Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming August 2015 Region 8 1595 Wynkoop St. Denver CO 80202 Five Points PCE Plume Superfund Site Proposed Plan / Notice of Public Comment Period The United States Environmental Protection Agency and Utah Department of Environmental Quality announce the Preferred Alternative for addressing the Five Points PCE Plume Site Davis County, Utah UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY Introduction The U.S. Environmental Protection Agency (EPA) and the Utah Department of Environmental Quality (UDEQ) seek public comment on the proposed cleanup plan for the Five Points PCE Plume Site (Site), located in Woods Cross and Bountiful, Davis County, Utah. This Proposed Plan summa- rizes the cleanup alternatives that were evaluated and pre- sents the Preferred Alternative for addressing the tetra- chloroethene (PCE) contamination in groundwater. EPA and UDEQ encourage the public to review the Pro- posed Plan and provide comments or concerns before the final remedy selection. Based on the information available at this time, EPA's and UDEQ's Preferred Alternative for addressing PCE contami- nation in groundwater is Containment at Plume Core and Plume Toe (Alternative 4). The Proposed Plan summarizes information that can be found in greater detail in the Remedial Investigation (RI) and the Feasibility Study (FS) Reports. These documents can be found in the Administrative Record File for this Site at the Davis County Library, South Branch or other reposi- tory locations listed on page 3. Additionally, the RI and FS Reports are available through the internet at http:// www2.epa.gov/region8/five-points-pce-plume. In order to gain a comprehensive understanding of the Site, EPA and UDEQ invite the public to review documents in the Administrative Record for the Site. This Proposed Plan fulfills the requirements of the Compre- hensive Environmental Response, Compensation, and Lia- bility Act (CERCLA) §117(a) and National Oil and Hazard- ous Substances Contingency Plan (NCP) §300.430(f)(2). EPA and UDEQ will select a final remedy for the Site after reviewing and considering all comments and information submitted during the public comment period. Based on the public comments and/or new information, EPA and UDEQ may modify the Preferred Alternative or select another al- ternative presented in this Proposed Plan. EPA and UDEQ will issue a document with responses to Mark Your Calendar! Public Comment Period: July 31, 2015 to August 31, 2015 Public Meeting Wednesday August 19, 2015 6:30 p.m.—8:00 p.m. Woods Cross Municipal Building 1555 South 800 West Woods Cross, UT 84087 Thursday August 20, 2015 6:30 p.m.—8:00 p.m. North Salt Lake City Hall 10 E. Center Street North Salt Lake City, UT 84054 Written or oral comments will be accepted at the meeting Send Written Comments to: Tony Howes Project Manager Utah Department of Environmental Quality (UDEQ) Division of Environmental Response and Remediation P.O. Box 144840 Salt Lake City, UT 84114-4840 E-mail: thowes@utah.gov Written comments must be postmarked by August 31, 2015 Page 1 of 8 ------- public comments, called a responsiveness summary, when it issues its final cleanup decision. Site Background The Site is located in northern Utah, on the bounda- ry of Woods Cross City and Bountiful City (Figure 1- 1) and consists of a groundwater plume contaminat- ed with PCE. The likely source of the PCE contami- nation is Your Valet Cleaners (YVC], a dry-cleaning facility in Bountiful, Utah which used PCE between 1964 and 2002. PCE levels greater than the federal and state stand- ards for drinking water, the maximum contaminant level (MCL) of 5 micrograms per liter (|ig/L) were observed in a Woods Cross City municipal drinking water well in 1996. As a result of this observation several investigations were completed in order to determine the extent and source of the contamina- tion. An assessment was completed by UDEQ in 1998- 1999 and included the installation of two monitor- ing wells and sampling of two Woods Cross City mu- nicipal wells. This assessment found PCE levels in groundwater as high as 310 (J.g/L and established YVC as the likely source for the PCE contamination. Two removal assessments were completed by EPA and UDEQ in November 1999 and July 2003. The agencies collected groundwater and sampled soil. These removal assessments confirmed the presence of PCE contamination in two Woods Cross City mu- nicipal drinking water wells and nearby monitoring wells. Soil samples collected during the July 2003 assessment found PCE contamination in subsurface soils at the YVC property. In April 2001 the UDEQ completed an Abbreviated Preliminary Assessment Report. This Report consol- idated and summarized information from previous investigations and determined that further assess- ment was needed under CERCLA. In October and November 2004, UDEQ conducted a Site Inspection which included the installation and sampling of two downgradient monitoring wells. This inspection provided information to support the site's placement on the National Priorities List (NPL). This investigation confirmed the presence of PCE concentrations greater than the MCL in a Woods Cross City municipal drinking water well and nearby monitoring wells. As a result of PCE contami- nation in groundwater, the EPA placed the Site on the NPL in September 2007. In September 2007 YVC, under an agreement with EPA, completed a Removal Action at their dry clean- ing property. The purpose of the Removal Action was to investigate and address possible PCE source areas at the YVC property. The Removal Action in- cluded completion of a ground penetrating radar survey, sample collection, excavation and disposal of contaminated soil with PCE levels greater than 3,000 micrograms per kilogram |.ig/kg and the re- moval of an underground storage tank. The EPA and UDEQ conducted an RI from July 2009 through April 2013. Work to support the RI was performed in phases and a total of 17 monitoring wells were installed and four soil borings were com- pleted. Soil boring results from the RI showed that PCE lev- els in soil at the YVC property were now well below the removal action level of 3,000 (ig/kg and would no longer represent a continued source to ground- water. Based on PCE concentrations in soil, cleanup alternatives presented in this Proposed Plan are for groundwater. The highest PCE concentration found in groundwater during the RI was 46 pg/L. Site Characteristics The Site is located in an area of residential and com- Figure 1-1 Location of the Five Points PCE Plume Site Page 2 of 8 ------- mercial use. The Site was previously known as the Bountiful Five Points PCE Plume Site, but was re- named to reflect the impact of the plume on munici- pal wells in Woods Cross City. The Five Points PCE Plume is approximately 1,360 feet wide by 6,080 feet long and extends from moni- toring well MW-1-2004 in the east to the Freda Well, a North Salt Lake City municipal drinking wa- ter well, in the west (Figure 1-2). The plume is ap- proximately 109 feet below ground surface in the eastern portion of the Site and descends downward to a depth of approximately 330 feet below ground surface in the western portion of the Site. The downward descent of the plume is likely due to cur- rent and historic pumping of nearby municipal wa- ter supply wells located near the toe or western edge of the plume. PCE contamination has been found in drinking wa- ter wells operated by Woods Cross City and North Salt Lake City and concentrations in those wells have been low. Several other municipal drinking water wells threatened by PCE contamination are located west and downgradient of the groundwater plume. The highest PCE concentration found in a municipal drinking water well during the RI was 5.4 |ig/L. Although, PCE concentrations in municipal wells have been low, Woods Cross City built a treat- ment facility that removes PCE from drinking water. Summary of Site Risks EPA and UDEQ performed a Human Health Risk As- sessment (HHRA) to evaluate potential risks from exposure to the groundwater contamination at the Site. Ecological risks were not evaluated due to the absence of exposure pathways for ecological recep- tors since contamination is found in groundwater at depths greater than 100 feet. The HHRA was completed as part of the RI and iden- tified PCE as the contaminant of concern in ground- water. The HHRA evaluated domestic use of ground- water by child and adult residents. Exposure path- ways evaluated in the HHRA were: (1) intentional ingestion of groundwater, (2) dermal exposure to groundwater, and (3) inhalation of contaminants in indoor air from household use of groundwater. The HHRA determined that there is a potential for unacceptable risk for all three exposure pathways evaluated in the HHRA, as a result of PCE contami- nation in groundwater. However, culinary water providers are required to meet federal and state standards for drinking water, the MCL of 5 |ig/L for PCE. It is EPA's and UDEQ's judgment that the Preferred Information Repositories The Proposed Plan and other documents in the Administrative Record are available at the follow- ing locations: Davis County Library, South Branch 725 South Main Street Bountiful, Utah 840101 801-295-8732 Utah