamer) are not explicitly represented in SEFA as options, so user-defined generic
emission footprint factors were assigned based on literature values for similar materials.
The results for key energy and air footprint metrics are summarized in Table 7.
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Table 7: Summary of Energy and Air Annual Footprint Results (/
nnual)
(ii i i n .mil Siisi.uii;il)li-
Ki'iiii'di.ilinn 1 iiii-l i-r
\ |>|>n i\i in ,ii I-
\iiiiu.il \ .iliu-
Greenhouse Gas Emissions (carbon dioxide equivalents [C02e]
2,710 tons
Total Nitrogen Oxides (NOx) + Sulfur Oxides (SOx) + Particulate Matter
(PM) emissions
49,232 pounds
Total Hazardous Air Pollutant (HAP) Emissions
1,175 pounds
Total Energy Use
56,906 MMBtu
Voluntary Renewable Energy Use
None on-site
Notes: CC>2e = carbon dioxide equivalents of global warming potential
MMBtu = 1,000,000 Btu
Based on the assumptions made in SEFA, approximately 96 percent of the global warming potential
(C02e) footprint is from electricity usage (electricity generation and related resource extraction and
transmission). The next largest contributors are materials production at 1.4 percent, laboratory analysis
items at 1.2 percent, and transportation of personnel and materials at 1 percent. Thus, electricity is the
main driver of the global warming footprint.
Because the C3 system recovers product, the optimization review team did a simplified analysis to
determine how much of the electricity use footprint is conceptually offset by productive use of the
recycled material (which is assumed to be for energy production). It is estimated that the C3 system uses
approximately 281,250 kWh per month, which is 75 percent of the total remedy electricity use of
4,500,000 kWh per year. The system recovers about 7,000 gallons of product/month. Using a 40 kWh per
gallon for energy value (typical for diesel) if the product could be burned for energy, at 70 percent
efficiency (typical maximum) at the site (no transportation energy, capital cost/energy use to provide
generator not included), it would generate 196,000 kWh per month. Thus, this conceptually would offset
196,000 / 281,250 = 70 percent of the electricity use footprint for the C3 portion of the remedy. However,
the remaining 30 percent of electricity use would still represent by far the highest contributor to the
footprint for the site, and based on these estimates the energy required by the C3 units is 144 percent of
the energy theoretically obtained from the recovered product. The high cost of operating the C3 units, in
addition to the high footprints from the electricity usage, is perhaps an even greater consideration.
5.3.2 Water Resources
The Annual Report for September 2011-August 2012 states the following:
"Ground water contamination has been documented in the shallow and deep zones of the
Ogallala aquifer, resulting in an impact of both private and public water supply wells. The
contaminant plume is 1.2 mi long and extends about 0.7 mi beyond the edge of the eastern
boundary of the former refinery. Supply wells in this area typically contain screen intervals that
span the entire saturated thickness of the Ogallala aquifer. Potential human receptors include
current and future onsite commercial/industrial worker and a potential future resident adult and
child. Potential exposure routes from ground water include ingestion, dermal contact, and
inhalation, primarily associated with exposure to the ground water plume."
The specific public water supply wells affected were not identified. The Annual Report for September
2011-August 2012 also discusses the following:
EA evaluated the provision of treated groundwater for non-potable use to nearby businesses with
water supply wells currently affected by the contaminant plume, which would allow for (1) the
reduction in surface discharge and lower the demand on the injection wells; and (2) removal of
the point-of-use filtration systems currently in place. The installation of treated water conveyance
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piping to these businesses is under consideration. These businesses include the Farmers Co-Op
(estimated 650 linear feet [If]) and T&B Services (estimated 700 If), which currently have point-
of-use filtration systems in place. Based on an initial evaluation, the provision of treated
groundwater may require installation of an additional water storage tank to ensure an
uninterrupted supply of water to each facility.
Per EPA direction, EA intends to extend the City of Levelland water line to a new residence
(estimated 100 linear feet, including a cased road bore) along Farm-to-Market 1490.
The Annual Report for September 2011-August 2012 also indicates that a private irrigation well north of
the extraction well network, near the downgradient extent of the plume, has been pumping since at least
2010 and could have some influence on the direction of groundwater flow.
5.3.3 Land and Ecosystems
Operation of the remedy does not appear to have secondary effects on local land and ecosystems.
5.3.4 Materials Usage and Waste Disposal
The primary chemicals and materials used are the anti-scale and filtration chemicals, bag filters, vapor
GAC, and air stripper blower intake filters. Sludge disposal has only been one truck of wet sludge in 4
years. GAC change-outs have also been minimal, with only one change of 10,000 pounds in 4 years (the
result of an upset in the C3 system).
5.4 Safety Record
The site team did not report any safety concerns or incidents.
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6.0 RECOMMENDATIONS
This section provides several recommendations related to remedy effectiveness, cost control and technical
improvement. Note that while the recommendations provide some details to consider during
implementation, the recommendations are not meant to replace other, more comprehensive, planning
documents such as work plans, sampling plans, and QAPPs.
Cost estimates provided in this section have levels of certainty comparable to those done for
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) feasibility studies
((-30 to +50 percent), and have been prepared in a manner generally consistent with EPA 540-R-00-002,
A Guide to Developing and Documenting Cost Estimates During the Feasibility Study, July, 2000. A
summary table of the recommendations with associated capital cost and changes in operating costs is
included as Table 8.
6.1 Recommendations to Improve Effectiveness
6.1.1 Add Sentinel Monitoring Wells If Access Allows
It does not appear that there are any sentinel monitoring wells, defined as clean wells located
downgradient of the plume. The 1,2-DCA plume extends to the farthest monitoring well in the
shallow/intermediate zone and the deep zone (MW-301 in the shallow/intermediate zone and EW-2 and
EW-3 in the deep zone). The use of private well sampling to augment site monitoring wells generally
suggests that high VOC concentrations have likely not spread far beyond the remedy extraction wells
located farthest east. However, it is likely appropriate to add up to two pairs (intermediate and deep) of
monitoring wells downgradient of the current monitoring and extraction well locations. The site team
indicated that there are substantial access issues for addition of monitoring wells, so no specific locations
are recommended herein. However, it is suggested that groundwater flow velocity be considered in
selecting the locations. Assuming the plume moves at velocity on the order of 150 ft/yr, these wells would
ideally be located on the order of 500 to 1,000 feet beyond the interpreted plume extent. That distance is
close enough that it would allow plume migration, if it is occurring, to be detected within approximately 5
to 10 years. If those wells are already contaminated when they are drilled, further plume delineation may
be merited. The optimization team assumes up to $100,000 may be needed to drill clusters of
intermediate/deep wells a two locations, including planning, drilling, surveying and addressing access.
The cost of sampling these new wells twice per year for VOCS, using PDBs, should be less than $1,000
per year when added to the other sampling already conducted.
6.1.2 Finalize Institutional Controls (ICs)
During the optimization review site visit, it was stated that ICs still need to be finalized. This effort is
especially important since there is the potential that the 1,2-DCA plume extent is not fully delineated in
the downgradient direction (see Section 6.2.1) and groundwater impacts are located beneath current and
potential future residents. A metes and bounds survey with a list of environmental conditions for each
affected parcel is required for ICs that are enforceable by the state. The site team's recent experience is
that the per parcel cost is between $4,000 and $8,000. The total number of parcels requiring ICs is not
known by the optimization team. The property owner must sign the restrictive covenant (RC) for the IC to
be an RC. If the property owner refuses to sign, the state will file a deed notice.
27
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6.1.3
Implement Changes to Extraction Strategy
As detailed in Section 5.1.1, the updated groundwater modeling recently performed by the site team
illustrates that equal or better capture can likely be achieved while eliminating extraction at the on-site
shallow wells that has been problematic as a result of persistent well fouling. The optimization team
agrees that switching to an extraction approach such as Scenario 3 evaluated with the update model and
described in Section 5.1.1 is preferred to the current extraction strategy. The optimization review team has
not attempted to quantify the costs of drilling and connecting the new extraction wells. There will be
savings in labor and project management that result from elimination of the problematic on-site extraction
wells, and these savings are discussed in other recommendations below.
A network of key monitoring wells located downgradient of the target capture zone should be identified,
and concentration trends at those wells should be regularly tracked, to confirm that capture is sufficient
over time under the new extraction rates. One type of well would be "performance monitoring wells,"
which are currently contaminated by VOC concentrations above standards, and those wells should clean
up over time if capture is sufficient. The other type of well would be the "sentinel wells" (see Section
6.1.1), which should initially have VOC concentrations below standards, and VOC concentrations should
remain below standards if capture is sufficient. The costs for this are already included in current
monitoring and reporting plus the costs estimated for recommendation 6.1.1.
6.2 Recommendations to Reduce Costs
6.2.1 Replace/Eliminate the C3 Systems
The five existing C3 systems are extremely expensive to lease and operate and should be replaced with
alternative approaches and eliminated as soon as possible. The optimization review team recommends the
following approach:
The shallow SVE system is already being considered for shutdown based on the low mass
relative to the deep SVE system. The site team has already suggested shutdown of the shallow
SVE system (which will eliminate one of the C3 units) and the optimization team agrees with that
suggestion.
The site team has already suggested that air stripper off-gas can be treated with vapor GAC,
eliminating the need for the Munters concentrator and one of the C3 units, and the optimization
team agrees with that suggestion.
Rather than using the remaining three C3 units for treatment of the deep SVE vapors, the
optimization review team recommends that those C3 units be replaced with a regenerative
thermal oxidizer, which can provide efficient performance at a wide range of influent
concentrations. A system for 1,500 scfm at 15,000 ppmv total VOCs would cost approximately
$300,000 (see Anguil quote in Appendix B) and installation would likely be under $150,000. The
system costs would include less than $500/month for electric, less than $l,500/month for
propane, and about $3,000/month for maintenance and outside labor to operate (assumes
conservatively a 1-day visit per month, and that the existing operator would handle daily checks
and routine maintenance).
Removing the five C3 systems as suggested above would pay for itself in 3 months, and savings
thereafter would be over $150,000/month for the C3 lease and support and energy (savings of
approximately $1.8 million per year). The regenerative thermal oxidizer is preferred over other thermal
oxidizer options because operating costs remain low as VOC mass recovery decreases over time.
28
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The optimization review team also compared the benefits of this recommendation with regard to
environmental footprints with the following simplified comparison:
Alternative 1 - Five C3 units using 3,375,000 kWh per year (which is 75 percent of the total
electricity use of 4,500,000 kWh per year estimated for the current remedy), plus 2,500 pounds
per year of vapor carbon for off-gas from the C3 units.
Alternative 2 - No shallow SVE, thermal oxidizer for the deep SVE system using 66,780 kWh
per year of electricity and 24,623 hundred cubic feet (ccf) of natural gas. The natural gas value
was used as a surrogate to represent both the fuel to be added to the thermal oxidizer (in this case,
propane) as well as the combustion of the site-related VOCs, such that the total British thermal
unit (Btu) of the thermal oxidizer (289,521 Btu per hour) is accounted for.