Department of Environmental Quality, Division of Environmental Response and Remediation 195 North 1950 West Salt Lake City, Utah 84114-4840 Hours: M - F, 8 a.m. to 4 p.m. 801-536-4100 EPA Superfund Records Center 1595 Wynkoop Street Denver, CO 80202-1129 To request copies of administrative record docu- ments call: 303-312-7273 or 800-227-8917 ext. 312-7273 (toll free Region 8 only) Alternative identified in this Proposed Plan, or one of the other active measures considered in the Pro- posed Plan, is necessary to protect the public from exposure to contaminated groundwater. Cleanup Objectives The cleanup objectives for the Five Points PCE Plume Site are: • Prevent human exposure to contaminated groundwater; • Prevent future migration of contaminated groundwater; and • Restore groundwater to beneficial use (drinking water standards) as a drinking water aquifer. EPA and UDEQ established a Preliminary Remedia- tion Goal (PRG) for PCE of 5[ig/L. The final action level for PCE will be established in the Record of Decision (ROD). Summary of Remedial Alternatives The FS identified a number of alternatives, including a No Action Alternative. A detailed evaluation was completed for five alternatives. The alternatives retained for detailed analysis are presented below. Other alternatives were eliminat- ed because they would not effectively address the Page 3 of 8 ------- •"I I i/r£ Q_ U Q_ O Q_ (L) > 3 CuO Page 4 of 8 ------- Contaminant of Concern Based on the Human Health Risk Assessment, tetra- chloroethene, also known as perchloroethylene (PCE) is the contaminant of concern in ground- water at the Five Points PCE Plume Site. PCE is a solvent used for the dry cleaning of fabrics and for metal-degreasing operations. It is also used as a starting material (building block) for making other chemicals and is used in some consumer products. PCE can enter the ground in liquid form through spills, leaky pipes, leaky tanks, machine leaks, and from improperly handled waste. If sufficient quanti- ties are released to soils, the PCE percolates down into the water table, where it dissolves into ground- water and forms a "plume" of contaminated groundwater. The contaminant plume then mi- grates in the direction of groundwater flow. EPA and the UDEQ consider PCE in drinking water a potential risk to human health. EPA and UDEQ have defined the MCL for PCE as 5 micrograms per liter. Some people who drink water containing PCE in excess of the MCL for many years could have prob- lems with their liver and may have an increased risk of getting cancer. In addition, exposure to very high concentrations of PCE vapors can cause dizziness, headaches, sleepi- ness, confusion, difficulty speaking and walking nausea, unconsciousness, and sometimes death. contamination, could not be implemented, or would have excessive costs. The Preferred Alternative for addressing PCE con- tamination in groundwater is Alternative 4, Contain- ment at Plume Core and Plume Toe. Five Year Reviews will be required for all the alter- natives evaluated, including Alternative 1. Common elements: With the exception of the No Action Alternative, land use restrictions or Institu- tional Controls (ICs) preventing the drilling and in- stallation of domestic groundwater wells are re- quired until Remedial Action Objectives (RAOs) are achieved for each alternative in order to prevent unacceptable human exposure to the contaminant of concern. The UDEQ and EPA will work with the Utah Department of Water Rights and local jurisdic- tions to establish ICs for restricting new domestic well development. In addition to ICs, Alternatives 2, 3, 4, and 5 consist of groundwater extraction, treatment, and discharge to a Publicly Owned Treatment Works (POTW). Alternative 1—No Action Capital Cost: $0 Operation & Maintenance Cost: $0 Present Worth Cost (30 year): $0 Construction time frame: None Federal regulations require that a "no action" alter- native be considered in order to provide a compari- son between potential remedial alternatives. Under this alternative, no action would be taken to address the contaminated groundwater plume. Groundwa- ter contamination would remain in its current state and risks to human health would remain un- changed. Alternative 2—Containment at Plume Toe Capital Cost: $731,000 Operation & Maintenance Cost: $199,000/yr Present Worth Cost (30 year): $3,370,000 Construction time frame: 3 months Estimated time frame to achieve cleanup objec- tives/RAOs: 30 years based on three dimensional groundwater modeling. This alternative consists of hydraulic containment at the plume edge or toe to prevent further migra- tion of PCE contaminated