The SEFA results for Alternative 1 versus Alternative 2 include the following:
The global warming potential footprint for this aspect of the remedy is reduced from 1,969 tons in
Alternative 1 to 270 tons in Alternative 2 (86 percent reduction by eliminating the C3 units).
The total energy use for this aspect of the remedy is reduced from 41,726 million British thermal
units (MMBtu) in Alternative 1 to 3,639 MMBtus in Alternative 2 (91 percent reduction by
eliminating the C3 units).
The total nitrogen oxides (NOx), sulfur oxides (SOx), and particulate matter (PM) emissions
footprint for this aspect of the remedy is reduced from 35,965 pounds in Alternative 1 to 1,673
pounds in Alternative 2 (95 percent reduction by eliminating the C3 units).
No further offset for reuse of the recovered fuel in Alternative 1 is applied, since the thermal oxidizer in
Alternative 2 is already fully accounting for the emissions that occur for the extra combustion associated
with that alternative.
In summary, this recommendation provides extremely large reductions for both costs and environmental
footprints.
6.2.2 Reduce Plant Operator Level of Effort
The site team reports combined operating labor and management (including reporting) requirements of
approximately 55 hours per week, plus addition support of 15 to 20 hours per month. A system resulting
from the modifications suggested in recommendation 6.2.1 above should require less operator effort. The
suggested system has an added thermal oxidizer component but elimination of on-site extraction well
pumping, shallow SVE and time to coordinate operational changes created by C3 issues should result in a
net reduction of operator time. Although not quantified in detail, assume savings of at least 20 percent of
the operator costs listed in Table 6, or $57,200 per year, are possible.
6.2.3 Reduce Groundwater Monitoring
The site team is conducting a quantitative optimization evaluation of long-term monitoring including
application of the Monitoring and Remediation Optimization System (MAROS) software. The
optimization team recommends the following reductions in groundwater monitoring based on a
qualitative review:
29
-------
Significant water quality changes over time would not be expected inside the target capture zone
for groundwater. The optimization review team suggests that monitoring frequency be reduced to
annual (from the current two to three times per year) for wells inside the target capture zone. The
optimization team further suggests semi-annual frequency (twice per year) for "performance
monitoring wells" and "sentinel wells" located downgradient of the target capture zone. This
frequency applies only to monitoring wells and remedy extraction wells (including those that that
are no longer being pumped) but not residences where sampling effort from taps is minimal and
where residents may prefer more frequent sampling. Assuming recommendation 6.1.2 is
implemented, the target capture zone would be based on extraction only as far east as the
locations of EW-05 to EW-10.
As discussed in Section 5.1.4, although some of the COCs for the site are metals, there does not
appear to be a major technical need to sample for analysis of metals at individual monitoring
wells on an annual basis. Sampling for analysis of metals could still be conducted regularly for
operating extraction wells and residences, but perhaps only every 5 years at monitoring wells.
This schedule would allow all VOC sampling at monitoring wells to be conducted with PDBs
except for infrequent events where other sampling approaches could be employed.
Without a detailed inventory, it is assumed that the reduced sampling frequency suggested above for
monitoring wells and extraction wells (and sampling most residences once per year as was done in 2012)
would eliminate approximately half the samples relative to 2012 sampling described by Table 3 and Table
6, and therefore might save approximately half of the sampling costs listed in Table 6, or approximately
$70,000 per year. Not analyzing for metals at monitoring wells would have no direct impact on costs
under current use of the CLP laboratory, since the site does not pay for those costs from the CLP
laboratory, but would result in minor laboratory cost savings to the state in the future. Using PDBs only
for monitoring well sampling (since samples would not be analyzed for metals at those wells) would
eliminate the use of low-flow sampling subcontract support, which would yield some savings, but the
savings was not quantified by the optimization review team.
6.2.4 Reduce PM/Support/Reporting
Reporting for the site is very good but costs for project management/support and reporting are high, likely
in part as a result of the complexities added by the significant well fouling issues and the need to
coordinate with the contract and operation for the complex C3 systems. The optimization review team
assumes that a simpler system resulting from eliminating the on-site extraction wells as well as the
modifications suggested in recommendation 6.2.1 above to eliminate the C3 systems, plus the reduced
groundwater monitoring frequency suggested in recommendation 6.2.3, should require less project
management, support and reporting. Although not quantified in detail, it is estimated that savings of at
least 20 percent of the Project Management/Tech Support/Reporting listed in Table 6, or $61,000 per
year, are possible based on the professional judgment of the optimization review team.
6.2.5 Reduce Well Rehabilitation Costs
Assuming on-site extraction wells are no longer used as per recommendation 6.1.2, well maintenance
costs would be reduced substantially. Assuming that approximately 75 percent of the well rehabilitation
costs currently pertain to the shallow on-site wells (the remaining maintenance costs are mostly related to
injection wells), savings of 75 percent of the well rehabilitation costs listed in Table 6, or approximately
$91,500 per year, are estimated. The optimization review team notes the site team has already suggested
elimination of extraction at the on-site extraction wells, in large part to eliminate much of the well
rehabilitation effort and cost.
30
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6.3
Recommendations for Technical Improvement
6.3.1 Evaluate Operation with Only One Air Stripper For Modified
System
After the planned replacement extraction wells have been installed and are operating, the total flow rate of
the extraction system should be assessed against the need to continue operation of both of the air
strippers. With the current flow of less than 200 gpm and future flow likely to be less than 200 gpm, one
stripper could be taken off-line. The site team may need to replace the stripper effluent pumps to allow
the stripper to be taken off-line. The potential cost savings of operating only one air stripper can be
compared against the replacement costs of the effluent pump necessary for operation of only one air
stripper. Operating an extra 30-horsepower blower requires approximately $13,800/year in electric costs,
so the cost of pump replacement would likely be paid for quickly and a change to one stripper would
likely be cost-effective. However, a detailed quantification of up-front costs and annual savings has not
been performed since the total future extraction rate is uncertain at this time.
6.3.2 Accurately Record Injection Rates for Each Location
The modeling update included as Appendix A to the Annual Report for September 2011-August 2012
stated the following: "The volume of water diverted to the impoundment was not metered, and meter
records for the injection wells appeared to be in error. Consequently, the volume of water injected at
wells versus the volume of water infiltrated at the impoundment is unknownDuring the optimization
review site visit, it was stated the when the new injection wells were added, they shared panels on the
SCADA with the adjacent injection wells in a manner that does not allow injection rates at individual
wells to be recorded. Given that modeling is a useful tool for evaluating extraction and injection
scenarios, and that injection rates can alter the capture zone of the extraction wells, it is recommended
that tools and techniques be implemented to accurately monitor injection rate at each location. These rates
should be summed and compared with the total discharge from the treatment system as a check on the
accuracy of the measurements. Discrepancies of more than 5 percent in these totals should be resolved.
An approximate effort of $15,000 is estimated to address this issue.
6.3.3 Include injection Well Screen Lengths in Well Construction
Table
The optimization review team notes that well construction information (including screened intervals) is
provided in the annual reports, but the construction information for the injection wells is not provided. It
is recommended that well construction information for the injection wells be included. Costs to
implement this recommendation are negligible.
6.3.4 Perform Simulations With No Recharge of Treated Water
The modeling indicates that a significant amount of treated water is recaptured, which increases the
extraction rate required for capture. Although the model simulations account for the recapture of treated
water, the modeling presented in the report does not illustrate the difference in capture that might result if
treated was not recharged to groundwater. (In other words, the model has not been used to illustrate how
much less extraction might be required to achieve similar capture if in absence of treated water being
recharged.) It is suggested that model simulations be performed to illustrate and optimize capture in the
absence of treated water being recharged. If the results show that the recharge of treated water is a
significant detriment to capture, or is causing a large increase in the amount of extraction required for
capture, then even greater effort might be merited for developing a re-use approach for the treated water.
Evaluating and documenting these scenarios with the current model should require less than $5,000.
31
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6.4
Considerations for Gaining Site Closeout
The groundwater remediation system is anticipated to continue operating under EPA supervision through
September 2020, when EPA will transfer operation and maintenance of the system to the TCEQ to
address any remaining contamination. The site team should make significant efforts to achieve consistent,
cost-effective system operation because operation will continue for many years based on the site
contaminant mass. The optimization review team does not believe that additional in situ technologies
should be considered until cost-effective operation of the current remedy is achieved. Any in situ remedy
would be extremely costly because of the large size of the contaminant plume and source area. It is
unclear how effective an in situ remedy would be at reducing the time span for remediation.
6.5 Recommendations Related to Environmental Footprint
Reduction
6.5.1 Replace/Eliminate the C3 Systems
The most significant footprint reductions would be associated with reducing electricity use by replacing
the C3 systems as described in recommendation 6.2.1. (Potential footprint reductions are also presented in
Section 6.2.1.)
6.6 Summary
Recommendations are provided in several categories including effectiveness, cost reduction, technical
improvement, site closeout, and environmental footprint reduction. Table 8 summarizes estimated costs
and savings associated with those recommendations. In particular, the recommendation to eliminate the
C3 systems requires the greatest capital cost, but has a very short payback period and results in significant
savings with respect to cost and environmental footprints.
32
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Table 8: Summary of Recommendations and Associated Costs
Kivniiiiiicii(|,iimn
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6.1.1 Add Sentinel
Monitoring Wells if Access
Allows
Effectiveness
$100,000
$1,000
May be limited by access
6.1.2 Finalize
Institutional Controls (ICS)
Effectiveness
Not quantified
(number of
parcels
uncertain)
Not quantified
$4,000 to $8,000 per
parcel for surveys and
related efforts required
for state-enforceable ICs
6.1.3 Implement
Changes to Extraction
Strategy
Effectiveness
Costs to install
and connect
new extraction
wells
(not quantified)
Not quantified
Site team planning to
add off-site pumping
wells EW-5R to EW-7R
(costs are significant but
are not quantified herein)
6.2.1 Replace/
Eliminate the C3 Systems
Cost Reduction
$450,000
($300,000 capital +
$150,000 install)
$ (1,800,000)
(GEO contract+
electric- fuel
recovery- thermal
oxidizer operation-
GAC)
Site team has started
process
6.2.2 Reduce Plant
Operator Level of Effort
Cost Reduction
$0
$ (57,200)
Caused by more simple
system resulting from
other recommendations
6.2.3 Reduce Groundwater
Monitoring
Cost Reduction
$0
$ (70,000)
6.2.4 Reduce PM/Support/
Reporting
Cost Reduction
$0
$ (61,000)
Caused by more simple
system resulting from
other recommendations
6.2.5 Reduce Well
Rehabilitation Costs
Cost Reduction
$0
$ (91,500)
Caused by elimination of
on-site remedy
extraction
6.3.1 Operate with Only
One Air Stripper (for
modified system)
Technical
Improvement
Not quantified
Not quantified
Larger discharge pumps
Site team started process
6.3.2 Accurately Record
Injection Rates for Each
Location
Technical
Improvement
$15,000
$0
6.3.3 Include Injection
Well Screen Lengths in
Well Construction Table
Technical
Improvement
negligible
$0
6.3.4 Perform Simulations
with no Recharge of
Treated Water
Technical
Improvement
$5,000
$0
6.5.1 Replace/
Eliminate the C3 Systems
Environmental
Footprint
Reduction
See 6.2.1
See 6.2.1
Same as 6.2.1
TOTAL
$570,000 plus
costs for
installing and
connecting
new extraction
wells and
implementing
ICs
More than
$ (2,000,000)
() indicates a cost savings.