groundwater. Alternative 2 includes the installation of one groundwater extraction well for hydraulic contain- ment of the PCE plume, four performance monitor- ing wells, and the groundwater extraction system including pumps, piping, and facilities. This alterna- tive assumes that two North Salt Lake City drinking water wells would continue to be operated. Howev- er, their use is not considered part of the remedy. Hydraulic containment will be accomplished by ex- tracting groundwater at an estimated rate of 300 gallons/minute. Extracted groundwater will be dis- charged to a POTW with granular activated carbon (GAC) pretreatment, if necessary. Operation of the extraction system at the plume toe will prevent contaminated groundwater from flow- ing to downgradient drinking water wells, thereby containing the contaminated groundwater plume. Effectiveness of the extraction system will be moni- tored using water level measurements, monitoring well sampling, and system influent/effluent sam- pling. Alternative 3—Containment at Plume Core Capital Cost: $481,000 Operation & Maintenance Cost: $180,000/yr Present Worth Cost (30 year): $2,725,000 Page 5 of 8 ------- Construction time frame: 3 months Estimated time frame to achieve cleanup objec- tives/RAOs: 25 years based on three dimensional groundwater modeling. This alternative consists of hydraulic containment at the plume core to prevent further migration of higher PCE concentrations (e.g., greater than 20 [ig/ L). Alternative 3 includes installation of one groundwa- ter extraction well for hydraulic containment of the plume core, three performance monitoring wells, and a groundwater extraction system including pumps, piping, and facilities. Hydraulic containment will be accomplished by ex- tracting groundwater at an estimated rate of 200 gallons/minute. Extracted groundwater will be dis- charged to a POTW with GAC pretreatment, which may be necessary as a result of higher PCE levels found in the plume core. This alternative will prevent migration of higher PCE concentrations found in the plume core and will reduce the overall plume mass, but does not prevent further migration of PCE concentrations found at the plume toe. This alternative assumes that two North Salt Lake City drinking water wells would continue to be operated. However, their use is not considered part of the remedy. Effectiveness of the system will be monitored using water level meas- urements, monitoring well sampling, and system influent/effluent sampling. Alternative 4—Containment at Plume Core and Plume Toe (The Preferred Alternative) Capital Cost: $1,212,000 Operation & Maintenance Cost: $254,000/yr Present Worth Cost (30 year): $4,086,000 Construction time frame: 3 to 6 months Estimated time frame to achieve cleanup objec- tives/RAOs: 20 years based on three dimensional groundwater modeling. Alternative 4 is a combination of Alternative 2 and Alternative 3. This alternative consists of hydraulic containment at the plume edge or toe to prevent further migra- tion of PCE contaminated groundwater and hydrau- lic containment at the plume core to reduce the overall mass of the plume and prevent further mi- gration of the higher PCE concentrations. This alter- native assumes that two North Salt Lake City drink- ing water wells would continue to be operated. However, their use is not considered part of the remedy. Alternative 4 includes the installation of two extrac- tion wells for hydraulic containment of the PCE plume, seven monitoring wells, and a groundwater extraction system including pumps, piping, and fa- cilities. Hydraulic containment will be accomplished by ex- tracting groundwater at an estimated rate of 300 gallons/minute from one well at the plume toe and at an estimated 200 gallons/minute from one well located at the plume core. Extracted groundwater will be discharged to a POTW with GAC pretreat- ment, if necessary. This alternative will provide hydraulic containment at the plume toe, prevent contaminated groundwa- ter from flowing to downgradient drinking water wells and reduce the risk of direct contact or inges- tion of contaminated groundwater through domes- tic use. Groundwater containment at the plume core will prevent migration of higher PCE concentrations found in the plume core and will reduce the overall plume mass. Effectiveness of the system will be monitored using water level measurements, moni- toring well sampling, and system influent/effluent sampling. Alternative 5—Containment at Plume Toe and ISCO at Plume Core Capital Cost: $3,364,000 Operation & Maintenance Cost: $220,000/yr Present Worth Cost (30 year): $9,097,000 Construction