33
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APPENDIX A
Select Figures from Site Documents
A-l
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DATE
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PROJECT NO
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FIGURE
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DATE
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exceeding MCL of 5 |jg/L
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Base Map Source:
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-------
APPENDIX B
Informational Quote:
Anguil Thermal Oxidizer
B-l
-------
ANGUIL For: Tetratech Proposal: AES-133256
MODEL 25 REGENERATIVE THERMAL OXIDIZER
Standard Base System
Design flow - 2,500 SCFM
99% destruction efficiency
95% thermal energy efficiency
1550ฐF oxidation temperature design
Skid mounted design
Two-chamber carbon steel reactor
Hot side bypass
High temperature ceramic fiber insulation
High temperature structured ceramic heat transfer media
Two (2) pneumatic vertical poppet valves with compressed air accumulation tank
Forced draft system fan and system motor (TEFC, 460V/3ph/60Hz)
Variable frequency drive
Burner (natural gas or propane fired) and fuel train (FM design)
Flame arrestor
Exhaust stack
PLC based controls with touch screen display (HMI)
NEMA 3R weatherproof control panel
Digital chart recorder and data logger
Remote communication via modem and Ethernet connectivity
Factory quality run and test prior to shipment
Start-up services, training of operators, operation & maintenance manuals
Shipment Terms
F.O.B. (Origin), Freight Prepaid & Add to the invoice
Budget Price
$290,000.00
**Due to the rapidly changing market price of specialty alloys Global reserves the right to
adjust the final price of the equipment accordingly to account for market price.
ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.anguil.com
8855 N. 55th Street' Milwaukee, Wisconsin 53223 Phone : 414-365-6400 Fax : 414-365-6410
-------
V'C
ANGUIL For: Tetratech Proposal: AES-133256
OPERATING COSTS - TECHNOLOGY COMPARISON &ฆ
Regnerative Thermal Oxidizer RTO /
/
4?'^'
SELECT TECHNOLOGY
Process
Flow
(SCFM)
Temperature
(ฐF)
Dilution
Flow
(SCFM)
voc
Load
(Ib/hr)
Electrical
Usage
(kW)
Electrical
Cost
($/hr)
Gas
Usage
(BTU/hr)
Gas
Cost i
($/hr) /
/Total
Cost
($/hr)
Month
Cost
1,500
120
1,000
91.00
7.73
$0.55
55,556
$0.39
$0.94
$676.00
1,500
120
0
55.00
2.31
$0.17
55,556
$0.39
$0.56
$6?6^0 i
1,500
120
0
25.00
2.31
$0.17
55,556
$0.39
$0.56
$402.40
1,500
120
0
15.00
2.31
$0.17
55,556
$0.39
$0.56 I
$402.40
1,500
120
0
10.00
2.31
$0.17
72,353
$0.51
$0.68
$402.40
1,500
120
0
5.00
2.36
$0.17
180,937 1
$1.27
$1.44
$487.06
1,500
120
0
0.00
2.41
$0.17
289,521
$2.03
$2.20
$1,034.32
Catalytic Oxidizer 65% Heat Exchanger
SELECT TECHNOLOGY
Process
Flow
(SCFM)
Temperature
TO
Dilution
Flow
(SCFM)
voc
Load
(Ib/hr)
Electrical
Usage
(kW)
Electrical
Cost
($/hr)
Gas
Usage
(BTU/hr)
Gas
Cost
($/hr)
Total
Cost
($/hr)
Monthy
Cost
1,500
120
1,000
91.00
5.92
$0.42
55,556
$0.39
$0.81
$582.40
1,500
120
0
55.00
1.85
$0.13
55,556
$0.39
$0.52
$373.60
1,500
120
0
25.00
1.95
$0.14
210,190
$1.47
$1.61
$1,160.16
1,500
120
0
15.00
2.03
$0.15
330,482
$2.31
$2.46
$1,773.63
1,500
120
0
10.00
2.06
$0.15
388,503
$2.72
$2.87
$2,066.05
1,500
120
0
5.00
2.10
$0.15
445,173
$3.12
$3.27
$2,351.67
1,500
120
0
0.00
2.13
$0.15
500,539
$3.50
$3.65
$2,630.72
Thermal Recouperative Oxidizer 65% Heat Exchanger
SELECT TECHNOLOGY
Process
Flow
(SCFM)
Temperature
(ฐF>
Dilution
Flow
(SCFM)
voc
Load
(Ib/hr)
Electrical
Usage
(kW)
Electrical
Cost
($/hr)
Gas
Usage
(BTU/hr)
Gas
Cost
($/hr)
Total
Cost
($/hr)
Month
Cost
1,500
120
0
135.00
4.14
$0.29
55,556
$0.39
$0.68
$488.80
1,500
120
0
90.00
4.37
$0.31
446,836
$3.13
$3.44
$488.80
1,500
120
0
55.00
4.81
$0.34
1,212,052
$8.48
$8.82
$2,475.25
1,500
120
0
25.00
5.20
$0.37
1,867,951
$13.08
$13.45
$6,353.54
1,500
120
0
5.00
5.45
$0.39
2,305,218
$16.14
$16.53
$9,680.88
1,500
120
0
0.00
5.51
$0.39
2,414,534
$16.90
$17.29
$11,899.10
ANGUIL ENVIRONMENTAL SYSTEMS, INC. ~ www.anguil.com
8855 N. 55th Street Milwaukee, Wisconsin 53223 Phone : 414-365-6400 Fax : 414-365-6410
-------
APPENDIX C
Input Summary for SEFA Footprint Analysis
C-l
-------
Appendix C:
Input Summary for SEFA Footprint Analysis
Appendix C: Input Summary for SEFA Footprint Analysis
For quantitative evaluation of the environmental footprint, the U.S. EPA Spreadsheets for
Environmental Footprint Analysis (SEFA) were used to organize this information and calculate
the environmental footprint metrics.
Two sets of SEFA files were used to evaluate the remedy as a whole and the alternative
suggested in the Optimization Review. The files are organized as follows:
"TotalRemedy" SEFA files: Entire Remedy Evaluation
o This set of SEFA files consists of one component that includes all contributors to
the O&M footprint for the original remedy design, including:
ฆ Material Use
ฆ Transportation of Materials
ฆ Waste Transport and Disposal
ฆ Transport of Personnel
ฆ Electricity Use
ฆ Off-Site Laboratory Analysis
"Recommendation" SEFA files: Evaluation of the C3 Systems and Suggested Alternative
o This set of SEFA files consists of two components to evaluate the footprint of just
the energy use and material use associated with the C3 systems and a
Regenerative Thermal Oxidizer (an alternative to the C3 systems).
o The "C3 System" component tab includes:
ฆ Electricity Use
ฆ Material Use
o The "Alternative System" component tab includes:
ฆ Electricity Use
ฆ Natural Gas Use
ฆ Material Use
The Total Remedy SEFA files have been used to evaluate the total environmental footprint of
annual O&M and calculate the footprint of each contributor (i.e. electricity use, transportation) as
a percentage of the total footprint. The Recommendation SEFA files have been used to evaluate
the potential reduction of environmental footprint that could be achieved by replacing the C3
units with a regenerative thermal oxidizer and replacing the zeolite wheel concentration with a
Vapor GAC unit.
Appendix C Page 2
-------
Appendix C:
Input Summary for SEFA Footprint Analysis
The follow tables detail the input to SEFA. These tables include a reference to where the
information can be found in the Optimization Review Report and/or documents Tetra Tech (TT)
reviewed and explain how the input values were derived and where they were inputted into the
SEFA files.
Total Remedy SEFA file input
Table A: Material Use Total Remedy
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Treatment Chemical -
Sodium Hypochlorite
Optimization Review - Section 5.1.2
o "13 gallons per day (gpd) of 12.5%
sodium hypochlorite"
A 12.5% solution of sodium hypochlorite
has roughly the same density of water
o Density of water = 8.35 lb/gal
13 gpd x 8.35 lb/gal * 365 days =
39620.75 lb/year
Material Use and Trans.
Selected: "Sodium Hypochlorite"
A user defined conversion factor
(See note below)
Input: 39620 lbs.
SRI 14 TotalRemedy energy.xlsx
Total Remedy ->Row 61
Treatment Chemical -
Sulfuric Acid
Optimization Review - Section 5.1.2
o "18 gpd of 93% sulfuric acid"
TT calculated 93% sulfuric acid has a
density of 14.9 lb/gal
o Density of sulfuric acid = 1.84 g/cm3
o Density of water = 1 g/cm3
o Density of 93% sulfuric acid = 1.84 x
.93 + 1 x .07 = 1.78 g/cm3 or 14.9 lb/gal
18 gpd x 14.9 lb/gal * 365 days = 97893
lb/year
Material Use and Trans.
Selected: "Sulfuric Acid"
A user defined conversion factor
(See note below)
Input: 97890 lbs.
SRI 14 TotalRemedy energy.xlsx
Total Remedy Row 68
Treatment Chemical -
Antiscalent
TT reviewed the document "Annual
O&M Costs (September 2012 - August
2013)" from the Site that specified:
o 2 x 55-gal drum every 60 days = 1.8
gpd
Antiscalent has a density of 1.3 g/cm3 or
10.8 lb/gal
o From Alfalaval - Alpacon Altreat 400
(scale inhibitor)
1.8 gpdx 10.8 lb/gal * 365 days = 7095.6
lb/year
Material Use and Trans.
Selected: "Anitscalent"
A user defined conversion factor
(See note below)
Input: 7100 lbs.
SRI 14 TotalRemedy energy.xlsx
Total Remedy Row 69
Treatment Chemical -
Defoamer
TT reviewed the document "Annual
O&M Costs (September 2012 - August
2013)" from the Site that specified:
o 2 x 55-gal drum every 75 days = 1.5
gpd
No literature value for density of
defoamer could be found so TT assumed
the density is roughly equal to water
1.5 gpdx 8.35 lb/gal * 365 days =
4571.63 lb/year
Material Use and Trans.
Selected: "Defoamer"
A user defined conversion factor
(See note below)
Input: 4570 lbs.
SRI 14 TotalRemedy energy.xlsx
Total Remedy ->Row 70
Appendix C Page 3
-------
Appendix C:
Input Summary for SEFA Footprint Analysis
Treatment Material -
Optimization Review - Section 5.3.4
Material Use and Trans.