time frame: 9 to 12 months Estimated time frame to achieve cleanup objec- tives/RAOs: 25 years based on three dimensional groundwater modeling. This alternative consists of hydraulic containment at the plume edge or toe to prevent further migra- tion of PCE contaminated groundwater and in-situ chemical oxidation (ISCO) treatment at the plume core to reduce the overall mass of the plume and prevent further migration of the higher PCE concen- trations. Alternative 5 includes all of Alternative 2 as well as installation of 38 injection wells and four monitoring wells, and injection of a chemical oxi- dant every three years. Alternative 5 consists of injecting an estimated 286,000 pounds of a potassium permanganate with approximately 1.7 million gallons of water, and groundwater extraction at an estimated rate of 300 gallons per minute from one extraction well in order to provide hydraulic containment of the plume toe. This alternative assumes that two North Salt Lake Page 6 of 8 ------- City drinking water wells would continue to be op- erated. However, their use is not considered part of the remedy. Operation of the extraction system will result in hy- draulic containment at the plume toe, prevent con- taminated groundwater from flowing to downgradi- ent drinking water wells and reduces the risk of di- rect contact or ingestion of contaminated ground- water through domestic use. ISCO treatment at the plume core will prevent migration of the higher PCE concentrations and reduce the overall plume mass. Effectiveness of the hydraulic containment system will be monitored using water level measurements and system influent/effluent sampling and effective- ness of ISCO would be evaluated based on volatile organic chemical (VOC) concentrations and ground- water geochemistry within and downgradient of the treatment area. Evaluation of Alternatives Nine criteria are used to evaluate the different re- mediation alternatives individually and against each other in order to select a remedy. This section of the Proposed Plan profiles the relative performance of each alternative against the nine criteria, noting how it compares to the other options under consid- eration. The nine evaluation criteria are discussed below. The "Detailed Analysis of the Alternatives" can be found in the FS. The first two criteria are threshold criteria and only alternatives that meet those threshold criteria can be chosen. 1. Overall Protection of Human Health and the Environment All of the alternatives except the "no action" alterna- tive would provide adequate protection of human health and the environment Alternatives 2, 3, 4, and 5 provide protection of human health since hydrau- lic containment would prevent migration of contam- inated groundwater to public drinking water wells and ICs that limit or prohibit well drilling to prevent potential exposures with COC until all RAOs are met Alternatives 3, 4, and 5 will reduce plume mass and prevent further migration of higher PCE concentra- tions found in the plume core. 2. Compliance with ARARs All of the alternatives, except the "no action" alter- native, comply with all the Federal or State Applica- ble or Relevant and Appropriate Requirements (ARARs). Since the Alternative 1 (no action) does not meet the threshold criteria it cannot be chosen and therefore not analyzed in the other criteria be- low. 3. Long-Term Effectiveness and Permanence Alternatives 2, 3, 4, and 5 will mitigate risk while the systems are in operation, and once cleanup objec- tives have been achieved there will be no unac- ceptable residual risk. Hydraulic containment will prevent contaminated groundwater from migrating to drinking water wells. ICs will effectively limit well drilling and groundwater use. Alternatives 3, 4, and 5 include treatment at the plume core which will reduce the period of time needed to reach cleanup objectives. 4. Reduction of Toxicity, Mobility, or Volume of Contaminants through Treatment Toxicity, mobility, and volume of the plume would be reduced as extracted groundwater is treated with GAC or at the POTW in Alternatives 2, 3, 4, and 5 and by ISCO in Alternative 5. 5. Short-Term Effectiveness Alternatives 2, 3, 4, and 5 are based on reliable and operational technologies that are well understood. Alternatives 2, 3, and 4 will pose no additional risk to the community and a low level of risk to workers during remediation. Alternative 5 poses some short- term risk to workers during use of chemical oxi- dants. For all alternatives, proper personal protec- tive and safety equipment will mitigate the risk of exposure to workers. Alternative 5 may result in significant disruption of residential neighborhoods during construction and injection. Alternative 4 is estimated to meet RAOs in 20 years, Alternatives 3 and 5 in 25 years, and Alternative 2 in 30 years. 6. Implementability Construction, operation and maintenance of alterna- tives 2, 3, 4, and 5 involve standard techniques. Equipment and specialists for Alternatives 2, 3, and 4 are readily available from various sources. Alter- native 5 would require specialized injection con- tractors. Effectiveness of Alternatives 2, 3, 4, and 5 would be evaluated through water level measure- ments, groundwater sampling and influent/effluent sampling. Alternatives 2, 3, 4, and 5 would require a moderate level of coordination with the local POTW for groundwater disposal, and state agencies for water rights. Alternative 5 would also require a moderate level of coordination with state, local, and federal agencies for injection. Extracted groundwater treat- ment is readily available, if required. There would be no ex-situ treatment required for ISCO. Coordination with Utah Department of Water Rights Page 7 of 8 ------- and local jurisdictions will be required to implement ICs. 7. Cost The estimated present worth cost of Alternative 3 ($2,725,000) has the lowest cost, followed by Alter- native 2 ($3,370,000), Alternative 4 ($4,086,000), and Alternative 5 ($9,097,000). 8. State/Support Agency Acceptance UDEQ has been the lead agency in conducting the RI and FS, and agrees with EPA on the Preferred Alter- native. However, UDEQ will provide final acceptance of, or comment on the Preferred Alternative after considering public comment 9. Community Acceptance Community acceptance of the Preferred Alternative will be evaluated after the public comment period ends and will be described in the ROD for the Site. Summary of the Preferred Alternative The Preferred Alternative for cleaning up the Five Points PCE Plume Site is Alternative 4 Containment at Plume Core and Plume Toe. This alternative is recommended because it is expected to meet RAOs sooner than other alternatives. Costs associated with this alternative are comparable or less than other alternatives that were considered and uses relatively simple and effective technology and treat- ment components. The Preferred Alternative prevents further migra- tion of the PCE contamination at the plume edge or toe and plume core through hydraulic containment The extracted groundwater will be treated, thereby reducing toxicity, mobility, and volume of contami- nation. The Preferred Alternative also uses ICs to reduce the risk of direct contact or ingestion of con- taminated groundwater through domestic use until all RAOs are met and uses groundwater pump and treat to reduce the overall plume mass. Based on information currently available, the EPA and UDEQ believe that the Preferred Alternative meets the threshold criteria and provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria. EPA and UDEQ believe that the Preferred Alterna- tive will be protective of human health and the envi- ronment The Preferred Alternative is expected to comply with ARARs, is cost effective, and utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable. Based on public comments or new information, EPA List of Acronyms |ig/kg micrograms per kilogram |ig/L micrograms per liter ARARs Applicable or Relevant and Appro- priate Requirements CERCLA Comprehensive Environmental Res- ponse, Compensation, and Liability Act EPA U.S. Environmental Protection Agen- cy FS Feasibility Study GAC Granular Activated Carbon HHRA Human Health Risk Assessment ICs Institutional Controls ISCO In-situ Chemical Oxidation MCL Maximum Contaminant Level NCP National Oil and Hazardous Sub- stances Contingency Plan NPL National Priorities List PCE Tetrachloroethene POTW Publicly Owned Treatment Works PRG Preliminary Remediation Goal RAOs Remedial Action Objectives RI Remedial Investigation ROD Record of Decision UDEQ Utah Department of Environmental Quality VOC Volatile Organic Chemical YVC Your Valet Cleaners and UDEQ may change the Preferred Alternative or select another alternative presented in this Pro- posed Plan. Community Participation EPA and UDEQ are distributing this Proposed Plan for public review and comment Those who would like to know more about the information that was considered in selecting the Preferred Alternatives may find that information in the Site Administrative Record (see page 3 for locations). The dates for the public comment period; and the date, location, and time of the public meeting are provided on the front page of this Proposed Plan. 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