Virgin GAC
o "GAC change-outs have also been
minimal, with only one change of
Selected: "Virgin GAC (coal
10,000 pounds in four years"
based)"
TT assumed GAC consumption is
Input: 2500 lbs.
approximately 2,500 lb/year
SRI 14 TotalRemedy energy.xlsx
Total Remedy ->Row 71
Note on User Defined Conversion Factors for Treatment Materials:
For all of the materials except Virgin GAC, a user defined conversion factor was used. The
conversion factor used for these materials was taken from the Final ESTCP Report, Quantifying
Life-Cycle Environmental Footprints of Soil and Groundwater Remedies, July 2013 (ESTCTP
Proj ect # ER-201127). All the materials used the Category 2 - Low Footprint conversion factors
from Table 16: Chart of Suggested Footprint Factors for Generic Materials. The conversion
factors were inputted into the "User Defined Factors" tab in SRI 14_TotalRemedy_energy.xlsx
for each of the four materials as follows:
Metric
Conversion Factor
per 1 lb. of Material
Units
Energy
0.0043
MMBtus/unit
C02e
0.5
lbs/unit
NOx
0.001
lbs/unit
SOx
0.002
lbs/unit
PM
0.0004
lbs/unit
Note: A conversion factor for Air Toxics is not
included in Table 16 from the ESTCP Report
Appendix C Page 4
-------
Appendix C:
Input Summary for SEFA Footprint Analysis
Table B: Transportation of Materials Total Remedy
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Transportation of Treatment
Materials -
Sodium Hypochlorite and
Sulfuric Acid
TT reviewed the document "Annual
O&M Costs (September 2012 - August
2013)" from the Site that specified:
o Metals Filtration Chemicals are bought
from Univar, Odessa, TX
TT assumed that the Sodium
Hypochlorite and Sulfuric Acid are
delivered together and are on a freight
truck making other deliveries
Distance from the Site to Odessa, TX is
approximately 140 miles
Material Use and Trans.
Input for each material: 140
miles one-way
Selected: Truck freight (gptm),
Diesel
279.1 Gallons of Fuel Used
SRI 14 TotalRemedy energy.xlsx
Total Remedy ~^Row 67 & 68
Transportation of Treatment
Materials -
Antiscalent and Defoamer
TT reviewed the document "Annual
O&M Costs (September 2012 - August
2013)" from the Site that specified:
o Antiscalent/Defoamer are bought from
Analytix Technologies, Houston, TX
TT assumed that the antiscalent and
defoamer are delivered together and are
on a freight truck making other deliveries
Distance from the Site to Houston, TX is
approximately 550 miles
Material Use and Trans.
Input for each material: 550
miles one-way
Selected: Truck freight (gptm),
Diesel
93 Gallons of Fuel Used
SRI 14 TotalRemedy energy.xlsx
TotalRemedy ~^Row 69 & 70
Transportation of Treatment
Materials -
Virgin GAC
TT was unable to find source of GAC so
the SEFA default value of 500 miles
travel to site was used
Material Use and Trans.
Input: No Input (Use Default)
Selected: Truck freight (gptm),
Diesel
18.1 Gallons of Fuel Used
SRI 14 TotalRemedy energy.xlsx
Total Remedy ->Row 71
Appendix C Page 5
-------
Appendix C:
Input Summary for SEFA Footprint Analysis
Table C: Waste Transportation/Disposal Total Remedy
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Transportation and Disposal
of used GAC
Optimization Review - Section 5.3.4
o "GAC change-outs have also been
minimal, with only one change of
10,000 pounds in four years"
TT assumed GAC consumption is
approximately 2,500 lb/year
TT assumed waste travels approximately
200 miles to non-hazardous waste landfill
Waste Transport and Disposal
Selected: Non-hazardous waste
landfill
Input: 1.25 tons, 200 miles of
transport
Selected: Truck freight (gptm),
Diesel
7.3 Gallons of Fuel Used
SRI 14 TotalRemedy energy.xlsx
Total Remedy Row 89
Transportation and Disposal
of Tank Sludge
TT reviewed the document "Annual
O&M Costs (September 2012 - August
2013)" from the Site that specified:
o 90 bbls of Tank Sludge in 2010; up to
120 bbls scheduled for Oct/Nov 2013
TT assumed Tank Sludge disposal is 100
bbls/year
Sewage Sludge has a density of 6.02
lb/gal
o From Aqua-Calc.com
1 bbl = 42 gals
42 gals/bbl x 6.02 lb/gal x 100 bbls/yr =
25284 lbs of tank sludge disposal
TT assumed waste travels approximately
200 miles to non-hazardous waste landfill
Waste Transport and Disposal
Selected: Non-hazardous waste
landfill
Input: 12.6 tons, 200 miles of
transport
Selected: Truck freight (gptm),
Diesel
73.1 Gallons of Fuel Used
SRI 14 TotalRemedy energy.xlsx
Total Remedy Row 90
Appendix C Page 6
-------
Appendix C:
Input Summary for SEFA Footprint Analysis
Table D: Transportation of Personnel Total Remedy
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Permanent operator
transportation during O&M
period
TT assumes 1 full time O&M personnel
working 5 days a week, 52 weeks a year.
TT assumes operator commutes from
Lubbock, TX to site, which is
approximately 68 miles roundtrip, and
drives a light duty truck.
Labor, Mobilizations, Mileage,
and Fuel
Input: 1 Full Time Operator
Operators, 1 crew, 260 days, 8
hours per day, 260 trips, 68 miles
roundtrip
Selected: Light-Duty Truck,
Gasoline
1040 Gallons of Fuel Used
SRI 14 TotalRemedy energy.xlsx
Total Remedy Row 16
Table E: Electricity Use Total Remedy
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Annual Electricity Use for
O&M
Optimization Review - Section 5.2.4
o "Metered electrical use for the period
September 2011 to August 2012 was
approximately 4,500,000 kWh"
On-Site Electricity Use
Input: 4500000
4500000 kWh, Energy Used
SRI 14 TotalRemedy energy.xlsx
TotalRemedy Row 59
Table F: Fuel Mix for Grid Electricity Total Remedy and Recommendation
The grid electricity fuel mix for entry in the "Grid Electricity" is specified in Section 5.3.1 of the
Optimization Review Report. This fuel mix is used in both the Total Remedy and
Recommendation SEFA files.
1- li'l ll'll llx SnlMYi-
1 m l Mix
Coal
35
Natural Gas
13
Oil
1
Nuclear
29
Nonrenewable T otal
78
Wind
12
Solar
2
Geothermal
0
Biomass
1
Hydro
7
Renewable T otal
22
Appendix C Page 7
-------
Appendix C:
Input Summary for SEFA Footprint Analysis
Table G: Off-Site Laboratory Analysis Total Remedy
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Annual GW Analysis
Sampling
Based on Section 3.3.2 of the
Optimization Review and TT professional
judgment, groundwater analysis sampling
consists of approximately 240 VOCs and
80 total metals samples a year
TT approximates the GW analysis
sampling costs $40,000 a year
Off-Site Laboratory Analysis
Input: GW analysis, 240 VOCs
and 80 metals per year, 40000
Unit Cost, 1 Number of Samples
SRI 14 TotalRemedy energy.xlsx
Total Remedy Row 102
Annual Process Sampling
Based on Section 3.3.1 of the
Optimization Review and TT professional
judgment, process sampling consists of
approximately 48 water samples and 96
air samples a year
TT approximates the process sampling
costs $24,000 a year
Off-Site Laboratory Analysis
Input: Process, 48 water and 96
air a year, 24000 Unit Cost, 1
Number of Samples
SRI 14 TotalRemedy energy.xlsx
Total Remedy Row 103
Recommendation SEFA file input C3 System Components
The C3 System tab of the Recommendation SEFA file has the same GAC material use as the
Total Remedy SEFA file but only has 75% of the electricity use. This is because approximately
75% of the total electricity use is contributed to the C3 Systems and only that portion of the total
electricity use could be affected by changing from the C3 systems to a regenerative thermal
oxidation System.
Table H: Material Use Recommendation C3 System tab
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Treatment Material -
Virgin GAC
Optimization Review - Section 5.3.4
o "GAC change-outs have also been
minimal, with only one change of
10,000 pounds in four years"
TT assumed GAC consumption is
approximately 2,500 lb/year
Material Use and Trans.
Selected: "Virgin GAC (coal based)"
Input: 2500 lbs.
SRI 14 Recommendation energy.xlsx
->C3 System ->Row 61
Table I: Electricity Use Recommendation C3 System tab
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Annual Electricity Use for
C3 System
Optimization Review - Section 5.3.1
o "The C3 system uses 281,250 kWh
per month, which is 75% of the total
remedy electricity use of 4,500,000
kWh per year."
75% of 4,500,000 kWh = 3,375,000
kWh
On-Site Electricity Use
Input: 3375000
3375000 kWh, Energy Used
SRI 14 Recommendation energy.xlsx
C3 System ~^Row 59
Appendix C Page 8
-------
Appendix C:
Input Summary for SEFA Footprint Analysis
Recommendation SEFA file input Alternative System Components
The Alternative System tab of the Recommendation SEFA file has revised electricity use and
includes natural gas use. These inputs are based on Section 6.2.1 of the Optimization Review
Report which states that the C3 systems could be replaced with a regenerative thermal oxidizer.
In addition to replacing the C3 units, Section 5.1.6 of the Optimization Review Report states
additional savings could be made by replacing the zeolite wheel concentrator with a vapor GAC
unit. This increase to the amount of GAC used has also been documented below and is included
in the Alternative System tab.
Table J: Material Use Recommendation Alternative System tab
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Treatment Material -
Virgin GAC
Optimization Review - Section 5.1.6
o The first suggestion states that the
zeolite wheel concentrator could be
replaced with Vapor GAC
TT assumed that the additional Vapor
GAC unit would consume
approximately 10,000 lbs of GAC a
year
Material Use and Trans.
Selected: "Virgin GAC (coal based)"
Input: 10000 lbs.
SRI 14 Recommendation energy.xlsx
Alternative System ~^Row 61
Table K: Electricity Use Recommendation Alternative System tab
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Annual Electricity Use for
Regenerative Thermal
Oxidizer
Optimization Review - Section 6.2.1
o "Thermal oxidizer for the deep SVE
system using 66,780 kWh per year of
electricity"
On-Site Electricity Use
Input: 66780
66780 kWh, Energy Used
SRI 14 Recommendation energy.xlsx
Alternative System ~^Row 59
Table L: Natural Gas Use Recommendation Alternative System tab
Item for Footprint
Evaluation
Source of Information and/or
Comments
Input Values to SEFA
Annual Natural Gas Use for
Regenerative Thermal
Oxidizer
Optimization Review - Section 6.2.1
o "thermal oxidizer for the deep SVE
system using 24,623 hundred cubic
feet (ccf) of natural gas"
o Thermal oxidizer running at 289,521
BTU per hour "to represent both the
fuel to be added to the thermal
oxidizer (in this case propane) as well
as the combustion of the site-related
VOCs"
On-Site Natural Gas Use
Input: Regenerative Thermox
System, 289521 power rating, 100%
efficiency, 8760 total hours
24623.34, Total ccf Used
SRI 14 Recommendation energy.xlsx
Alternative System ~^Row 45
Appendix C Page 9
------- |